Green Roofs Public Comment Summary - Denver · Green Roofs Review Task Force 1 Green Roofs Review...

Summary – Public Comment May 3rd – June 3rd, 2018 Green Roofs Review Task Force

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Green Roofs Review Task Force Public Comment

2-page Executive Summary

Survey Results Summary - When asked, ‘is the proposal an improvement?’ where 10 meant ‘yes’ and 1 meant ‘no’ the

average was 5 out of 85 responses. The 25 individuals who identified as ‘interested public’ had an average of 4, so they liked the proposal less than those who identified as being in the real estate sector.

- The majority of comments from ‘interested public’ respondents fell along the lines of “Listen to what the voters wanted, stop straying so far from the original ordinance.” Or “Why is this specifically designed for developers! The people of Denver voted yes to green roofs.” “New proposal looks like an easy way for builders and owners to not do much in the way of making their buildings more green.” There was also some push back against putting green space at grade.

- From the real estate sector many thought the proposal was an improvement. Many also said that the proposal would still cause delays in roof replacement.

- Most respondents said no this wouldn’t prevent density, though a few pointed out that by tying coverage to number of floors it could have that effect.

- In addition, several sub-groups requested exemptions such as historic buildings, existing buildings, multifamily buildings.

- Respect the voters choice and don’t change anything. The proposal will result in few actual green roofs.

- Repeal the ordinance entirely, it is a bad idea. - Provide incentives for meeting the requirements. - Kudos on your hard work. The proposal will work for all buildings. The proposal is an

immensely positive change and will allow people to do more to achieve the benefits by taking a more holistic approach that fits their buildings.

- Require green roofs and more green and trees on the ground to really solve urban heat island.

- Most people said the proposal would not prevent density. - About half wanted LEED precertification, half wanted just a submissions of LEED design

review with a plan for how any requested changes will be made. - Cool roof requirements will result in many commercial buildings having condensation

below the roof membrane and lead to roofing system failures and possible mold issues. Also, cool roofs do not last as long. Black (EPDM) roofs are more durable against hail and they may hold up better to the UV that comes with solar panels.

- Cash in lieu is a slippery slope that too many will pick. Simply paying a fee to avoid the ordinance doesn't seem like an appropriate path. What needs to change if this option is to remain in the proposal is that the $18/sf of required green roof space needs to be increased to $75-150/sf of required green space.

Public Briefing and Comment Sessions Summary

- The proposal is better and more realistic


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- The burden of the proposal may disproportionally burden 40-60,000 sq ft 5 story apartment buildings on small corner lots that are adding important density to our City; exempt 5 stories or less or lower the burden on these sorts of multifamily buildings

- Integrate zoning breakpoints into the proposal or use FAR to determine who can do more green space

- Allow for ‘option 9’ for new buildings – propose your own solution - Exempt unavailable roof space from the calculation - We need incentives to go with this so the burden doesn’t fall on those who can least afford

it – apartment dwellers broadly - Concern about the fee in lieu not really delivering the benefits, shouldn’t be able to buy out

of compliance Emails and Letters Summary

- Give incentives for more contiguous green spaces - Exempt certain buildings entirely – affordable housing, non-profits, existing buildings - Incentivize density. Possibly flip the new compliance percentages so large roofs have to

have more coverage - The proposal goes beyond the requirements on the ballot. - Add in blue roofs - Make sure the fee in lieu covers maintenance costs - Don’t require cool roofs, or if you do, make sure cool roofs don’t result in condensation - Supportive of alternatives that meet the intent or the original initiative. - Request that the NGBS Green certification be included in addition to LEED and Enterprise

Green Communities. - Historic buildings should be exempt. Character-defining feature is a specific term in the

preservation field and is well established by the National Park Service. No new definition is necessary.

- Allow for other solutions and new technologies that achieve the environmental impact. - Appreciate the flexibility and choices in the new proposal. Include a definition of available

roof space. Require coverage only over the available roof space if it is less than the required coverage area.

- Strengthen the Energy Program to include more buildings, a shorter timeline to comply, and more ambitious energy efficiency and renewable energy targets for buildings. Keep the Energy Program separate from roof replacement.

- Concerns about the cost for skinny 6 story buildings with a 60% coverage requirement. They carry a disproportionate burden under the new coverage requirements.

- Do not require cool roofs as they are not appropriate for every building.


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Green Roofs Review Task Force Public Briefing and Comment Sessions

May 11 and 14th, 2018 Summary

Attendees (with affiliation when indicated): Chris Alcorn, Alcorn Construction; John Zachum, Zachum Development Group; Mike Matheson, Neil Levine; Justin Berry, Prices; Bill James, Appraiser; Elisa Potowski; Ellen Thorpe, Meridian Consulting; Brandon Malero, community member; Christy Kelley, Marijuana Industry Group; Mark, voter; Susan- voter; Uptown on the hill; Adam, Downtown Denver Partnership; Sherie, landscape contractor; Nancy, Apartment Association; DJ, congress park resident; Taylor- highlands resident; Joe, CRL Associates; Mark, DHA; Josh, voter; John, Historic Denver

Task Force Members: John Bringenberg, Chris Parr, Austin Krcmarik, Scott Prisco, Brandon Riethheimer, Councilwoman Susman Council Staff: Luke Palmisano and Jack Paterson

I. Opening - No decision yet - Task force needs your help to make recommendation to City Council - Tell us what matters to you - Tell us what you would do to honor what the voters approved and do it better – more efficient, fairer,

less expensive, etc.

II. Presentation – Current Version of a Replacement for the Ordinance

III. Questions

Q: Self certification for Denver Housing Authority? A: Self certification should be fine Q: Why do 6 out of 8 options didn’t include green space? A: The ballot included possibilities that would not have any green space, despite the ballot title; the new

options allow for green and green/solar Q: You estimate that costs go down for new buildings in every category; which is the least-cost in your

analysis? A: Green on the ground was the lowest-cost option in many cases Q: Does LEED limit the green options proposed by the voters, and what does water quality in LEED mean? A: LEED takes a very holistic approach to sustainability, so there are options, including water quality

measures like green space Q: What happens in the Landmark Commission doesn’t like the changes necessary to meet this ordinance in

a landmarked building? A: We need your help defining character-defining features that would ensure aligning landmark status and

this ordinance Q: Is an apiary considered green roof space? A: Not in the proposal, but we will pass this idea along to the task force so they can think about that as a

beneficial element of a green roof Q: For on-site solar, does it have to be on the building; could it replace existing green space? A: It could be anywhere on site; whether it could replace existing green space depends on the zoning; it is

possible to keep pervious surface under solar panels Q: So, If I’m not replacing the roof, I still have to come up with energy efficiency? A: In this proposal, yes, if the building is over 50,000 sq ft Q: Are you exempt if you are already LEED Gold or higher?


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A: Yes Q: What’s the definition of community solar? A: Xcel has two programs – we would use those to define the off-site option Q: We are in planning a new building now, do we build to the current law? A: If you can’t wait for this process to reach its conclusion, you could comply with the current law as the

voters adopted it and that will in all likelihood satisfy the new ordinance once City Council concludes this effort

Q: Irrigation for roof tops, is that just adding to our water supply problem? A: Green roofs plants are low water; Denver Water thinks we’ll see more water-wise plants Q: Do water-wise plants still offer the same benefits? A: Yes, they help improve water quality Q: Why is improvement to air quality not listed among the benefits that the proposal will produce? A: Experts reviewed air quality information and found no measurable, citywide benefit to air quality from

the ordinance Q: Are there concerns with fire safety; can firefighters see visible signs of fire if a green roof is covering it?

[no fire department staff available to answer] Q: If green space is moved to the ground, does that take the place of already required open space; are you

double counting? A: The green space would have to be in addition to other requirements so that it is truly new green space Q: Why LEED Gold and not Silver? A: The analysis indicates that gold is the more on par with the level of benefits from the ordinance as voters

passed it IV. Public Input

I build apartment buildings – dense, urban mass-transit-oriented development; give more density and parking standard relief so the buildings can better mitigate costs

Look at the implications for 5-story, 40,000-50,000 sqft, 30+ unit buildings – consider making the exception 5 stories because that’s the limit for stick-built on a parking podium; these are the rental units that are serving an important part of the market; in addition, these buildings do not have available roof space – they have individual HVAC units on the roof and the mechanical can cover 65-70%

My typical building projects are 250,000 sqft; fee-in-lieu helps, the new proposal works better for us than the ordinance as it stands today

Integrate zoning breakpoints into the proposal so the building types in the zoning code are the same as this ordinance

Voters want to reduce heat island and want climate benefits Ballot didn’t weigh economic benefits and impacts; We need more time to review this proposal and to distribute it to constituents The proposal is a lot more realistic for budgets than what was on the ballot The task force needs to look carefully at the roof questions and consider the weight of insulation at time

of roof replacement – cool roofs are not a no-brainer and can have a shorter lifespan The ordinance should exempt non-profit or affordable housing Use the fee-in-lieu to help affordable housing Exempt 5 stories or less, 5-story residential is very common Coverage requirement should be smaller for smaller buildings Allow for an ‘option 9’ – let businesses to propose their own solution that has to be as good as the eight

in the proposal

Exempt for all unavailable roof space from the calculation Need to incentivize taller buildings It’s a green roof initiative; offering so many options will add loopholes We support the ordinance because it addresses important environmental problems and are concerned

that the proposed changes would negate the environmental benefits of the vote


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Existing buildings should at least be able to meet the financial contribution if no other option works Rate study to verify or replace the $17/ft fee should incorporate maintenance costs The costs are prohibitive for apartment builders and increase rents at a time when we cannot afford to

do that The options work well but there should be fast permitting for green roofs like other cities Offer incentives for the green roof options I don’t like the ability to put money into a fund, as a voter I am looking for the ordinance to contribute

to the green experience in downtown Denver Any flexibility and more options are great An incentive program would be beneficial – realize these benefits without putting the cost on the

working people who are renting apartments If there is a, then everyone should share the cost; Affordable housing is important to me; there are widespread, public benefits, but the costs are

concentrated; increased building costs means higher rent and longer lead-times for new construction; the task force should recommend spreading the cost to the greatest number of public citizens; you can make this fair through a general-fund subsidy to the individual properties that are bearing the cost

LEED is great for accruing points and has the least cost impact Affordable housing; we estimated that the current ordinance would increase rents between $65-82 per

month per person for new buildings and $45-55 per month for existing buildings; additional costs are passed on to renters; that includes insurance cost increases

If there are subsidies to residential developers, there has to be a way to guarantee that they aren’t keeping the subsidy and raising rents anyway

In some parts of the city, green on the ground is not viable because it would take rentable space Affordability – are we talking about those at 30% average median income (AMI) as well as people who

work full time but still can’t afford market rents? There are programs that assist people below 30% AMI, but we are looking to help people between 30-

50% AMI who can’t afford to buy houses I love the more options For some buildings, like retail, there are always being parking lots that are taking up green space, the

recommendation should look at building space and parking lot space The task force should entertain a financial hardship test, if you can demonstrate it you can be exempt or

can limit how much you are required to do If the cost exceeds the public benefit, there should be a limitation on cost I think the task force needs to think about incentives Concerned about the mandate on historic buildings; historic buildings are already sustainable; the costs

of this ordinance could be the difference between keeping an historic building or demolishing it V. Next Steps

- There are two more task force meetings – so keep input coming – attend if you can – May 25 and June 7

- Once the task force is done, the council process will also have a public process and opportunity to give input directly to council


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Green Roof – Public Input – Summary of Individual E-mails and Letters

1. I would strongly support language being added to the policy that allows for rainwater storage and reuse (Blue Roof) as an equivalent to Green Roof. In all ways the “blue roof” has an improved or equivalent impact as compared to the Green Roof:

It decreases the heat island effect – equivalent or better compared to green roof It conserves water – equivalent or better than green roof It utilizes rainwater as irrigation – same as green roof It reduces runoff – same as green roof It does not require supplemental irrigation on the roof as does a Green Roof, while at the same

time it reduces site irrigation needs. – better than a green roof

2. - The measures that you have proposed go beyond the requirements of the ballot initiative and penalize

density. - It builds-in absolutely no forgiveness or exemption for affordable housing. - The exemption for smaller residential buildings should speak to the type of construction, rather than the

building height in stories; Type V and Type III construction, wood construction, should be excluded for residential buildings; this would allow an effective 4 stories of wood construction over a parking garage deck, now considered a 5-story building, to fall under the exemption while allowing the 4-story residential construction to provide parking in the urban core.

- Consider the use of a SEDI score approach and NGBS Certified green, Energy Star, and the Living Building Challenge, not LEED and Enterprise

- The increased complexity in the proposed changes is not a welcome revision especially when the complications go above and beyond the limitations of the approved ballot initiative.

3. Given that social and ecological benefits of off-site green areas are magnified when in one contiguous area, I

think there is potential for incentivizing over-compliance and larger green roofs (or more solar coverage) for a more reliable way to achieve the contiguous spaces idea; consider using the funds from the $17/sqft non-compliance fee to subsidize over-compliance; if a building owner that was only required to use 20% of available roof space but wanted to cover 100%, they could apply to the Department of Public Health and Environment for some $/sqft amount for the extra 80% of the roof space.

4. - Consider exemptions for the non-profit sector – churches, foundations, schools, historic buildings, HOAs. - The IBC - 1504.8 Specifically says roof guidelines don’t allow for ballasted roofs over 15’ building height in our

wind zone . The roof trays in many instances will need to be ballasted, which will conflict with current/existing codes and law, similar to the storm water retention conflict, and carry a substantial cost.

5. The Green Roof Initiative must be adjusted to include exemptions for all existing buildings, designs on new

construction that structurally and financially cannot support the burden, and new buildings that provide affordable housing.

6. - Incentivize density - Allow to mix in the green section – provide some green roof and pay the penalty for the difference between

what is built and what is required


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- Allow owner to bank benefits from solar panel technology improvements - Certification – allows that if the project submits for LEED Gold but only reaches Silver that the penalty is

discounted - Allow a mix of on-site and off-site solar - If a part of a roof replacement has already met the requirements previously, then a future replacement, as

long as it doesn’t impact the way the ordinance was achieved should not be “…still required…” to do more - LEED is not the only grading system – green Globes, Energy Star, NGBS - LEED is not a smooth progression of attainability – there are sometimes severe jumps in thresholds – and

these adjust over time - Definitions

o Definition of stories – clarify – garden level, attics, etc. o Skylights and other natural daylighting areas on roofs o Required maintenance pathways. o Fire Department requirements (now or future) that reduce available roof area o Solar area = panel area or the entire solar “farm” including access pathways, structure, etc… - often 20%-

30% of the area used by solar installations o Set a minimum Solar panel efficacy/sf along with calculated reductions/rewards for using higher

efficiency solar panels o Energy efficiency defined - BTUs, Energy Costs

- Campuses o Need a way to designate signature architectural character defining element for a campus o Need a system to bank credits for open space required, energy efficiency, and current green space

inventory beyond that which is currently required

7. - Green Roofs walk paths, safety rails, parapet walls, access, constructing the roof, crane fees, inspection costs,

fines, etc. all add to the cost of construction and to insurance cost and raise the possibility of risk/liability from workers on the roof

- These translate into raising the cost of goods manufactured in those buildings - Funds from the fees have to go to this effort and should not be diverted - Is this a way to revive the cool-roof initiative that failed before?

8. - Denver Museum of Nature and Science – Strong supporter of environmental sustainability - Solar (2 PV arrays for a combined 200kW) - Implemented cool roofs covering 123,000 sqft (of 171,198 existing roof sqft) - Ground source heat pump technology utilizing recycled water as a heat source/sink - Support the goals, concerned about the challenges:

o 15 separate buildings of varying age (1908-2014) o No option for green-on-the-ground because the museum doesn’t control the ground in City Park o Over 18,000 square feet of pitched roof o Presence of mechanical on existing roofs o Need to protect the natural history collections and dioramas held in trust by the museum

9. - Financial Contribution to off-site greenspace – cover maintenance as well as acquisition - Off-site Renewable Energy – if Xcel can’t meet the demand, find others (arcadia.com) who will - Asphalt Parking Lots around buildings – should be included in the total square footage of the building


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10. - City of Denver code is not stringent enough for roofing to prevent condensation in white roofs that are

installed without sufficient insulation - Cool roofs installed in a way that causes condensation are not sustainable - Do not mandate the use of cool roofs in this climate - Require ventilation and insulation meet the codes for all reroofing, whether or not there’s insulation under

the deck - Require cool roofs to be designed for air and vapor transmission control by a qualified design professional - Require proposed cool roof assemblies to be reviewed by a design review committee

11. - Extend possible exemption from the ordinance to not-for-profit organizations – residential Common Interest

Communities are almost exclusively not-for-profit corporations

12. - Include in the ordinance of a mechanism to financially incentivize green roof construction

13. - The options for buildings to comply with the intent of the Initiative are appreciated and provide flexibility to

account for the varying architecture and constraints of existing and future Denver buildings - Need definition of Building – The Initiative and Proposal do not define building - Need definition of Available Roof Space / Rooftop Elements / Skylights - Fee-In-Lieu – Inclusion of the fee-in-lieu option allows for greater flexibility - Solar Measurement – is energy generation is a more relevant measure than a percentage of the roof area? - Unintended Consequences – We remain concerned that the calculation for the coverage requirement based

on building height may cause development to reduce

14. - The proposed Green Building Policy for existing buildings would adversely impact thousands of significant

buildings in Denver that are not designated landmarks. - Denver Landmark Preservation believes green roofs are appropriate for existing buildings with low-slope or

flat roofs that are not visible from public vantage points - Denver Landmark Preservation believes that cool roofs are appropriate for existing buildings with low-slope or

flat roofs. However, the installation of a cool-roof coating or cool-roof materials on an existing building with a pitched roof would adversely impact the historic integrity of the building

- Allow exceptions to the Green Building Policy when compliance would not be allowed per the Design Guidelines for Denver Landmark Structures and Districts and the Secretary of the Interior’s Standards for Treatment of Historic Properties.

- Allow existing buildings to count their existing green space toward compliance with the policy. - Allow exemptions for green roofs and on-site solar for existing buildings that have character-defining roofs or

roof features, in addition to cool roof exemptions. - Allow existing building owners to pay a significantly reduced financial contribution if the building is a locally-

designated landmark or in a locally-designated historic district, if it is listed on the National Register of Historic Places individually or as part of a historic district, or if it is listed on the Colorado Register of Historic Properties individually or as part of a historic district.


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- Reduce LEED Gold Certification requirements to simply LEED Certification for existing buildings, which is a more manageable option for existing building owners.

- Allow skylights to be exempt from roof square footage. - Add a seat for an historic preservationist nominated by the Denver Landmark Preservation Commission to the

Green Building Technical Advisory Group.

15. - Green roofs have been shown to be a cost effective tool to mitigate climate problems, but it is also one of the

more expensive ones; flexibility should be used as one incentive to go beyond any minimum requirements - In order to stay popular, the GRI needs to have more carrot, less stick – accomplishments to be incentivized

should include reversing contributions to climate change, enhancing human health and well-being, protecting and restoring water resources, protecting and restoring biodiversity and ecosystem services, promoting sustainable and regenerative resource cycles, building a green economy, and enhancing community, social equity, environmental justice, and quality of life

- Letting shorter buildings have a smaller green roof diminishes the desired benefits greatly for larger footprint buildings which have larger environmental impacts to be mitigated

- All new roofs should be cool roofs for at least 75% (LEED) of roof areas even without any GRI - More efforts need to be made to promote green infrastructure - Grade level green spaces are very different and should not be considered equivalent to roof level green

spaces - 19% energy efficiency from code is not very much - For 3% green roof area and 8% EE, I doubt many volunteers with the GRI would have been motivated; a very

low bar for baseline performance should not be the goal - The Existing Building Energy Program off ramps are so low that they will likely render the GRI to the point of

being meaningless before 10 years - Overall, the proposal does not look to be an improvement over the ballot

16. - It wouldn't it make more sense to have the 1 story industrial type buildings have a higher percentage of roof

space dedicated to a green roof, as they typically have more roof space; taller buildings will typically have less roof space; the chart seems like it should be flipped – 1 story 60%, 6 stories or higher 10% or more

- Specify energy cost vs. energy use savings - LEED v4 is very challenging. I would recommend Silver Gold is more challenging to obtain than Enterprise

Green Communities. Why are they being treated as equivalent? What about other rating systems? WELL, Envision, LBC, Park Smart, etc.

- Roofs cannot typically be 100% green and solar. Leave way for mechanical equipment and fire code solar access

- 40% and 30% for mechanical equipment is a high percentage. A 10,000 sf roof would be able to exclude 4,000 sf for mechanical equipment. That is a space 80' x 50'. I recommend lowering those to between 30%-25% and 25%-20%

- Recommend adding an energy efficiency option if, for example, the roof replacement is part of a larger renovation

- Recommend adding language, "Net Zero Energy" -ADM...or "Zero Net Energy (ZNE)" per California. - What about roofs with skylights? - Use an accepted definition from DOE (ZEB), California (ZNE), etc. - Define savings metric; cost vs. use - Sustainability consultant be required as well - Doing the number of floors requirements makes a whole lot more sense than how it was shown earlier by

square footage only though its more complicated in general -


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17. Jessica Chickering - The alternatives could include additional green space, energy efficiency, photovoltaics, and green

building certification, as long as the investment and benefit of the alternative meets the intent of the original initiative.

- The initial draft did not take into account many factors that would exclude buildings from participating or make new development prohibitive.

- If the goal is carbon offset then the proposed alternatives do well to meet this.

18. 9 Identical Letters from:

Steve Armstrong – Director of Multifamily & Commercial Services – Performance Point Beth Ainsworth – NGBS Green Verifier – Performance Point Paul Gay – Quality Assurance Manager – US EcoLogic Carson Zirges – NGBS Green Verifier Ken Snowden – Accredited Verifier, National Green Building Standard – Snowden builders, Inc Jeff Slaugh – Regional Manager – US-EcoLogic Michelle Foster | Vice President, Innovation Services – Home Innovation Research Labs Sandy R. Gallo – Director of Business Development – PEG, LLC. Dondi Atwell – Inspection Department Manager – ATS

- ICC/ASHRAE – 700 National Green Building Standard (NGBS) should be recognized as a named alternative to

LEED Gold or Enterprise Green Communities as one of the allowable green certification compliance options for new or existing buildings to comply with the Denver Green Roof requirements because it is affordable, rigorous, and specifically designed for residential occupancies.

- Any multifamily building, or the residential portions of mixed-use buildings, regardless of height and construction type can earn NGBS Green certification.

- Further, the next version of the NGBS, expected in 2019 and under development, will also allow entire mixed-use buildings (where the non-residential portion is 49% or less) to be certified as compliant.

- NGBS be named as an acceptable compliance path to LEED and Green Communities.

20. John Olson Deputy Director – Historic Denver

- Concern about its potential for unintended consequences to historic properties in our City - Historic properties are important for our City’s identity, our quality of life, and our cultural enrichment, and they

help our community achieve sustainability goals. - The re-use of historic buildings reduces the amount of demolition and construction waste deposited in landfills,

lessens the unnecessary demand for new energy and other natural resources needed to construct a new building, and conserves the energy originally expended to create the existing structures.

- Older and historic buildings that meet the criteria for green roof inclusion under this proposal, like those in the Lower Downtown Historic District, tend to be centrally located, dense, walkable, and are often mass-transit accessible - qualities promoted by Smart Growth advocates.

- Concerned about how “character defining features” may be defined; the term character-defining feature is a specific term in the preservation field and is well established by the National Park Service in their Preservation


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Brief #17: Architectural Character (https://www.nps.gov/tps/how-to- preserve/briefs/17-architectural-character.htm). We do not believe a new definition is necessary

21. Ron Goodman – Carlisle Construction Materials One of the reasons people choose black EPDM under solar is for its long term weatherability and superior UV resistance. It is one of the longest lasting roofing membranes as you want to minimize the need to reroof when solar panels are involved. Kristi Kelly – Executive Director – Marijuana Industry Group - Additional time for review – we would respectfully request any additional time that the Task Force is

comfortable providing in order to more fully and thoughtfully demonstrate our position for this proposal prior to their submission of a recommendation to Council.

- Ability to petition for other ways to achieve goals of green roof environmental offset because technology will evolve, and not every business will be able to conform to the options for compliance

- Clarification on insurance impact - Consideration of Impacts for Businesses on Flood Plain (FEMA impacts) - We anticipate receiving more feedback and submitting additional comments as our members start to work

through this process

22. EPDM Roofing Association and additional signatories - In hot and sunny climates like climate zones 1 and 2, the logic of cool roofs to save energy is generally

accepted. However, in northern climates like Denver, 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 like Denver, 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.

- For these reasons, we urge the Green Roofs Review Task Force to remove the cool roof mandate portion of the proposed modifications.

23. Michael Gifford – President – AGC of Colorado - We appreciate the flexibility and choices in both the New Buildings and Existing Buildings sections - The available roof space needs to be calculated as the total roof space less the area used for mechanical

equipment and yard, skylights, any AHJ egress and maintenance pathways, the border zone required by fire code, etc. In addition, if Denver Fire Department requires an additional fire suppression system on the roof to mitigate risks of dry landscaping, any dry-pipe sprinkler system added to the roof would take up additional roof space

http://www.nps.gov/tps/how-to-


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- The net result is a calculation of true available roof space for each project. That area can then be used for the calculation of green, solar or financial contribution requirements

- You could also change the language in the proposal to be the actual Available Roof Space of each project or the percentage, whichever is less

24. Lauren Poole – Executive Director – Energy Efficiency Business Coalition of Colorado The Energy Efficiency Business Coalition of Colorado express our strong support for the direction of the Denver Green Roofs Review Task Force and the Draft Green Building Proposal with these suggestions: - The draft policy increases flexibility and reduces the upfront costs of compliance, while at the same time

meeting or exceeding the benefits intended by voters – in particular the climate benefits

- This new draft policy is much more workable for builders and building owners, and much more valuable for Denver citizens

- Particularly, the Energy Program for existing buildings is commendable and well-designed and should most certainly be a part of the final adopted policy

- We recommend the Energy Program in the draft proposal be strengthened through one or more of the following ways: Include a broader range of buildings (25,000 sq ft+, instead of just 50,000 sq ft+) Include a minimum number of Energy and Atmosphere points for the LEED Gold option (possibly 10) Shorten the time to comply (from 10 years to every 5 years) Require larger reductions in EUI (20% instead of 15%) Move retrocommissioning to be a way to meet the 15% EUI reduction, rather than an option of its own Specify that the program be renewed and continued beyond 10 years (we don’t believe Denver voters

intended only 10 years of environmental benefits) - The Task Force was wise to separate the energy program from roof replacement so that energy efficiency

upgrades are not further delayed or avoided while buildings save up capital for roof upgrades (an unintended consequence of the original ordinance

- We are also glad to see that energy efficiency above code is a pathway for new buildings - According to the U.S. DOE, energy efficiency provides nearly 30,000 jobs in Colorado (nearly 35,000 if you

include smart grid technologies) and 42,000 based on research results from a 2017 Environmental Entrepreneurs report. These jobs and these energy efficiency upgrades contribute to Denver’s currently thriving economy and help maintain Denver’s clean energy leadership

25. Colin Voorhees – Acquisitions Analyst – RedT Homes - The 1% increase, quoted on the bottom of page 3, is misleading. It should be noted that this is not a

comparison to the original ballot measure but is actually a cost increase in terms of the project as a whole, between no green roof and a green roof; looking at the simple excel document I supplied, the increases between the measures, for our project, can be up to 66%

- “Cost Analysis,” is also misleading; on page two, it shows additional cost being less for the new proposal, even though the new square feet requirement is quite larger; going from 30% roof coverage to 50% roof coverage, one would most likely not see a cost decrease

- One solution is to increase the footprint requirements not by 10% per floor, but, by something more modest such as 3-5% per floor, and maybe extending up to 10 floors, where it still maxes out at 60%. Or, utilizing gross floor area as a metric, which was the original plan.


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Green Roof – Public Survey – Summary of Individual Survey responses

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