If you’ve never heard of the State Building Code Council (SBCC), you’d be far from the only one. State government often relies on appointed technical committees to deal with specialty areas, such as updating the state building code every three years. These committees can have a big impact on our daily lives without attracting much notice.
That lack of attention is an opportunity to push for some pretty major changes without much public scrutiny. That’s what one SBCC subcommittee is attempting to do this week. Its new proposal, finalized last Friday and to be voted on by the full SBCC this Friday, would essentially mandate the use of Dedicated Outdoor Air Systems (DOAS) in all new and remodeled commercial buildings. The purpose of these systems is to allow outside air ventilation into a building separate from conditioned air. No other state mandates the use of DOAS.
It’s an attempt to jam through by bureaucratic process new rules that are unlikely to make it through the Legislature. The proposal needs a 2/3 yes vote on Friday, or the matter will go to the Legislature instead.
Right for every building?
The proposed DOAS rule is a classic top-down, one-size-fits-all mandate that proponents push for well before all the facts are in. Consider:
- The proposed rule is based on a comparison of just three buildings. That is not an extensive study. The three buildings are all similar and within 30 miles of each other in Western Washington, yet this would be a statewide standard. Are DOAS appropriate for all of Washington’s climate zones? Are other approaches more appropriate for some building types? The SBCC has looked at too few buildings and areas to really know.
- Rather than a performance-based approach, the DOAS proposal mandates one particular technology. Why require a certain technology, which may not be right for every commercial building, instead of a goal based on actual, measurable energy efficiency?
- The DOAS proposal is being pushed by the City of Seattle’s Energy Code Director, who for some reason is the designated “architect” representative to the SBCC. Other areas of the state might see this as a Seattle-centric approach that ignores the reality on the ground outside Seattle’s green bubble.
DOAS can help increase the energy efficiency of some buildings. However, is our goal the reduction of energy use or the installation of DOAS? The fact is, some (for instance, companies that make DOAS) have much to gain from mandating a particular technology rather than setting a broader efficiency standard. It will mean money in their pockets, but it isn’t likely to be the best approach for every commercial building.
This focus on a certain system rather than good outcomes is generating opposition from many in the building industry, including those known for their focus on green buildings such as MacDonald-Miller (a company with close ties to Gov. Inslee), McKinstry, and Vulcan. They recognize that this rule would constrain them from using all available options to increase a building’s energy efficiency.
When it’s time for Friday’s vote, SBCC members would be wise to question if they have enough information to mandate such a sweeping rule. The better course is to vote it down, study these systems in much more depth, and come back to the table in three years with a stronger proposal.