Loading...
HomeMy WebLinkAboutConstituent Letter - Read Before Packet - 1/2/2019 - Letter From Chadwick L. Collins, Asphalt Roofing Manufacturers Association (Arma) Re: City Of Fort Collins Proposed Ordinance Number 151 - Asphalt ShinglesTo: City Council of Fort Collins, Colorado From: Chadwick L. Collins, Technical Director, Asphalt Roofing Manufacturers Association (ARMA) Date: December 27, 2018 Re: City of Fort Collins Proposed Ordinance Number 151 – Asphalt Shingles The Asphalt Roofing Manufacturers Association (ARMA) represents the North American asphalt roofing manufacturing industry. ARMA members include all major North American makers of asphalt roofing products, both commercial and residential, including those that utilize manufacturing techniques that allow our members’ asphalt shingles to meet impact resistance standards such as those set forth in UL 2218. ARMA members account for approximately 85 percent of North American asphalt roofing production. ARMA appreciates the opportunity to provide the following comments to the City Council of Fort Collins concerning proposed Ordinance No. 151, which would require that all asphalt shingles, but not roofing made of other materials, installed on a residential roof meet the class 4 impact resistance requirements set forth in UL 2218: 1. The model building code which Ft. Collins is proposing to amend contains the following in its preface: This code is founded on principles intended to establish provisions consistent with the scope of a building code that adequately protects public health, safety and welfare; provisions that do not unnecessarily increase construction costs; provisions that do not restrict the use of new materials, products or methods of construction; and provisions that do not give preferential treatment to particular types or classes of materials, products or methods of construction (emphasis added). 2. The proposed amendment language would impose performance requirements upon asphalt shingles and no other roof covering materials (metal, tile, wood shake, slate, etc.). ARMA believes that, contrary to the fundamental tenets of building code set forth above, this ordinance would give preferential treatment to other roof covering products and put asphalt shingles at a competitive disadvantage in the marketplace. UL 2218 is designed to apply, and does apply, to steep slope (residential) roofing manufactured out of any material, not just asphalt. Impact resistance testing can be performed, and is performed, on standing seam and other metal roofing, as well as on tile, wood and slate roofing; products made out of those materials are tested to UL 2218 and are sold as impact resistant. ARMA can see no justifiable reason to discriminate against its members’ products by requiring that only shingles made out of asphalt meet impact resistance requirements. 529 14th Street, N.W., Suite 750 • Washington, DC 20045 • PHONE: 202.591.2450 FAX: 202.591.2445 • www.asphaltroofing.org 2 3. The cost impact evaluation used to justify the proposed amendment language only compared the cost of currently approved asphalt shingles to that of asphalt shingles that would meet the proposed enhanced performance requirements. No cost evaluation was made comparing impact resistant asphalt shingles to other roof covering materials. 4. There are multiple accepted impact testing methods available to manufacturers of roof coverings. While many producers utilize the UL 2218 test that is specified in the current draft of your proposed code amendment, some concrete tile manufacturers choose to use ANSI/FM 4473 for evaluating impact resistance. We therefore recommend that, should the City choose to move forward with the amendment at this time, the amendment language be edited to require that roof coverings be tested to class 4 impact resistance according to either UL 2218 or ANSI/FM 4473. ARMA suggests for your consideration the following code language: R903.5 Impact Resistance. Roof covering assemblies installed on slopes equal to or greater than 2 on 12 shall bear a label indicating compliance with FM 4473, Class 4, or UL 2218, Class 4. Additionally, the referenced standards listed in Chapter 44 should be updated to include the above standards. 5. In response to the City staff’s concerns about whether other than asphalt shingle roof coverings meeting Class 4 impact resistance are available, our research shows that they clearly are available. The Texas Department of Insurance maintains a product list of all class 4 impact resistance products at http://www.helpinsure.com/home/roofingx.html. Products of every type and description are identified as meeting class 4 impact resistance requirements. Concrete tile products tested to ANSI/FM 4473 are listed, together with a multitude of products tested to UL 2218, on American Family Insurance Company’s summary of products (https://web.amfam.com/pdf/insurance/roof.pdf). CONCLUSION ARMA requests that the Council postpone the second reading of and a vote on the proposed ordinance to allow the Council and the City’s building officials time to receive and review additional data and make a more fully informed decision on any local amendment to the model building codes. Alternatively, if the Council believes that it possesses sufficient information to move forward now, ARMA respectfully requests that the amendment be revised to apply to all steep-slope residential roof coverings, and not just to asphalt shingles. 1 Sarah Kane From: Ray Martinez Sent: Wednesday, January 2, 2019 4:15 PM To: Carrie Daggett; Darin Atteberry; Sarah Kane Subject: Fwd: Ft. Collins Proposed Ord. No. 151-Asphalt Shingles - ARMA Memo Attachments: image001.jpg; ATT00001.htm; Fort Collins CO Ordinance No 151 - 12-27-18 ARMA Comment.pdf; ATT00002.htm Ray MARTINEZ, Councilman Dist-2 970.690.3686 Sent from my iPhone Begin forwarded message: From: "Collins, Chadwick" <CCollins@kellencompany.com> Date: January 2, 2019 at 4:09:34 PM MST To: "raymartinez@fcgov.com" <raymartinez@fcgov.com> Cc: "Fischer, Mike" <MFischer@kellencompany.com>, Reed Hitchcock <rhitchcock@asphaltroofing.org> Subject: FW: Ft. Collins Proposed Ord. No. 151-Asphalt Shingles - ARMA Memo Mr. Martinez, Thank you for taking my phone call this afternoon. Please see attached as requested for the memo I referenced in our call. I look forward to speaking with you tonight at the council meeting.