Article reprinted from Western Roofing magazine Sept/Oct 2007.

 

 

The Draft Cool Roofing Proposals Get Chilly Reception

by Bill Callahan, executive director, ARC of the Bay Area Counties

 

 

The CEC held the second (and last) pre-rulemaking workshop on the draft 2008 Energy Code on June 13, in Sacramento. Despite promises that the process of developing the "cool roofing" aspects of the 2008 Code would be more inclusive of roofing contractors than was the case with the 2005 Energy Code, it was painfully obvious from the outset that the process has once again been dominated by roofing material manufacturers and that no attempt has been made to solicit the views of roofing contractors.

                  In the first instance, in reviewing written comments submitted prior to the workshop, association executive director Dr. William T. Callahan, Jr. found numerous references to "stakeholder meetings." An e-mail request of CEC staff for information about the dates, agendas, and guest lists for these meetings went unanswered. During the workshop, however, both CEC staff and a number of speakers confirmed that several so-called “stakeholder meetings" had indeed been held, that they had addressed issues such as the relative cost of various types of roofing systems and that only the manufacturing side of the roofing industry had been involved. No roofing contractors or contractor associations were invited to participate.

                  The lack of involvement on the part of the contracting segment of the industry was also painfully obvious from some of the substantive proposals contained in the draft 2008 Energy Code. The draft proposed standards for roof insulation, for example, are rife with flayed assumptions, inaccurate cost estimates, and impracticalities that betray their origins outside the “real world" of actually installing roofs.

                  Draft Sections 149 (b) 1 B iv and 149 (b) 1 B v establish new insulation requirements that are to apply when low-slope non-residential or high-rise residential roofs are replaced. If the existing roof insulation is less than R-19, then depending on the climate zone either R-8 or R-14 of continuous insulation must be installed above the roof deck.

                  In questioning CEC staff about this proposal, Callahan and Marty Dunham, vice president, Enterprise Roofing Service, Concord, elicited responses that demonstrated that the CEC had greatly underestimated the number of existing buildings with less than R-19 roof insulation; had not factored labor into their cost estimates; and had no appreciation of the cost and feasibility issues involved with raising the level of an existing roof, relocating or replacing drains and dents, disconnecting and reconnecting conduits, removing and reinstalling skylights and rooftop equipment, raising curbs, etc. Jay Salazar, chief building official, City of Vacaville, also pointed out that CEO staff did not seem to appreciate that raising the level of the roof and its associated appurtenances could run afoul of local building codes and zoning ordinances, as well.

                  In the course of these exchanges, it also came to light that the new R-8 or R-14 insulation requirement would not count toward any trade-off involving adding insulation to compensate for not installing a “cool roof.” The trade-off calculation would begin above the new R-8 or R-14 baseline, which greatly compounds the cost and feasibility issues associated with raising the level of the roof. In many cases, building owners would be faced with alternatives to "cool roofs" that are either prohibitively expensive or simply not feasible. Whether they would choose to comply with this de facto "cool roof" mandate is uncertain at best.

                  The association and many of its contractor members have vigorously protested these onerous proposals and have demanded that they be deleted from the draft 2008 Energy Code. In our view, far more energy would be saved by increasing understanding of and compliance with the “cool roofing” provisions of the existing Energy Code than by promulgating new insulation provisions that are either infeasible or so costly as to encourage widespread noncompliance. Stay tuned. •••