About Ellen Thorp

As associate executive director of the Bethesda, Md.-based EPDM Roofing Association, Ellen Thorp does advocacy work for ERA related to codes, standards and state regulations.

Codes and Standards: Dealing With Decision Makers

During the past ten years, in my role as Associate Executive Director of the EPDM Roofing Association (ERA), much of my professional focus has been on monitoring the development of building codes and standards that could impact the products of our members, and the people who use those products. This past decade has been marked by intense debate, focusing on issues such as how the design of buildings can save energy, protect the health of the people who work there, and resist the ravages of increasingly frequent intense and even cataclysmic weather events. It has been an important time for the roofing industry to be engaged.

Given the complexity of the multiple codes and standards that impact roofing, it’s important to know the difference between codes and standards. To clarify, building codes are a set of rules that are frequently adopted into law, and are designed to specify the minimum requirements to safeguard the health, safety and welfare of building occupants. Building standards are set by national organizations such as ASHRAE and determine the performance requirements of the materials used in building construction. While standards are frequently incorporated into codes, that is not always the case.

Each year, ERA has increased its commitment of time and resources to stay abreast of proposed changes in codes and standards. As part of this commitment, I have sat through, and participated in, countless hours of codes and standards meetings and hearings, as well as related meetings with individuals and groups who share ERA’s goals. When I started out, I felt that it was important for members of the roofing industry to stay involved in the code and standard-setting processes. A decade later, I am convinced that participation by the roofing industry is essential if codes and standards are to support the best possible service and products that we can give our customers.

A few insights, based on my experience:

1. Science speaks.

ERA members, because of their close relationship with contractors and consultants, want to make sure that the choice of building materials is left in the hands of the design professional, the consultant, the architect, the engineer, the contractor and, of course, ultimately the building owner or facility manager. When we have codes and standards that do not reflect science-based evidence and/or the best practices within the roofing industry, then those stakeholders may not be able to choose the best product for the job at hand. In some cases, proposed modifications to existing codes or standards are suggested by people from the industry. In those instances, our role is to provide research and evidence to support the proposed change. Either way, science-based testimony usually carries the day. Not always, but without good scientific evidence to support a specific position, the chances of winning are nil to none. It takes time and clear thought to influence the codes and standards process, but without a base of indisputable scientific evidence, it’s hard to get out of the starting gate.

2. Collaboration is essential.

We have always welcomed forging partnerships with like-minded roofing professionals. But there have also been times when we have acted as consulting partners with regulatory agencies. A recent example: when regulatory agencies across the Northeast and Mid-Atlantic states were charged with improving air quality, they chose to reduce the amount of allowable volatile organic compounds, or VOCs, in adhesive sealants. This was a very good idea, and the industry was certainly supportive of the intent, but the way in which many of those states intended to enact those VOC regulations would have crippled the roofing industry. Essentially, the agencies were taking a regulation that was written for the state of California and applying it universally across the New England and Mid-Atlantic States.

So, ERA conducted studies, showing how the climate of those Northeastern and Mid-Atlantic states was dissimilar from the climate of California. We also provided technical information on how product would react differently in those different climates, and then we asked for a delayed implementation period to allow the research and development divisions in our companies to develop new products. These new products are appropriate for use in the climates in question and still allow the regulatory agencies to achieve their goals, successfully reducing the amount of the VOCs. Our participation was essential to help the regulatory agencies draw up a realistic timeline that would take into account the needs of the roofing industry.

3. Monitor the decision makers.

It’s important to monitor the discussion surrounding any proposed changes in codes and standards. It’s equally as important to monitor who will be making the final decisions on these issues. Since there are various facets of the roofing industry, code-setting bodies would be wise to ask the local roofing experts for advice on whom to include in their decision-making process. I’ve seen instances where committees have incorporated someone who may technically be from the roofing industry, but that person’s breadth and depth of knowledge is not appropriate for the topic at hand.

I would say we have seen mismatch of decision makers when urban heat island and cool roof issues are being debated. An individual may know a fair amount about climate change, but that doesn’t mean the person necessarily understands the nuances of cool roofing. Additionally, they may not be aware of the breadth of research on that topic and instead rely on dated information from college or grad school without being appropriately briefed on new and emerging research.

4. Prepare for a variety of responses.

We have worked with some regulatory agencies during a collaborative process and they’ve been very grateful for our input. There have been other situations where it seems that the policymakers just want us to rubber stamp their very well-intentioned but ill-conceived draft codes. That’s not something that we are willing to give. These initiatives, these outreach campaigns, take a tremendous amount of time and effort and financial resources, and difficult as it may be, our members feel that they owe it to the industry and their customers to make sure that anything that we’re involved in is done the right way and rooted in science-based evidence. There are no shortcuts in these sometimes very difficult fights.

5. Everyone can contribute.

Every member of the roofing community can be active and engaged and make a contribution to ensuring that codes and standards reflect the true needs of the construction industry and our customers. It’s very valuable to build relationships with state legislators and attend town hall meetings. It is crucial to identify candidates that are pro-business and pro roofing, and support them financially as well as from an educational perspective by sharing information with them about the roofing industry.

This is also critically important: When you are asked to write a letter to a key decision maker, be sure to do it. Recently, as part of a campaign to preserve choice of building products for roofers, I visited a city councilmember’s office. On the wall was an enormous white board where every single constituent member’s concern was tracked, along with a reference to the response. This particular city council member had an 87 percent “close rate,” meaning that 87 percent of the concerns that they had received in a given period had been responded to. My experience has been that municipal and state legislators take constituent outreach very, very seriously. Every letter, every e-mail makes a difference.

6. Gather intelligence for your professional organization.

If there is one takeaway that I want people to get from this article, it is to keep us informed. It is darned near impossible to track everything that happens on a city, county, state and national basis because there is no software that currently tracks these issues before they are formally proposed and published for review. And that is often too late to educate the policy makers. It is critical for the readers of this article to attend their local trade association meetings and become acquainted with the policy makers and the legislators in their area. Equally as important, everyone can become a resource for legislators and policymakers when they have a question about roofing.

I’m looking forward to the next decade of victories for the roofing industry, allowing us to deliver superior roofing systems to a broad range of customers. But this will happen only if key decisions about the roof are made by roofing experts, and not mandated by politicians who are far removed from the design process.

USGBC and other Code-, Regulation- and Guideline-setting Bodies Are Increasingly Working with Industry

Earlier this year, the USGBC announced a 16-month extension to register products under LEED 2009, prior to the implementation of LEED v4 on Oct. 31, 2016. The action set off speculation, both off and online, about what caused USGBC to act with some calling for a more in-depth explanation for the delay. But the real reason, most likely, was simply stated in USGBC’s own press release: In a survey taken at GreenBuild in late October, 61 percent of respondents—almost two-thirds of those polled—said they are “not ready” or “unsure” if they were ready to pursue LEED v4 and required additional time to prepare. USGBC said it was also getting the same message from the international community.

The response to the USGBC action tended to fall into two camps: those who said the council was caving to the pressure of industry and those who said USGBC was taking a reasonable action after having put forward a complicated, unworkable and unneeded ratings system. Based on my extensive work with code-setting and regulatory bodies, I see a third option emerging, one that bodes well for the environment and the building sector.

During the past year, as part of my job as associate executive director of the EPDM Roofing Association (ERA), I have attended and testified at more than 20 hearings held by a broad range of groups, including the IGCC, SCAQMD (the South Coast Air Quality Management District, overseeing much of Southern California) and ASHRAE. Frequently, I have been accompanied by representatives of our member companies, Firestone, Carlisle and Johns Manville. And often I have been joined by members of industry groups, such as the American High-Performance Buildings Coalition.

Collectively, we have offered our findings on a range of issues that are critical to our industry, such as the importance of climate in the choice of roofing color and the need to preserve the builder’s choice when deciding on reflectivity options and the unique qualities of ballasted roofing that should be considered in any code-setting activities. Our testimony is based on meticulous research, as well as on empirical evidence and firsthand knowledge gained from years of experience in the building industry. Increasingly, we find that we are listened to and that our interaction with code-setting and regulatory bodies is a mutually beneficial exchange of ideas, rather than an adversarial give-and-take.

For instance, we worked closely with the Ozone Transport Commission in its efforts to achieve federally mandated clean air standards in the Northeast and Mid-Atlantic states. Initially, we pointed out that their proposed regulations would have mandated the use of low-VOC products that were in development but not yet available in the marketplace. And we also demonstrated that the roofing industry would need ample time to train roofing contractors in the use of these new products. We worked with regulators, state by state, and developed a mutually agreed upon seasonal approach. While the process is still ongoing, many state regulators expressed their gratitude for the advice we offered and the expertise we brought to the table.

I am certainly not privy to the inner workings of the USGBC. But their extension of the deadline for the implementation of LEED v4 seems to be part of a trend: The groups who are drawing up codes, regulations, and ratings systems are increasingly working with the building industry and the end results are based on good science and good sense.

The Cool-roof Bandwagon: Is It Headed To Your City?

Spring is here, and summer is on the horizon. But for millions of Americans, it will take more than a few days of sunshine to thaw the memories of the winter of 2013-14. The National Weather Service is still compiling the statistics to let us know just how bad the winter really was. In the meantime, most of us have a more immediate way to measure the impact of the polar vortex on our lives: One look at our heating bills and we know that this past winter deserves its reputation as one of the most brutal on record.

On the West Coast, as 2014 dawned, very different climate issues were front and center. The city of Los Angeles was being praised for its mandate requiring all new and renovated domestic housing to install “cool”, or reflective, roofing. The L.A. City Council passed the requirement as one of its last acts of 2013, and the new ordinance became part of California’s Title 24, which already required “cool” roofs in new and remodeled commercial construction.

THE NEWS media hailed Los Angeles as the “first major city to require cool roofs”, implying other urban areas will inevitably follow its lead. However, the winter of 2013-14 did a good job of reminding us that the climatic conditions of Southern California are dramatically different from the Midwest, Northeast and Mid-Atlantic regions of the U.S. This simple fact needs to be underscored as the bandwagon to require cool roofs travels somewhat erratically to major Eastern cities.

Last June, the mayor of Pittsburgh initiated a lukewarm cool roofs program by calling for volunteers to help paint the roofs of 10 city buildings white. Two-thirds of the Pittsburgh effort—$56,000—was funded by the Bloomberg Philanthropies, a project of former New York City Mayor Michael Bloomberg. The tagline of Bloomberg Philanthropies is “Good Intentions, Great Results.” I applaud the mayor’s good intentions in supporting projects that are designed to save energy. As for achieving “great results” by painting the roofs of 10 Pittsburgh buildings white? Don’t bet your next heating bill on it.

While Bloomberg was mayor of New York, the city launched the “NYC °Cool-Roofs” initiative, encouraging building owners to cool their rooftops by applying a reflective white coating as part of the city’s overall plan to reduce greenhouse- gas emissions 30 percent by 2030.

In Baltimore, the talk about cool roofs was fueled by a report issued last October by the Abell Foundation, a non-profit dedicated to enhancing quality of life in Baltimore and Maryland. The report, which is primarily an overview of previously published research, recommended increased use of cool roofs in Baltimore.

While these cities institute varied programs to support cool roofs, several major facts are ignored:

    ▪▪ Energy costs are closely related to climate. A solution that works in a warm and temperate climate to curb energy costs will not necessarily work in a colder climate.
    ▪▪ It’s vitally important to consider the source of information about cool roofing. Unbiased, up-to-date scientific studies can provide the data you need to make an independent judgment. Likewise, the manufacturers of roofing membranes have a vested interest in ensuring their products are used correctly and have in-depth knowledge of how roofing systems will perform in a wide variety of conditions.
    ▪▪ Choosing and installing a roof that will contain energy costs is a complex business. It requires understanding the interaction between building design, climate, insulation and all the other factors that impact the efficiency of a roofing system. A one-size-fits-all approach will only delay the discovery of workable, cost-effective, energy-efficient solutions.

IN FACT, a study conducted by Arizona State University published this past winter in the Proceedings of the National Academy of Sciences underscores the pitfalls of disregarding climate differences in roofing decisions. “What works over one geographical area may not be optimal for another,” says sustainability scientist Matei Georgescu, who led the research.

Although the headlines are touting Los Angeles’ cool roof requirements, I’d like to see headlines that read, “Energy Savings Achieved by Roofs Designed to meet Midwest and Northeast Climate Challenges”. Before anyone thinks about driving that cool-roofing bandwagon from Los Angeles to New York, you might want to equip it with snow tires.