ERA’s Response to the EPA Sunsetting Proposal

The EPDM Roofing Association (ERA) is proud to represent the country’s largest manufacturers of both white and black commercial roofing membranes. We feel their knowledge and experience of our members positions us well to provide government officials, architects, and design professionals with solid and credible information that allows them to make educated decisions. No one product is ideally suited for every building or climate, which is why our members manufacture a wide variety of products to provide optimal solutions for each building’s unique needs.

It is precisely because of our members experience with the roofing industry that ERA submitted comments in favor of the EPA’s proposed repeal of the ENERGY STAR Specification for Roof Products Program, announced June 5th. The ENERGY STAR label and specification played a critical role at the time of its launch in 1999, jumpstarting demand for cool roofs. It also brought the necessary attention to the long underappreciated role that roofs can have on overall building performance. Twenty years later, however, it is clear that the Program has been surpassed, in many instances, by commercial and residential building codes, high performance certification standards like LEED, and evolving building performance experience that allows building science to inform designers and architects on best product utilization for a particular climate and building.

Specifically, as the EPA points out in its request for comments on its proposal, “Efficient commercial roofing, initially driven by ENERGY STAR, is now driven by codes and voluntary building standards, as well as standard design practices nationally. Commercial buildings codes in all but five US states include requirements for roofs. Further, highly reflective commercial roofs are now part of the mind-set for designers, contractors and building owners in climate zones across the majority of the south. Many states and municipalities have adopted IECC 2010, 2012, or 2015 or ASHRAE 90.1-2007, 90.1-2010, or 90.1-2013 as their building codes, meaning their standards for roof products on commercial buildings are stricter than the ENERGY STAR Roof Products Version 3 specification in climate zones where reflective roofs are beneficial (Zones 1-3).”

ERA’s support of this EPA action can be best understood in the following contexts. In hot and sunny climates, the logic of cool roofs to save energy is generally accepted, although the effect diminishes with greater insulation levels and so do some benefits. However, in northern climates, the heating penalty virtually always outweighs or offsets the cooling benefit and

moisture control or condensation risks are greater than experienced in conventional black roof membranes. This reality necessitates a “very selective use” approach for cool roofs. Such an approach strives to identify the limited cases where specific end use conditions may provide a benefit while also considering appropriate measures like the addition of air/vapor barriers to mitigate increased moisture accumulation risks. For cool roofs in northern climates, one has to understand the heating penalty, moisture accumulation potential as well as the other performance trade-offs associated with their selection and use.

Good roofing practice must be the dominant criterion in any roof design. The licensed design professional, an Architect/Engineer, has long-term experience and access to science to effectively weigh the broad variety of issues that inform the choice of a roofing membrane. These include not only the color of the membrane, but also issues such as the durability of the membrane, the method of attaching the membrane, the choice of insulation, and the use of air or vapor barriers. Ultimately, the licensed designer should be relied upon to make the correct roof system design choices, including that of roofing membrane for any individual building project.

Additionally, sunsetting the ENERGY STAR Specification for Roof Products Program will most likely help to strengthen the physical performance of buildings in the face of future threats. This past year is on record, as reported by FEMA, for being the most expensive year for extreme weather and natural disaster events that affected roughly 25.8 million people and exceeded $2 billion in disaster assistance. While there is debate about the cause of this increase in extreme weather, there is overwhelming agreement that it will continue. Given the compelling need to create a resilient built environment, it is clear that design decisions must be made by local individuals responding to the best climate and weather information that informs their specific challenges. A government program urging the use of one particular color in all applications could run contrary to the protection of life and property in the face of these emerging threats.

Based on the unmatched experience of our members in the development and use of roofing products, combined with our awareness of the need for resilient design tailored to the specific threats encountered in varying geographic areas of the U.S., ERA has strongly endorsed the proposed phaseout of the Energy Star Roofing Products Program.