Green Roof and Wall Policy Guide 2023
Green Roof and Wall Policy Guide 2023
Green Roof and Wall Policy Guide 2023
ACKNOWLEDGEMENTS
Authors
The report was co-authored by:
Richard Hayden, GRP, Retired (Advisor), American Hydrotech, Inc.
Jeff Joslin, Director Emeritus, Current Planning, San Francisco
Planning Department
Peter Lowitt, FAICP, Retired, Devens Enterprise Commission
Rushil Malik, Marketing Manager, Green Roofs for Healthy Cities
Steven W. Peck, GRP, Honorary ASLA, Founder and President,
GRHC
Maya Stern, Program Co-ordinator, Green Roofs for Healthy Cities
(GRHC)
On the Cover:
2023 Jeffrey L. Bruce Awards of Excellence Winning Project Photos
Top Row (left to right): 4131 South State - Omni Ecosystems, 5665 Woodlawn - Omni Ecosystems.
Second Row: Drexel University - Parker Interior Plantscape. Third Row (left to right): Javits Center
Farm - Brooklyn Grange, 4131 South State - Omni Ecosystems, Javits Center Farm - Brooklyn Grange.
Bottom Row: University of Hartford - Recover Green Roofs. Submit your project, policy or research
leader for a future award here.
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Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Green Roofs for Healthy Cities – Policy and Professional Development Support . . . . . . . . . . . . . . . . . . . . . . 15
Construction Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
Lessons Learned . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .34
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Introduction
In an era of climate change, marked by extreme heat, drought, flooding, fire and worsening air quality, policy
makers the world over are looking to the roofs, and more recently the walls, of the buildings in their cities
for relief. Over the past 20 years, local governments from across North America have been introducing
green roof policies in order to generate a market for these technologies and achieve multiple policy
objectives.
Green roofs go by many names, including eco-roofs, living roofs, vegetative roofs, and roof gardens to name
a few. Green roof policy is often a key component of a larger government policy effort to implement various
forms of green infrastructure, also known as ‘natural infrastructure’, in cities to address multiple challenges
simultaneously. Green infrastructure measures include bioswales, urban forests and wetlands. This report
focuses primarily on green roofs and green walls, which remain significantly underutilized by policy makers
across North America.
A decade ago, the City of Toronto was the first major city in North America to adopt a mandatory green
roof requirement for new buildings. As a result, it now boasts more than 1000 green roofs and over 10
million square feet of additional green space. Policy makers in Portland, Oregon and Chicago, Illinois were
also two of the early adopters of green roofs. They provided financial incentives, regulations and
procurement policies for green roofs. Each of these cities has seen millions of square feet of growth in the
green roof market, with the resulting increase in employment and many other benefits. Portland, Oregon
and Cambridge, Massachusetts have recently made green roofs mandatory on new buildings.
Green roofs are neither new nor exotic. In fact, they’ve been deployed elsewhere in the world for decades
on modern structures, and in some cases they’ve been common practice for generations. The concept is
simple and derived from “natural infrastructure”, such as wetlands, forests and prairies. They mimic such
environments in terms of aesthetics and habitat. They are functionally comparable in terms of providing
ecosystem services: filtering air and water, employing rainfall to support plant life, and absorbing and
detaining such rainwater that would otherwise need to be managed through engineered drainage, septic,
and/or treatment systems. They have the capacity to displace vast areas of negatively impacting roofs with
“green infrastructure”, with the cumulative potential to avoid costly expansions of municipal water
treatment systems and address challenges like the worsening urban heat island.
A decade ago, targeted green wall policies lagged behind the implementation of green roof policies, in part
because of the relative newness of the green wall industry in North America, and because there was less
performance data and a less-evolved universe of providers for these technologies. Since that earlier era, a
growing number of cities have developed more comprehensive green infrastructure policies that capture
the many benefits of green walls as well as green roofs, urban forests, bioswales and other forms of
engineered green infrastructure.
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Green roof policies vary considerably: some have come to include regulations which require compliance,
and others offer voluntary incentive programs. Certain municipalities have adopted regulations and
incentives for installing green roofs, with different agencies operating programs with complementary goals
to foster deployment of these technologies.
The specific construction requirements of mandated and incentivized green roofs also vary, from simple
roof coverage and media depth requirements, to more complex construction standards which include items
such as leak detection and minimum maintenance standards. Over the past five years, Green Roofs for
Healthy Cities and the Green Infrastructure Foundation have worked to develop a comprehensive
performance rating system for green roofs and walls called the Living Architecture Performance Tool
(LAPT). The LAPT is intended as a readily implementable standard for municipalities to assert a consistent
set of design, construction, maintenance, and performance requirements. A number of different projects,
from simple sedum roofs to more complex intensive roof gardens have been certified under the LAPT.
In some jurisdictions, where such policies and regulations have been considered, initial costs for a green roof
have – unsurprisingly – proven to be a political challenge as development constituencies have reacted to
first costs rather than considering life cycle costs. However, in a variety of markets, geographies, and
bioclimates, the life cycle value and financial return of green roofs has been demonstrated to be
consistently robust, resulting directly in the increasing number of cities establishing mandatory
requirements typically focused on new buildings.
Plants growing naturally along the sidewalk, some leaning in. Photo: Phipps Conservatory and Botanical Gardens
Regulations catalyze maturing markets. Requiring developers to implement green roofs provides a certain
green roof economy that allows the most rapid and successful emergence of local product and service
providers. Such deployment also consistently results in an early and dramatic reduction in installation costs,
thus furthering the cost-efficacy of these systems.
Cities that have recently established green roofs to address green building goals and/or stormwater
management objectives include: New York, Seattle, Toronto, San Francisco, Cambridge, Gatineau, and
Washington DC. This layered approach tends to produce greater results such as in Devens, Massachusetts.
Stormwater regulations, viewshed overlay requirements and greenhouse gas mitigation work in concert to
support green roof implementation.
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These cities each have a combination of green roof regulations for new buildings and incentives for existing
buildings to substantially, directly, and effectively manifest new development that cost-efficiently
contributes positively and remedially to the built environment.
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Climate Mitigation
Green roofs are able to provide additional thermal
insulation benefits for many roofs, thereby reducing
energy consumption associated with space heating and
cooling. Portland State University and Environment
Canada established an Energy Calculator which provides
base levels of energy savings in multiple climates across
North America. Many of the energy savings benefits to
buildings depend on their age, with older buildings often
lacking sufficient insulation the benefits are greater.
Photo: Brodie Kerst. The Old Chicago Post Office in downtown
Chicago
Reduce Urban Heat Island
Impervious surfaces and a lack of vegetation, often widespread in poorer neighborhoods, contributes to the
urban heat island, which is the term used to describe the higher temperatures experienced in urban areas
relatively to the surrounding countryside. The implementation of a significant amount of green roofs in a
given area, has the potential to lower the urban heat island effect, which contributes to improved air quality
and the reduction of energy consumption associated with air conditioning. While traditional roofs will heat
up the surrounding environment, green roofs act as outside air conditioning and cool their surroundings
through evapotranspiration. See here for detailed papers on energy, climate and green roofs.
Membrane Durability
Green roofs protect waterproofing membranes from the wear and tear associated with solar radiation
exposure, temperature fluctuations, and mechanical damage, thereby extending the life expectancy of most
membranes by two times or more. This results in significant savings associated with future membrane
replacement costs as well as reducing the need for removal, disposing and recycling of worn out
membranes.
“Similar to current UL 2218-rated hail resistant roof materials, with the Class 4 rating, it is my
hope that green roofs will be approved as a roof choice qualifying for the same insurance
premium discounts. Roofs that use UL2218-rated materials enjoy up to 35 percent savings on
their insurance premiums.”¹
¹Leila Tolderlund, Living Architecture Monitor Winter 2019 19-20. “Green Roofs Stop Costly Hail Damage to Roof Membranes
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Public Art/Aesthetics
The Devens Enterprise Commission in north central Massachusetts adopted a viewshed protection
ordinance to protect the view from the nearby Museum of the New England Landscape. Views from the
museum must be mitigated with green walls, roofs and the use of low reflectance materials. Green walls
have also been recognized as meeting regulatory requirements for the installation of public art in Oakland,
California. greenroofs.org
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Stormwater Management
Green roofs have the ability to retain stormwater through the plants, growing medium and additional layers
that capture and hold, or slow the progress of water off a roof. Many jurisdictions recognize green roof
assemblies for their stormwater retention benefits through stormwater regulations. In recent years,
manufacturers have begun introducing green roof systems that enhance the stormwater retention capacity
of green roofs, often through the use of cups in the drainage layer, fabrics or fleeces that expand to hold
more water. They are also incorporating systems that allow for the detention of stormwater (typically up to
6 inches in depth) for a period of time, often two to three days, before controlled release. The detention
capacity gives civil engineers a greater degree of certainty over stormwater management than retention
alone. Managing stormwater on roofs, can save developers costs associated with below grade or under-
building stormwater detention structures and the space and mechanisms they require.
Moderne, Saratoga Springs, NY. Photo: Bonacio Construction Stormwater retention testing. Photo: Green Roof Diagnostics
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Green roofs and walls provide social, economic and environmental benefits. Within a given city, thousands
of green roof projects covering tens of millions of square feet of land area have the ability to reduce the
growing threat of the urban heat island effect, and reduce flooding and water quality challenges and costs
by retaining and detaining stormwater. The addition of plants improves air quality, resulting in better human
health and well being. Some jurisdictions also utilize roof space to provide habitat for pollinators, and rare
and endangered species of flora and fauna.
As green roof benefits accrue at various scales, such policies constitute a natural public-private partnership.
The real value over time is quantifiable and scalable, and analysis in advance of policy initiatives
demonstrating these benefits is one of the single most valuable tools to promoting such policies, whether
addressing elected officials, the public, housing advocates, developers, designers, or owners.
At the building scale, green roofs provide private/building owner benefits, which are determined by the
type of building. For almost all buildings, green roofs increase the life expectancy of waterproofing
membranes and reduce energy costs - benefits that accrue to the building occupants and owners over the
long term. For some buildings, added real estate value benefits building owners, as well as affording the
opportunity to generate additional revenue through the rental of roof space, and higher prices for amenity
decks (whether for sale or rental). For other buildings, such as large warehouses that are not climate-
controlled, the benefits of green roofs may be substantially less for the owner.
At the public/community scale, the benefits also include: job creation, substantial energy savings, significant
tax base increases resulting from added real estate value, and health benefits resulting from enhanced
views, biophilic value and biodiversification. For some of these attributes, the monetary value is quantifiable.
For others, the supportive data is more intuitive or observational.
Whether public or private, clearly monetizable benefits result. Regardless of the form of ownership
independent life-cycle cost-benefit-analyses conducted by ARUP for the General Services Administration
(GSA) have demonstrated that extensive, lightweight green roofs typically offer as little as a five- or six-year
simple payback.³ For privately owned projects, this value accrues directly to owners. For rental projects,
ultimate savings can benefit the owner and renter. When applied to public buildings, the value returns to the
public directly. For projects serving economically challenged communities, the resulting benefits contribute
directly to meaningfully advancing social equity goals. The value-added and direct savings resulting from
green roofs are genuinely equal opportunity.
³ Federal High-Performance Green Buildings: Green Roofs. U.S. General Services Administration. (2021, June 4).
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Voluntary implementation of green roofs continues to advance as developers and institutions embrace the
value and benefits of such facilities. However, only through the implementation of green roof policies and
regulations can sufficient momentum occur that results in the creation or expansion of providers,
substantial municipal benefits, a scale sufficient to achieve expeditious first-cost reductions, and a more
rapid and broad-scale response to emerging climatic and economic challenges.
Increased exposure to green roofs through municipal demonstration projects can also serve to dismantle
public misconceptions about the technology. Education targeting building owners, architects, landscape
architects, engineers and policy makers will likely have the greatest impact on bringing green roof
technology into the mainstream.
For many building owners and developers, the common private benefits may not be perceived as
sufficiently quantified or immediate enough to justify the additional upfront capital investment. This is
where financial and regulatory incentives become important. Examples include the City of Toronto’s Eco-
Roof Incentive Program which offers CDN$100 per square meter of green roof and Washington DC’s
US$15 per square foot incentive in targeted watersheds where combined sewer overflows are frequent.
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Some of the policies described in this report are helping to develop the market and turn these public
benefits into private benefits through credit systems and development bonuses. There are also policies that
help promote education and awareness about green roofs and their benefits through increased access and
exposure to green roofs and resources.
The green roof job market for design, installation and maintenance is primarily a local one, and the past 20
years has clearly demonstrated that the industry has grown largely due to the increased demand stimulated
by education, financial incentives and green roof requirements.
Few, if any, public policies can accomplish so much with so little, as green roof requirements. They leverage
private investment for multiple public benefits, generate private benefits, do so on otherwise squandered
space, and are relatively easy and low cost to administer.
These concerns have been consistently and entirely disproven. Green roof maintenance requirements are
modest and anticipatable, and the stability of such systems and their contribution to roof longevity and
durability is well documented. Professional training and the Green Roof Professional (GRP) accreditation
program have promoted best practices to ensure that high-quality and well-performing systems
predominate. Green Roof Installation and Maintenance Professional (GRIMP) certification provides hands-
on training and best practice information to industry professionals.
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To further support policy development efforts, GRHC has established a number of initiatives and resources:
The Green Roof Professional (GRP) training and accreditation program can provide you with
professionals to help understand best practices in the design, installation and maintenance of green roof
systems.
GRHC’s Technical Committee and Policy Committee are available as ongoing resources to provide
expertise as helpful.
GRHC has been directly involved in policy development in Toronto, San Francisco, Denver, New York
City, the State of Washington, Cambridge, Vancouver and Washington, DC, providing feedback,
analysis, and educational support.
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GIF generates research reports to promote informed decision making, such as the cost-benefit analysis used
to advocate for the Denver Green Roof Ordinance. The study found that:
An extensive green roof would provide energy and stormwater savings, increased employee
productivity and improved real estate values, all of which would more than offset the installation and
maintenance cost of the green roof. Additionally, there would be significant community benefits.
By 2033, an estimated 57.5 million square feet of green roofs would be built, generating approximately
25,000 job-years, reducing the urban heat island and helping to manage stormwater. The Net Present
Value of these green roofs would be $50 million.
By 2058 the green roofs would have a Net Present Value of $1.85 billion, because there would only be
maintenance costs and the benefits would continue to accrue.
Over the past seven years, GIF has developed and implemented the Living Architecture Performance Tool
(LAPT), an independent review system to help policy makers establish incentive and regulatory programs.
The LAPT creates a minimum standard for green roof and wall performance and allows for four different
levels of certification - certified, silver, gold and platinum. Projects can earn up to 110 points and can be a
green roof or a combination of green roof and wall. The LAPT third party certification could be used by
policy makers by referencing it to incentive programs. There are important prerequisites required for LAPT
certification associated with design practice, adherence to local regulations and minimum five year
maintenance standards. The LAPT is designed to help policy makers adopt performance standards that
make sense in their particular climate, and so that these projects generate the desired performance
outcomes.
The Living Architecture Academy provides online training courses, including GRP training, GRIMP training,
the Green Infrastructure Introductory Course and a more detailed Green Infrastructure Economic Valuation
course. To sign up for online training and learn more visit our LAA website.
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As one example: Denver’s citizen-led green roof initiative was a particularly challenging scenario. An
aggressive initiative was put to a public vote without the benefit of City support. Most felt that an initiative
would not make it onto the ballot, let alone build necessary public support. Those likely to be immediately
impacted by such a requirement - developers, builders, and the roofing industry - quickly organized once the
initiative qualified to be on the ballot and public interest and support was evident.
The opposition was swift, assertive, well-resourced, and orchestrated a campaign based on false narratives,
rather than facts. Efforts to countermand the initiative included blitzing all media outlets, lobbying elected
officials, and widely distributing literature filled with unfounded claims.
The claims were all answerable, and the initiative passed with a substantial margin. But the fundamental
lesson remains: the best offense is a strong-and-ready (and fact-based) defense.
Green Roofs are Too Expensive for Affordable Housing Projects and Public Buildings
Cities around the world are currently facing an affordable housing challenge. In the absence of analysis and
advocacy, policy makers and others will raise the issue of “unnecessary” first costs, claiming such costs
would put affordability further out of reach. In fact, more vulnerable projects will benefit most meaningfully:
full cost recovery within six years on average and the economic benefits then accruing to those projects and
occupants through energy savings and deferred maintenance for remaining decades to come. Affordable
projects will be all the more challenged in the future. Green roofs guarantee a more stable and accessible
future for such projects and their residents, thus directly addressing environmental equity imperatives.
The same is true for public buildings, where the long-term savings resulting from green roofs benefits the
public for the life of the building, which helps armour against the uncertainty of future tax-based economies
and public-building maintenance budgets.
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Structural Challenges
When included at the beginning of the design and engineering phase, the weight of a green roof can be
easily and affordably accommodated by the structural engineers for the project. Existing structures may
have some limitations, but green roofs may be installed with special considerations for lightweight
assemblies on buildings originally designed with stout structures (such as buildings designed to
accommodate rooftop parking) or can otherwise be addressed through additional structural reinforcement.
There are a number of ASTM standards that govern how green roofs and their growing media and
components are evaluated including ASTM E2399 which is used to measure saturated weight of the
growing media.
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The Urban Rooftop Farm on the Toronto Metropolitan University (TMU). Photo: TMU Urban Farm
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Green roofs can have many different design objectives, as described below.
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Blue/Green Roofs
These green roof types retain and detain
stormwater within an enhanced green roof
section by augmenting the growing media with
synthetic materials that act like sponges in the
green roof. Unlike Blue Roofs, stormwater in a
Blue/Green Roof is held in the pore spaces in
the growing media and synthetic elements and
released via transpiration and evaporation from
the plants within the Blue/Green green roof Van Dusen Botanical Garden Visitor Centre 2017 by Connect
assembly. Landscape Architecture Inc. with Architek. Photo: Brett Ryan Studios.
Urban Agriculture
Roofs
Growing food on rooftops is
an increasingly widespread
application where urban
farmers grow food crops on
specially designed green
roofs. A wide variety of
crops, from vegetables to
vineyards, can be cultivated The Javits Center, New York City. The waterproofing is done by American Hydrotech, and the
on rooftops. urban agriculture assembly is managed by Brooklyn Grange. Photo: Brooklyn Grange.
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The Shoppes at Kingsbury Square, 2014 A living wall in Drexel University, Pennsylvania. Photo: Parker
Interior Plantscape.
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The following provides some simple definitions of the types of policies and programs from across North
America that can be used to increase the installation of green infrastructure – focused mainly on green
roofs and walls. Some require direct expenditures, while others only administrative costs. There are
significantly more green roof policies at present than green wall policies.
Density/Floor Area Ratio Bonus
By including green infrastructure in building design, developers are permitted to increase the density of
their building through the allowance of additional floor area than otherwise allowed. Additional height may
also be a bonus attribute if that’s otherwise a code limiter.
Funding (Grant)
Up-front funding to cover the installation costs of specific types of green roofs or green roofs that retain a
certain amount of water. Such funding support typically ranges from $7.50 to $15 per square foot and may
be capped at a certain amount per project. Below these amounts program uptake is typically minimal. Some
jurisdictions provide grants to offset the cost of initial structural loading assessments for existing buildings,
thereby removing a barrier to program uptake.
Funding (Rebate)
Projects may be reimbursed for the cost (up to a certain amount) of installing green roofs.
Funding (Subsidy)
Property owners make co-payments for part of the cost of the installation of the green roof.
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Tax Credit/Abatement
Deductions from taxes (credit) or a reduction of taxes (abatement) for the construction of a green roof. The
amount is calculated as a percentage of the cost of construction, or as a dollar amount per square foot of
green roof constructed up to a certain limit.
Procurement
New and or existing government facilities, or the facilities of government funded agencies, boards and
commissions are required to install green roofs during new construction and/or when re-roofing occurs, if
structural support is sufficient.
Other
Additional, less common policies and programs to
inspire the construction and installation of green
roofs and walls, include:
Expediting project permits if green roofs are a
part of the project plan.
Low interest loans.
Using green roofs and walls to achieve points for
sustainable development plans.
Employing a stormwater credit trading system
that allows developers to purchase some of their
regulatory retention of stormwater requirements
on the open market, or sell excess capacity,
beyond the regulatory minimum. This ability helps
to finance capital and maintenance costs
associated with multiple forms of stormwater Photo: Habitat Horticulture Exterior Living Wall at 2177 3rd
management. St. in San Francisco, CA.
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Construction Standards
Developing construction standards alongside incentives and regulations is critical to the success of your
policy initiative. Some jurisdictions have developed detailed construction standards which incorporate a
combination of prescriptive and performance based elements. These standards are essential for ensuring
that green roofs are properly designed, installed and maintained, as long standing public assets. Below is an
example of a construction standard implemented in 2012 by Deven’s Enterprise Commission for its green
roof regulations. See appendix B for an example of a comprehensive construction standard from Devens.
Though there is no one-size-fits all template for green roof policy evolution, there are some typical stages
that have been identified over a number of initiatives that may be useful when considering such efforts.
They are as follows:
Discovery/Initiation
Establishing/identifying the policy potential, possibly to include a strategic window of opportunity, and
initiating accordingly. This opportunity can take various forms: a project champion (such as the right mayor,
elected official, or department head), a climate change initiative, or other related planning efforts (whether
at a neighborhood, district, or citywide scale). San Francisco’s green roof path began with a motivated
official, a willing elected sponsor, and an emerging climate change agenda. In Denver, the lack of interest or
willingness on the part of public officials catalyzed a citizen-led effort that prevailed - despite the lack of
official support - with the voting populace demanding effective action.
Environmental Enlightenment
Focusing on the environmental potential, and establishing how it correlates with existing or prospective
policies or strategic opportunities.
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Professional Ripening
If regulatory mandates are established and markets are invigorated, trades and professionals will emerge to
meet new market opportunities and demands.
Economic Maturation
As markets evolve and the supportive environment tracks with that evolution, economies of scale
contribute to greater economic efficiency and value.
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Understanding the added value and cost of any regulation is critical to both immediate and long- term
support and effectiveness. Making the business case for new green roof policy is essential, in a way that
incorporates local conditions and real costs based on local expertise, trades and real estate economics.
Any effort to establish a policy or regulation should include anticipatory financial analysis to address
concerns about the first-cost of green roof installation and maintenance. Economic concern is inevitable: it’s
the one aspect that all policy makers and the constituencies most affected will raise early. Demonstrated
benefits for different types of buildings and at various building scales, and at the community-wide scale
have proven to win over a wide variety of constituencies for the policies in cities like New York, Denver,
San Francisco and Toronto.
The financial analysis should be applied to an array of building typologies given the wide range of economic
factors at play. For example, multi-unit housing and big box retailers face very different cost and benefit
scenarios and have different opportunities for cost savings/revenue generation associated with green roofs.
Assumptions within such analyses need to be based on local bioclimatic conditions, zoning and the specific
development environment. The more ready and complete the analysis, the greater the likelihood of
advancement. Once an analysis is established for a particular geography, it is a modest effort to apply it to
various building typologies as appropriate for the locality. This information will address concerns of
stakeholders, and can also contribute to the crafting of a more effective policy.
The analytical tools exist and are accessible.
Executing a cost-benefit analysis that is transparent
and defensible is essential to best understand and
describe the implications and benefits of prospective
policy initiatives. San Francisco’s analysis was
procured and designed with the specific intent of
being non-proprietary, transferable, and readily
calibrated and applied to other climates and market
conditions. Since its origination, Green Roofs for
Healthy Cities has assisted in applying this essential
tool elsewhere.
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Identify stakeholders, both supporters and others, early in the process to to best-
define an effective regulatory approach and accompanying advocacy strategy.
It is recommended to seek input from other municipalities who have generated policies and regulations in
order to employ that intelligence to achieve early support from stakeholders.
Denver, Colorado
Denver s a good recent example where such early input was not achievable, with mixed results as a
consequence:
In 2017, Denver passed the Green Roof Ordinance, following a citizen-led effort in reaction to local
government’s climate change inaction. The stringent ordinance mandated green roofs on both new and
existing buildings. Following passage, a technical committee was convened to adjust the mandated
requirements. That process determined that green roofs were not feasible for most existing buildings. This
opened the initiative to a fundamental reworking, which was amended to mandate a less stringent and
impactful set of compliance options.
The Denver effort provides two principle lessons. First: in the absence of policy leadership and best public
participation practices, fundamental stakeholder issues may not be adequately vetted and incorporated, and
ultimate results may be compromised. Second, if efforts are not appropriately led by policymakers; citizens
can, and will, act.
Cambridge, Massachusetts
Cambridge is another example of - when elected
officials and leaders do not adequately address
the imminence of the climate change threat,
citizens will step in. In that case, Mothers Out
Front orchestrated a sophisticated and
intentional multi step effort to manifest a clear
and assertive green roof requirement. Their
approach is fully documented and an excellent
template for citizen action.⁶
Photo: Mothers Out Front
San Francisco, California
Alternatively, San Francisco developed and applied its financial analyses early. Armed with that information,
it then proactively identified and educated elected officials, neighborhoods, housing advocates, and
designers. Once the city’s mandatory green roof and solar regulations were defined and went through public
processes, there was no opposition whatsoever.
⁶ Melissa Ludtke, Living Architecture Monitor Summer 2021. A Climate Solution: How Mothers Out Front Won A Green Roof
Requirement in Cambridge, Mass. https://livingarchitecturemonitor.com/articles/mothers-out-front-green-roof-requirement-in-
cambridge-massachusetts-su21
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Mandatory policies provide the most immediate path to green roof deployment. However, flexibility is
necessary in terms of public support and performance.
In the case of San Francisco, the option to employ solar, living roofs, or a combination was key to its ready
path to approval and implementation. Financial analysis included balancing the cost benefit for these
respective approaches so as to offer a level playing field for projects considering one option or the other. As
the cost-effectiveness of these two approaches would likely change over time, consideration might be given
to revisiting the balancing of the options once or twice a decade for municipalities offering a menu of
choices.
As described above, Denver was able to achieve consensus once stakeholders arrived at a menu of
compliance options. However, Denver’s highly politicized process did not go through a process of assessing
the relative environmental and cost benefits for each option, and tailoring them accordingly. As a result,
many developers will pursue the lowest first cost solutions.
Similar to Denver, in New York City, recent policies in support of green roofs include an either or provision
for solar panels, which enjoy a high level of subsidies. As a result, many developers are opting for solar panel
only roofs, even though the two technologies are complementary in many ways, including increasing solar
panel efficiency by anywhere from 1 to 15 per cent. .
Establishing a level playing field between various competing roofing technologies is one approach, while
another is deciding to tilt the market to a technology which best suits local needs. For example, if the area in
question is lacking in accessible green space, then policy can be developed that provides enhanced support
for this application. This approach is exemplified by Green Area Factor policies, which provide a weighing of
different green infrastructure applications, based on the extent to which they provide public benefits.
Incentives have played a big role over the last decade in many cities,
particularly when the benefits of green roofs were unproven and/or
unknown. Incentives make sense now, only if it is the only politically PollinateTO grant recipients, Toronto. Photo:
viable path. Matt Forsythe
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Incentives can encourage markets, but regulations establish markets, and provide predictable demand so
that private sector suppliers can ramp up their activities. Mandates are also simpler and more cost-effective
to implement and less likely to fall victim to future budgetary cycles.
Several jurisdictions, recognizing the need for flexibility, offer developers the opportunity to buy out of the
requirement for a green roof, typically at higher rates than compliance. In the case of Toronto, the money is
deployed into the Eco-Roof Fund which provides financial incentives to implement green roofs on existing
buildings. It is important to price the buy out properly, and design-in recalibration of the buy-out rate over
time, so that it is properly scaled and not the least expensive option. It is also important to employ funds to
achieve a similar effect.
Complementing compliance options for mandatory policies with incentive policies may make choosing a
green roof option more appealing. However, incentive policies with low tax abatements, minimal rebates, or
strict restrictive covenants will not be adequate to encourage markets to emerge. The benefits of incentive
programs must outweigh or at least meet the cost of installing a green roof for private property owners in
order to have a meaningful effect. If there are buy-out options for those having green roofs mandated, the
cost of the buy-out must be at least the same or higher than compliance with the mandate.
Be clear about what is meant by ‘green roof’ as it relates to other roof technologies, such as solar panels or
reflective roofing. San Francisco employed the term “living roof” because that ordinance was advanced
following a period of drought, and it was thought “green roof” could be optically problematic in a moment
where homeowners were being asked to minimize water use. Portland has long-used the term “ecoroof”, as
green was already in abundance and the terminology helped reinforce the environmental enhancement
qualities of green roofs.
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Green Roof Professional (GRP) certification is designed to provide those who earn the accreditation with
knowledge of best practices in design, installation, and maintenance. Should concern be raised about the
availability of professional capacity or expertise, such certification can be referenced, and even incentivized
by providing expedited review for certified professionals.
As in so many things, the green roof policy perfection can be the enemy of the good.
Local appetite for new regulation is variable, particularly when considering “new” technologies in an
evolving market. There’s wisdom in manifesting politically expedient “starter” requirements if necessary,
allowing the market and the trades to mature, in anticipation of additional requirements down the road as
changing political landscapes and other policy efforts present new opportunities to expand or otherwise
augment approaches already in-place.
It is necessary to be specific about what is meant by a ‘green roof’ with a clear delineation of performance
requirements, and appropriate but minimal detail about specific assemblies. For example, four inches of
growing medium can retain a quarter inch of stormwater, or three inches of stormwater, depending upon its
composition. If stormwater retention is a primary policy driver, it is more appropriate and accurate to define
a requirement established based on inches of rainfall retained, rather than prescriptive language about
individual systems. This is particularly key, as technologies and practices will evolve over time. A resilient
regulation will be able to deliver results, while allowing for the evolution and innovation of technical
approaches.
The Living Architecture Performance Tool describes all of the potential green roof and wall benefits and
provides performance measures, minimum requirements, and examples of how they can be achieved. Many
building owners/developers will seek the least costly compliance path; clearly and convincingly defining the
relative costs and benefits of the technologies can help projects select approaches most suitable for their
performance and program.
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Lessons Learned
Policy is a great tool to address the lack of awareness of green roofs and promote education about green
roofs. But policies without implementation tools are not effective at increasing the installation of green
roofs or walls in cities. The time to implement meaningful tools is now. Any effort to establish a policy or
regulation should include anticipatory financial analysis to address inevitable concerns about the first- cost
of green roof installation and maintenance.
It is recommended to seek feedback from other municipalities who have generated policies and regulations,
as well as attempt to achieve early support from stakeholders. In 2017, Denver passed the Green Roof
Ordinance after a citizen-led effort advocated for green roof policy. The ordinance mandated green roofs on
both new and existing buildings. The requirements for green roofs on all existing buildings were particularly
concerning to some constituencies, and led to well-organized and funded opposition to the initiative.
Following passage, a technical committee was convened to adjust the requirements mandated by the
sweeping initiative. Over the course of that process, it was determined that green roofs are not a feasible
option for 95 percent of existing buildings because they would be unable to support the extra loading
requirements. This opened the initiative language to a fundamental reworking, and it was ultimately
amended to now mandate that buildings have a cool roof and one of a series of compliance options, of
which installing green roofs or walls are included. The complicated array of options in Denver comes with an
immediate cost: staffing to administer the ordinance is multiples greater than other cities with clear codified
mandates. This added cost also makes the program vulnerable to future budget processes in leaner times.
Multi-story green facades around an inner courtyard, Jakob Rope Systems, Vietnam. Photo: Oki Hiroyuki for G8A Architects, HCMC,
Vietnam
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Complementing compliance options for mandatory policies with incentive policies may make choosing a
green roof option more appealing. However, incentive policies with low tax abatements, minimal rebates, or
strict restrictive covenants do not make installing green roofs accessible or appealing. The benefits of
incentive programs should outweigh or meet the cost of installing a green roof for private property owners.
Conducting a cost-benefit analysis that is transparent and defensible to best understand and describe the
implications and benefits of prospective policy initiatives is key. Once an analysis is established for a
particular geography, it is a modest effort to apply it to various building typologies as appropriate for the
locality. This information will help you not only to address concerns of stakeholders but can also contribute
to a more effective policy. Avoid either or options for regulatory compliance, particularly since green roofs,
blue roofs, solar roofs and reflective (white) roofs have very different cost and benefit profiles and are
therefore not equivalent to each other.
Consult with various stakeholders and you will likely find that there is a very large public constituency in
favor of policies that support green roofs and walls. Building owners and developers are already on board
with green roof and wall policies that can be hugely helpful in countering concerns.
Be clear about what is meant by ‘green roof’ as it relates to other roof technologies, such as solar panels or
reflective roofing. Language matters: San Francisco employed “living roof” terminology because that
ordinance advanced following a period of drought concern, and it was thought “green roof” could be
optically problematic in a moment where homeowners were being asked to minimize water use.
Use performance-based measures, such as minimum retention rates for stormwater, rather than prescribing
systems or their components. This allows the market flexibility as to how best to meet the performance
requirements. The Living Architecture Performance Tool is designed to improve the performance of green
roofs and walls by providing a scientifically based framework of performance measures and minimum
prerequisites for the design, installation and maintenance of these technologies. It can provide a framework
for meeting your policy objectives and performance goals.
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Conclusion
Despite the numerous recent advances in implementing green roof regulations, green roofs and walls
continue to be underutilized in many cities across North America. Cities each year are establishing
increasingly stringent beneficial requirements in order to address a number of policy goals. It is appropriate,
and necessary to continue to advocate for policy where there is none to incorporate green roofs and walls
in all major new developments. Appropriately conceived policy will ensure that green roofs and walls are
installed and maintained according to best practices. Such expansive deployment is already advancing the
real estate value and city-scale environmental benefits. Green Roofs for Healthy Cities continues to monitor
and provide feedback on legislation to evaluate individual policies and facilitate continuous improvement.
Green Roofs for Healthy Cities is committed to continuing to develop tools that municipalities can use as a
guide to create their own policy. In addition to green roof performance standards, it will continue to address
the applicability of appropriate programs in different geographies and bioclimates, elaborate on different
regulatory measures, and be available to support future such efforts.
Ultimately, success in increasing green roof policy and the widespread implementation of green roofs is a
direct result of green roof champions in government and industry collaborating to promote and sponsor
legislation. In partnership with third parties, such as Green Roofs for Healthy Cities, and passionate citizens
advocating for change, green roofs will continue to be assertively advocated for and implemented as an
essential and effective means to combat local and global environmental challenges.
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Resources
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Residential
Tax Funding (Grant, Stormwater Fee Density or Floor Area
Stewardship Other
Credit Rebate, or Subsidy) Credit Ration Bonus
Program
Bellingham,
X 2017 – Vegetated Roof Incentive
Washington
Fees in lieu of
Cambridge, greenspace on
2021 – Green Roof Ordinance
Massachusetts appropriate
buildings
Minimum roof
2017 - Green Building Ordinance
Denver, Colorado X pitch requirement
2023 – Green Roof Incentive
waived
Ellensburg,
X 2013 – Density Bonus Incentives
Washington
Fees if
stormwater
2018 – Green Infrastructure Bonus
Hoboken, New Jersey X performance
Standards for Impervious Coverage
measures are not
met
Accelerated
Kirkland, Washington X?? 2013 – Priority Permit Review
permit process
Minneapolis,
X 2017 – Stormwater Utility Fee Credit
Minnesota
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Mandate or
Location Incentives Policy Name
Regulation
Northeast Ohio
Regional Sewer X Revised 2016 – Impervious Area Reduction Credit
District
Onondaga
Grant 2018 – Green Improvement Fund
County, New York
Prince George
2013 – Rain Check Rebate Program
County, Maryland
Saint Laurent,
X 2016 - Règlement sur le zonage no RCA08-08-001
Quebec
Waiving of application
and pre-application
fees, reduced
Shoreline, Transportation impact
2022 – Deep Green Incentive Program
Washington fees, Departures from
Development Code
allowed, accelerated
permit process
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Policy Details: The Sustainable Development Policy requires that development projects earn a number of
points by implementing select sustainable strategies. It applies to new developments, TIF funded
developments receiving over $1 million, or multi-family housing projects over 5 units that receive specific
financial assistance. All new developments are required to reach 100 points. The two compliance pathways
are earning points from the strategies menu without building certifications or earning points from a building
certification and earning the reset of the points from the strategies menu. The menu includes strategies in
the following categories: health, energy, stormwater, landscapes, green roofs, water, transportation, solid
waste, work force and wildlife. The green roofs will earn a project 10 points if 50-100% of the building’s net
roof area is covered with vegetation, or 20 points if it covers 100% of the net roof area. The net roof area is
the gross roof area with the exception of the area for mechanicals, maintenance pathways, window washing
systems, swimming pools and skylights. More than 5 million square feet of green roofs have been
implemented in Chicago to date as a result of its policy initiatives in support of green roofs.
Link: https://www.chicago.gov/city/en/depts/dcd/supp_info/sustainable_development/chicago-
sustainable-development-policy-handbook0.html
Denver, Colorado
Policy Name: Green Building Ordinance
Year: 2017
Policy Details: New buildings, new additions to buildings and existing buildings with a certificate of
occupancy that are 25,000 ft² must have a cool roof and comply with one other Green Buildings
requirements. The compliance options are: green roofs/green space, installing or purchasing solar or other
renewable energy, energy cost savings/using less energy than code, green building certifications, payment
to the Green Building Fund, and enrolling in the Energy Program. The compliance option for green space
can be achieved by installing a green roof. With this option, the green roof of new buildings must be
calculated by starting with the total roof area and deducting the following: private terraces equal to or
smaller than the gross floor area of the abutting unit at the roof level, outdoor amenity spaces, rooftop
mechanical and electrical equipment, skylights, glass covered atriums, window glazing, and areas covered by
renewable energy devices. Vegetation shall be designed to cover 80% of the vegetated roof within 3 years,
or be used for urban agriculture.
Link: https://www.denvergov.org/Government/Agencies-Departments-Offices/Agencies-Departments-
Offices-Directory/Community-Planning-and-Development/Green-Buildings-Ordinance
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Devens, Massachusetts
Policy Name: Policy for Construction of Vegetated Roofs
City: Devens Enterprise Zone, MA
Year: 2011, amended 2012
Policy Details: When building a green roof, a member of the construction team must be a Green Roof
Professional (GRP). The policy requires that the vegetation on the roof not be an invasive species, and that it
must be native plants with seeds appropriate to Devens’ USDA hardiness zone (5b). Green roofs shall have a
minimum of 4 inches of growing media that cover 40% of the roof area, with at least 80% coverage within
three years of the date they are planted.
Link: http://devensec.com/development/DEC_vegetated%20_Roof_policy_revised_January2012.pdf
Policy Name: Industrial Performance Standards and General Regulations: Greenhouse Gas Mitigation
(974CMR 4.11 2.(c))
Year: 2012
Policy Details: Projects that require an air quality permit are required to have a vegetated roof that covers at
least 30% of the roof. The roof must be designed in compliance with the Policy for Construction of
Vegetated Roofs.
Link: http://www.devensec.com/rules-regs/decregs411.html
Policy Name: Viewshed Overlay District Vegetated Rooftops and Vegetated Walls Requirement (974CMR
3.04(8) (i)5)
Year: 2013
Policy Details: The design standards for buildings in the Viewshed Overlay District (projects visible from the
Museum of the New England Landscape) are required to the extent possible to install vegetated roofs and
vegetated walls.
Link: http://www.devensec.com/rules-regs/decregs304.html
Fife, Washington
Policy Name: Green Factor
Year: 2009
Policy Details: In order to receive a project permit, new developments, redevelopments and construction
sites must have a landscaping plan that achieves the green factor. Plans meet the green factor by
implementing green factor elements, each of which have a score. The total green factor score that must be
met is calculated by dividing “the green area factor by the lot area”. Each green factor element has a
correlated multiplier, which is used to calculate the green factor. The green factor elements include green
roofs.
Link: https://www.cityoffife.org/258/Fife-Green-Factor
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Policy Details: New buildings and existing buildings undergoing major renovations in specific occupancy
groups defined in the New York City Building Code are required to have a 100% of the available roof space
as a sustainable roofing zone. A sustainable roofing zone is covered in a green roofing system and/or solar
panels and/or wind turbines. Currently, only 1 in one thousand buildings have a green roof in New York
City.
Link: https://legistar.council.nyc.gov/LegislationDetail.aspx?ID=3557657&GUID=B4C3A822-2FBB-45FD-
8A74-C59DD95246C1&Options=ID%7CText%7C&Search=1032
Policy Name: The Clean Water, Clean Air, and Green Jobs Environmental Bond Act of 2022
Year: 2022
Policy Details: 4.2 billion dollars are being allocated towards mitigation projections such as flood risk
reduction, clean energy, and land conservation. The bond mandates that disadvantaged communities
receive 40 percent of overall benefits of state spending on clean energy. The bond act will support over 84
000 jobs and 8.7 billion dollars in project spending and the projects that receive funding must comply with
minimum wage requirements.
Link: https://www.nysac.org/files/NYSAC%20Whitepaper%20-
%20Clean%20Air,%20Clean%20Water,%20and%20Green%20Jobs%20Bond%20Act.pdf
Portland, Oregon
Policy Name: EcoRoof Requirement
Year: 2018
Policy Details: New buildings with a net building area of 20,000 square feet or more must have an ecoroof
that covers 100% of the building area (with exceptions). New buildings with a net building area of 20,000
square feet or more must have an ecoroof that covers 100% of the building roof area, except that up to
40% of the area may be covered with elements such as skylights, solar panels, mechanical equipment, etc.
The ecoroof must also meet the Portland Stormwater Management Manual's Ecoroof Facility Design
Criteria. The ecoroof requirement applies in the Central City 2035 Plan District. Previously, Portland
provided grants for green roof installations to help manage stormwater (33.510.243 Ecoroofs).
Link: https://lpdd.org/resources/portlands-ecoroof-requirements/
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Policy Details: All flat and low-pitched roofs, and flat and low-pitched roof sections must be covered in
vegetation or covered in materials with a solar reflective index (SRI). A permit will be required for the
installation and replacement of any roof cladding for a flat or slow-pitched roof (under 2:12) or for a section
of a flat or slow-pitched roof. Only the following types of materials are authorized to cover a flat roof or a
low-pitched roof:
- Green roof (vegetated).
- Light roof covered with white gravel.
- Light roof covered with a material with a Solar Reflectance Index (SRI) of at least 78, as attested by the
manufacturer or a professional.
Link:http://ville.montreal.qc.ca/pls/portal/docs/PAGE/ARROND_SLA_EN/MEDIA/DOCUMENTS/2018%2
0TOITPLAT%20ANG.PDF
Policy Details: New buildings are required to have 15% of the roof space as solar panels or 30% of the roof
space as a Living (green) Roof. The ordinance applies to buildings that are: non-residential buildings with a
gross floor area of 2000 square feet or residential buildings of any size, and the buildings have 10 or fewer
occupied floors. The growing media should be at least 4 inches deep. The vegetation must have a high
species diversity, include native species, and be low water use and use low maintenance plants.
Link: http://default.sfplanning.org/publications_reports/ZAB_11_Better%20Roofs_051517.pdf
Policy Name: Central SOMA Plan Living Roof and Solar Requirement
Year: 2019
Policy Details: New buildings are required to have 15% of the roof space as solar panels and 50% of the
roof space as a Living (green) Roof. The ordinance applies to buildings that are: on a lo 5000 square feet or
larger with a building height 160’ in height or less.
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Seattle, Washington
Policy name: Green Factor
Year: 2007
Policy Details: Minimum Green Factor scores must be met for areas requiring landscaping. There are
different scores required depending on the zoning of the development. Under the Seattle Green Factor,
varying landscape elements are assigned a multiplier value (or a score). The Green Factor is calculated by
multiplying the square feet of a landscape element by its score. The landscape elements include green roofs
and walls along with other types of green infrastructure. Green roofs must have at least 2 inches of growing
medium, and have a higher score if they have over 4 inches of growing medium.
Link: https://library.municode.com/wa/seattle/codes/municipal_code?
nodeId=TIT23LAUSCO_SUBTITLE_IVAD_CH23.86ME_23.86.019GRFAME
Toronto, Ontario
Policy name: Green Roof Bylaw
Year: 2009, amended 2011
Policy Details: New commercial, institutional and residential developments with a minimum gross floor area
of 2000 meters squared are required to have green roofs. detailed construction standards. The plant
selection and design must cover at least 80% of the green roof within 3 years of planting. The growing
medium must be at least 4 inches to help ensure winter plant survival.
The coverage requirements for the green roof bylaw are graduated. Buildings with larger gross floor area
are required to cover more from 20% at the low end to 60% at the high end. Available Roof Space. The
bylaw allows for solar rooftops by defining Available Roof Space as excluding areas for renewable energy. A
if gross floor area is > 4,999m², 30% of available roof area if gross floor area is 5,000-9,999 m², 40% of
available roof area if gross floor area is 10,000-14,999m², 50% of the available roof space if gross floor area
is 15,000-19,999m² and 60% of the available roof space if gross floor area is 20,000m²+.
Developers can provide cash-in-lieu for reduced green roof area, or to avoid implementing a green roof at a
cost of $200/meter squared. To date, less than 10% of new buildings have requested any payment of cash-
in lieu. This money goes to fund the Ecoroof Grant Program, which provides grants to existing building
owners of up to $100/meter squared for green roof installations. To date, more than 6.5 million square feet
of green roofs have been implemented in Toronto through this policy over the past thirteen years.
To encourage more biodiverse, Toronto developed guidelines for biodiverse green roofs that describe best
practices to create habitat and promote biodiversity. In 2022, through the City’s green building
requirements for new development, the Toronto Green Standard Version 4, higher performance green
infrastructure became a requirement for all new development. This has driven the uptake of more intensive
and biodiverse green roof systems.
Link: https://www.toronto.ca/city-government/planning-development/official-plan-guidelines/green-
roofs/green-roof-overview/
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Washington, DC
Policy Name: Green Area Ratio
Year: 2017
Policy Details: All new buildings that require a Certificate of Occupancy must meet the appropriate Green
Area Ratio (GAR) based on the zoning district. The Green Area Ratio is the ratio of the weighted value of
landscape elements to land area. The score of landscape elements is calculated by multiplying the area of
each element by its multiplier value and adding the scores together. Landscape elements include: soil and
amendments, bioretention, new and existing planting, trees, vegetated walls and roofs, and more. Vegetated
roofs must have a minimum of 5-7 species and no more than 20% of the total vegetated roof can be
individual native species. Plants should achieve minimum 80% coverage after 2 years. There must be a
minimum of 2 succulent plugs/square foot or 10 lbs of cuttings/100 square feet. Designs must include
supplemental water. Green walls must include 1 cubic foot of soil/10 square feet of green façade.
Link: https://doee.dc.gov/node/619622
Incentive Programs
Austin, Texas
Policy Name: Downtown Density Bonus Program
Year: 2014
Policy Details: Developments may achieve bonus area for buildings by providing green roofs. The green
roofs must be built to the Vegetated Roof Performance Standards. For 30-49% coverage of green roof
(which is calculated as a portion of total roof area excluding mechanical equipment), 2 bonus square feet are
granted; and for 50% or greater coverage of green roof, 3 square feet are granted. 2 additional bonus
square feet can be achieved if the roofs are publicly accessible and 2 additional bonus square feet can be
achieved if the roof meets the Downtown Public Plaza Standards. The green roofs must be 90% native
species or adapted species with no invasive species.
Link: http://www.austintexas.gov/edims/document.cfm?id=206958
Bellingham, Washington
Policy Name: Vegetated Roof Incentive
Year: 2017
Policy Details: Use of a vegetated roof will help to meet criteria that could qualify a project for a 50%
reduction in the stormwater development charges.
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Additionally, a vegetated roof can also be incorporated into a project to help avoid the triggering of the 0.1
cfs increase in flow for the 100-year storm threshold to require stormwater detention or to reduce the
required size of stormwater mitigation facilities by using allowed stormwater modeling credits. Credits can
be found in the Stormwater Management Manual for Western Washington published in 2005 or the Low
Impact Development Technical Guidance Manual for Puget Sound.
Link: https://cob.org/wp-content/uploads/amm303-vegetated-roof.pdf
Chicago, Illinois
Policy Name: Green Permit Program
Year: 2014
Policy Details: Projects that include green technologies, including green roofs, can receive an expedited
permit process (fewer than 30 days) and possibly a reduction of the permit fees. Projects which meet the
most stringent sustainability guidelines may qualify for a waiver of consultant code fees ($25,000).
Link: https://www.chicago.gov/city/en/depts/bldgs/provdrs/permits/svcs/green-permits.html
Cambridge, Massachusetts
Policy Name: Green Roof Ordinance
Year: 2021
Policy Details: The Green Roofs initiative will require developers within the city to integrate vegetative or
biosolar roofs into their design plans going forward when constructing new buildings. This ordinance also
includes incentives which the previous initiative in 2009 did not have for developers to create vegetative
roofs. Developers who do not meet the city’s new green roof requirements will be obliged to make a
payment to the Cambridge Affordable Housing trust to fund green roofs on supportive housing projects.
Link:
https://www.cambridgema.gov/CDD/zoninganddevelopment/sustainabledevelopment/article22greenroofs
requirement#:~:text=Under%20the%20Green%20Roofs%20Requirement,in%20the%20Gross%20Floor%2
0Area.
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Covington, Washington
Policy Name: Green Building Incentives
Year: 2022
Policy Details: Cottage owners can receive a bonus of one and one-half times base density if the cottage
and community building are built to LEED Gold, or Built Green 4 Star or 5 Star standards.
Affordability and green building incentives may be combined up to a maximum of two times base density.
Note that 4 and 5 Star Built Green levels require verification by a third party.
Link: https://covington.municipal.codes/CMC/18.37.040
Denver, Colorado
Policy Name: Green Roof Incentive
Year: 2023
Policy Details: If a green roof occupies more than 50% of the total area of any building’s primary roof
surface, the minimum requirement for pitched roof provision will be waived provided the building design
complies with the other major standard intentions
Link:
https://steamboatsprings.net/DocumentCenter/View/3854/Sec404BaseAreaDesignStandards9242019?
bidId=
Ellensburg, Washington
Policy Name: Density Bonus Incentives
Year: 2013
Policy Details: The purposes of the Density Bonus Initiatives are to promote a variety of housing types built
with green building practices, promote compact development patterns, promote the integration of trails,
promote the preservation of historic resources, promote the integration of affordable housing into new
developments, encourage the preservation of valuable resource lands outside of the city.
There are several bonus elements Developments may use a combination provided they comply with the
maximum density provisions set forth for the zone. An exception to the maximum density provisions is only
provided for projects complying with Net Zero Energy standards. See below the table of Density Bonuses
for the R-S and R-L zones
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Kirkland, Washington
Policy Name: Priority Permit Review
Year: 2013
Policy Details: This is a way to get faster permit processing in Kirkland for new single-family home or duplex
projects that certify through programs such as Built Green or LEED. Not only will your permit get priority,
but the homes or homes you construct will have the added value of being certified through a widely
recognized green building program and will be better for the people who live in them and better for the
environment. Use of a vegetated roof will help to meet criteria that could qualify a project for a 50%
reduction in the stormwater development charges.
In order to qualify for Priority Permit Review under Kirkland’s Green Building Program, you must submit
with a completed building permit application the following items:
1. A completed and signed Green Building Program Priority Review for New Single-Family Residences
contract
2. A preliminary checklist that shows how the design is to achieve either:
a. Four star or better rating through Built Green or
b. Silver or better rating through LEED for Homes
3. A copy of a Third-Party Verifier contract who will verify your Built Green or LEED project.
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Additionally, a vegetated roof can also be incorporated into a project to help avoid the triggering of the 0.1
cfs increase in flow for the 100-year storm threshold to require stormwater detention or to reduce the
required size of stormwater mitigation facilities by using allowed stormwater modeling credits. Credits can
be found in the Stormwater Management Manual for Western Washington published in 2005 or the Low
Impact Development Technical Guidance Manual for Puget Sound.
Link: https://www.kirklandwa.gov/Government/Departments/Development-Services-Center/Green-
Building
Policy Details: Individual residential properties can receive a credit up to 25% for implementing best
management practices. Multi-residence, industrial and private properties can receive credits up to 50% for
practices that reduce stormwater quantity and improve its quality. Approved best management practices
are rain gardens, on-site stormwater storage and vegetated filter strips. The rain garden must cover at least
50% of the roof, or an equivalent amount of impervious area must drain into the rain garden. Additionally,
non-residential properties can receive a credit for using Green Infiltrative Infrastructure, and educational
facilities can receive an education credit for educating students on stewardship of water resources.
Link: https://citybase-cms-prod.s3.amazonaws.com/515488394718481f85d7c98d231aa959.pdf
Milwaukee, Wisconsin
Policy Name: Green Infrastructure Partnership
Year: 2019
Policy Details: The program offers incentive funding on a per-gallon captured, reimbursement basis for a
host of green infrastructure strategies designed to capture and clean water where it falls. The eligible
strategies include green roofs.
Link: https://www.mmsd.com/application/files/5615/4696/0544/18-
009_Funding_Natural_SolutionsWEB.PDF
Minneapolis, Minnesota
Policy Name: Stormwater Utility Fee Credit
Year: 2017
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Policy Details: Property owners can receive credits against their stormwater utility fee for installing a green
roof. There are two categories of credits for constructed stormwater management practices: Category 1:
Stormwater quality credits: The amount of the quality credit (up to 50 percent of the stormwater utility fee)
is based on the percentage of the total impervious area on the parcel treated by BMPs. Category 2:
Stormwater quantity-reduction credits: Property owners who can demonstrate that all stormwater is
retained on site without discharge during the 10-year design storm (50% credit) or the 100-year design
storm (100% credit), may be eligible for a stormwater quantity reduction credit.
Link: http://www.minneapolismn.gov/www/groups/public/@publicworks/documents/webcontent/wcmsp-
205493.pdf
Policy Details: Residential properties can receive a rebate of $9/square foot up to a total of $7,500 for
installing a minimum 100 square foot green roof. Green roofs on institutional/commercial properties must
be a minimum 200 square feet and are eligible for up to $20,000 in rebates. The green roofs must have at
least 4 inches of growing media.
Link: https://www.montgomerycountymd.gov/water/rainscapes/rebates.html
Policy Details: Property owners can receive a one-year tax abatement of $5.23/square foot for the
installation of a green roof, and in certain high need areas, as much as $15 per square foot. At least 50% of
the roof must be covered with a vegetation layer. The vegetation layer must be 80% sedum or an equally
hardy species. The application must be submitted by a registered architect or licensed engineer. In 2019,
New York City Council passed a resolution to call on the state legislature to pass and the governor to sign
legislation that would increase the real property tax abatement for the installation of green roofs to
$15/square foot. Details of this abatement are still being worked out at the time of publication.
Link: https://www1.nyc.gov/assets/buildings/pdf/green_roof_tax_abatement_info.pdf
https://legistar.council.nyc.gov/LegislationDetail.aspx?ID=3331993&GUID=78C453B3-D03B-49C7-AE5E-
255E41404254&Options=&Search=
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Policy Details: Private property owners can apply for a grant to fund the design and construction of a green
roof. The funding is determined based on the area of the green roof and the depth of the soil. Roofs must
be between 3500-20,000 square feet. At 1.5-1.99 inches of soil depth, projects receive $10/square foot; at
2-2.99 inches of soil depth projects receive $15/square foot; at 3-3.99 inches of soil depth, projects receive
$25/square foot; and at 4+ inches of soil depth, projects receive $30/square foot. There is a restrictive
covenant with the grant stating that projects cannot be destroyed, removed or altered without the city’s
consent and must be maintained for 20 years.
Link: https://www1.nyc.gov/html/dep/html/stormwater/nyc_green_infrastructure_grant_program.shtml
Policy Details: If a green roof is properly designed and installed, the area of the previous area will be
reduced from the property’s impervious area calculation. Property owners must recertify yearly to confirm
that the green roof hasn’t been removed and that it is being maintained. The current impervious area
charges for residential properties are: $3.09 for less than 2,000 square feet; $5.15 for 2,000-3,999 square
feet; $9.27 for 4,000 square feet or more; and $2.07 for any size homestead. The current impervious area
charges for non-residential properties are $5.15 per ERU or 3,000 square feet.
Link: https://www.neorsd.org/I_Library.php?
SOURCE=library/CreditManual_ALL_12182012.pdf&a=download_file&LIBRARY_RECORD_ID=4699
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Policy Details: Facility property owners are eligible for grants for the installation of green infrastructure for
stormwater management, such as green roofs. Green roofs on high-priority sites can receive up to 30
cents/gallon captured, medium-priority sites can receive up to 20 cents/gallon, and captured low-priority
sites can receive up to 10 cents/gallon.
Link: http://savetherain.us/wp-content/uploads/2018/06/2018_GIFApplication_051618.pdf
Philadelphia, Pennsylvania
Policy Name: Green Roof Tax Credit
Year: 2007, revised 2016
Policy Details: Businesses can apply for a Green Roof Tax Credit for 50% of the cost to construct a green
roof, up to $100,000.
Link: http://www.greenroofsphilly.com/incentives.html
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The Philadelphia Water Department lists green roofs as a stormwater management method. The
Philadelphia Stormwater Management Guidance Manual includes green roof plan standards for the
development and construction of green roofs.
Link:
https://www.phila.gov/water/wu/Stormwater%20Grant%20Resources/StormwaterGrantsManual.pdf
Policy Details: The program reimburses property owners who install stormwater management practices.
Residential property owners can be reimbursed up to $4,000, and larger property owners can be reimbursed
up to $20,000. Stormwater management practices include green roofs with $10/square foot of green roof
reimbursed for at least ¼ of the roof being a green roof for residential properties; and at least $10/square
foot for at least 6 inches of planting material on ¼ of the roof for non-residential properties. Non-residential
properties can also receive $20/square foot for over 6 inches of planting material.
Link: https://cbtrust.org/grants/prince-georges-county-rain-check-rebate/
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Redmond, Washington
Policy Name: Green Building and Green Infrastructure Incentive Program
Year: 2011
Policy Details: The incentive program details sustainable development techniques which may be used
when building green buildings and infrastructure. Points are rewarded for using such techniques, and can
be used toward certain incentives. See the link below for the full table and explanation of which techniques
are awarded points.
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Note Stormwater Infrastructure requirements are based on impervious area. Use of techniques at left is
likely to reduce infrastructure costs - an additional incentive
Link: https://www.codepublishing.com/WA/Redmond/CDG/RCDG20C/RCDG20C3057.html
Seattle, Washington
Policy Name: Land Use Code
Year: Amended July 2022
Policy Details: There are height exceptions for elevator penthouses if the elevator provides access to a
high-rise rooftop that has a green roof.
Link: https://library.municode.com/wa/seattle/codes/municipal_code?
nodeId=TIT23LAUSCO_SUBTITLE_IIILAUSRE_CH23.75MAPLCO_PT3DEST_23.75.100STHE
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Shoreline, Washington
Policy Name: Deep Green Incentive Program
Year: 2022
Policy Details: In order to request exemptions, waivers, or other incentives through the Deep Green
Incentive Program, the applicant or owner shall submit a summary demonstrating how their project will meet
each of the requirements of the relevant certification program, such as including an overall design concept,
proposed energy balance, proposed water balance, and descriptions of innovative systems.
An eligible project shall qualify for the DGIP upon determination by the Director that it has submitted a
complete application pursuant to SMC 20.30.297, Administrative Design Review (Type A), and has complied
with the application requirements of this subsection.
The project must be registered with the appropriate third-party certification entity such as the International
Living Future Institute, Built Green, US Green Building Council, Passive House Institute US, or Salmon Safe.
Projects requesting departures under the DGIP shall meet the current version of the appropriate certification
program, which will qualify them for one of the following tiered packages of incentives:
Tier 1 – Living Building Challenge or Living Community Challenge Certification: achieve all of the Imperatives
of the ILFI programs;
Tier 2 – Emerald Star or Petal Certification: satisfy requirements of Built Green program or three or more ILFI
Petals, including at least one of the following: water, energy, or materials;
Tier 3 – LEED Platinum, 5-Star, PHIUS + Source Zero plus Salmon Safe, or ZE plus Salmon Safe: satisfy
requirements of the respective USGBC, Built Green, PHIUS, ILFI, and/or Salmon Safe programs. The addition
of Salmon Safe certification to PHIUS+ Source Zero or ZE projects is not required for detached single-family
projects; or
Tier 4 – PHIUS+ or 4-Star: achieve all requirements of the PHIUS or Built Green programs.
Link: https://www.codepublishing.com/WA/Shoreline/#!/Shoreline20/Shoreline2050.html#20.50.630
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Toronto, Ontario
Policy Name: Eco-Roof Incentive Program
Year: 2009
Policy Details: Existing buildings, new buildings with a gross floor area of less than 2000 metres squared, and
new construction projects by schools and nonprofits are eligible to receive a grant of $100/square metre of
green roof installed and up to $1000 for a structural assessment to determine if a green roof is feasible. The
roof must be built according to Toronto’s detailed Green Roof Construction Standards.
Link: https://www.toronto.ca/services-payments/water-environment/environmental-grants-incentives-
2/green-your-roof/
Washington, DC
Policy Name: Stormwater Retention Credit Training Program
Year: 2013
Policy Details: Property owners can install green infrastructure to reduce stormwater runoff and generate
Stormwater Retention Credits. One gallon of stormwater retained in one year is equal to one credit. Credits
can be sold to projects that are required to implement stormwater management practices; and credits can be
sold to the Department of Environment and Energy if they drain into the District Water Bodies. The purchase
price per credit is based on the infrastructure’s location in the Municipal Separate Sewer System, with non-
tidal credits at $1.95 and tidal credits at $1.70. To be eligible for credits, the infrastructure must pass
maintenance inspections.
Link: https://doee.dc.gov/src
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Other
Policy Details: Adams County’s Stormwater Utility Credit encourages technical design and maintenance of
stormwater best management practices. These credits are granted to properties on two bases: 10 control of
water quantity and 2) control of water quality. Additional credit may be granted to properties for
stormwater infrastructure maintenance conducted on behalf of the County to ensure the proper function of
regional treatment on that property. Following are the maximum available credit percentages:
Water Quality Credit: 25%
Water Quantity Credit: 35%
Self-Maintenance Credit: 5% (of impervious area treated)
Basic criteria for eligibility is:
Credit will only be granted to non-single family properties
The amount of credit given for a BMP will be based on the amount of impervious area for which the
practice provides water quantity or quality treatment
Ongoing credit will be available only to properties that maintain their structural controls in fully
functional condition
Credit is not available for any property outside the utility service area. Maximum credit does not differ
from one property to the next based on proximity to water bodies
Maximum credit is not contingent upon lot size
In general, each of the three credit types can be granted at once. The maximum credit for water quality
and quantity credits is 60% credit.
Link: http://www.adcogov.org/sites/default/files/5708.pdf
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Baltimore, Maryland
Policy Name: Stormwater Fee Credit
Year: 2013
Policy Details: This fee provides citizens with a credit for maintaining, operating, and improving the City of
Baltimore’s stormwater management system. Stormwater fees for single family homes are calculated based
on the amount of impervious area on the property with the highest monthly fee being $10 USD. Citizens
can receive credits/ a discounted rate on this monthly fee via public participation such as participating in
tree planting or stream clean ups. For every 4 hours of such participation, one can receive a credit of $10
USD for a maximum of $30/year. Citizens can also claim credit by utilizing Simple Residential Best
Management Practices such as installing rain gardens to claim up to $16/year, planting trees to claim up to
$5/year per tree, and rainwater harvesting systems to claim up to $25 per rain barrel.
Link:
https://publicworks.baltimorecity.gov/sites/default/files/SFP%20Stormwater%20Guidance%20Document.
pdf
Policy Details: This program helps citizens build and maintain a rain garden at home. A direct cash payment
is given to help with some of the costs of plants and seeds. This incentive is only available for residential
buildings in Fort Wayne.
Link: http://www.catchingrainfw.org/incentive-program
Kitchener, Ontario
Policy Name: Stormwater Credit Policy
Year: 2012
Policy Details: Kitchener’s Stormwater Credit Policy rewards residents and businesses for reducing the
runoff flowing into local drainage systems.
Link: https://www.kitchenerutilities.ca/en/services/stormwater_credit_policy.aspx
Seattle, Washington
Policy Name: Stormwater Facility Credit
Year: —
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Policy Details: Provides a credit to privately-owned systems that reduce stormwater flow and/or provide
water quality treatment. Typically, single family homes do not have qualifying stormwater systems. Any parcel
property owner with a functioning, well maintained stormwater system in compliance with City Stormwater
Code standards qualifies for this program. These properties can still install green stormwater infrastructures
to receive this credit.
Link:
http://www.seattle.gov/util/ForBusinesses/DrainageSewerBusinesses/StormwaterFacilityCredit/index.htm
Washington, DC
Policy Name: RiverSmart Landscaping Rebates
Year: 2018
Policy Details: RiverSmart Rebates are for residents who do not want to wait for a stormwater assessment
through RiverSmart Homes, want to hire a contractor, or do it themselves. You can front the cost for four
different options, install the feature, and then submit for partial reimbursement. For trees, you can receive
rebates up to $100 for individuals who plant trees on private residential or commercial property, you can
receive rebates of $2/gallon for rain barrels with a maximum rebate of $1000, you can receive rebates of
$3/square foot of area treated by a rain garden with a maximum rebate of $2200, and you can receive
rebates of $10 per square foot of impervious surface removed and replaced with permeable pavers and
$5/square foot of impervious surface removed and replaced with vegetation, with a maximum rebate of
$4000.
Link: https://doee.dc.gov/riversmartrebates
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There are a variety of mandatory and voluntary guidelines and standards that govern the green roof
industry. These concern the establishment of testing protocols that are used to determine the performance
of products—such as measuring the rate of water runoff through a drainage layer or the root repellency
capabilities of a waterproofing membrane. Guidelines and standards can be either performance-based, such
as “the green roof assembly must retain the first two inches of rainfall”; or prescriptive, such as “a particular
product or its equivalent must be used.” Performance- based standards differ from prescriptive ones
because they lay out measurable criteria that have to be fulfilled without determining how they are met.
With voluntary standards, like the US Green Building Council’s LEED® program or the Sustainable Sites
Initiative™ (SITES™), there may be certain minimum requirements that must be met, while others are
optional or performance-based.
Standards are typically developed by independent, non-profit standard setting bodies such as the
International Code Council (ICC), ASTM International, Canadian Standards Association (CSA) and the
American National Standards Institute (ANSI) and later adopted by state or local governments.
In addition to standards developed by governments and traditional standard setting bodies, a number of
standards and guidelines have been published on the design and construction of green roof systems and
components, including those by FLL, a German standard-setting body and FM Global, which writes
guidelines for its insurance partners.
What follows is an overview of standard and guideline setting bodies and the work that is applicable to
green roof product testing, design and installation.
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The FLL Guidelines are prescriptive and specify elements like seam overlaps and vegetation- free zones.
Some North American companies use FLL as a mark of their products’ and systems’ excellence. However,
when drawing on the recommendations therein it is important to remember that these guidelines were
produced for the German market and as such cannot always be directly applied in the diverse North
American climate and weather context. Local building codes, ordinances, and other geographically specific
legislation, as well as climate extremes, should take precedence over imported standards.
At time of writing, the most current version of the FLL Guidelines in English was revised in 2008 and
contains the following, applicable to green roofs:
FLL Guideline for the Installation and Maintenance of Green Roofs (2008) Richtlinie für die Planung,
Ausführung und Pflege von Dachbegrünungen
Advice for the Maintenance of Green Roofs (2002) Hinweise zur Pflege und Wartung von begrünten
Dächern
Click here to read about the standard.
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FM Global
Though it is not a formal standard setting body, FM Global, a commercial and industrial property insurance
and risk management organization, exerts a large amount of influence over the construction industry. It
published Property Loss Prevention Data Sheet 1-35: Green Roofs in early 2006. This prescriptive
document is largely based on FLL Guidelines and draws on other FM Data Sheets to establish standards for
an FM Approved Green Roof Assembly.
FM 4477 Approval Standard for Vegetative Roof Systems, released in 2010, outlines FM approval
requirements for all vegetative roof systems that are installed over an FM Approved roof assembly (FM
4470). Vegetative roof systems are evaluated for performance related to fire from above and below the
structural deck, foot traffic, and water leakage.
In addition to standards that address green roofs specifically, like those described above, a number of
voluntary rating systems for green buildings and sites also acknowledge the environmental benefits of these
technologies.
As a component of larger integrated design strategies, green roofs and walls can contribute to earning
LEED credits, usually in conjunction with other sustainable building elements. In other words, LEED is a
measure of total building sustainability, and does not propose to measure the sustainability of individual
building components, such as roofs.
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For commercial buildings and neighborhoods to earn LEED certification, a project must satisfy all LEED
prerequisites and earn a minimum number of points on the LEED rating system scale as prescribed for
various project categories (USGBC, 2013). Green roofs can help achieve these points. By consequence, the
end goal of LEED certification is driving many building owners to incorporate green roofs into their designs.
The 2013 Rating System and Reference Guide, released in the fall of 2013, is the culmination of a two-year
pilot program and extensive collaboration. It replaces the pilot document Guidelines and Performance
Benchmarks 2009. The credit system aims to fill in the gap left by US Green Building Council (USGBC) and
other organizations, which are primarily focused on the building's envelope and may not adequately address
all land in a designated site or space. By providing a holistic guideline and rating system for sustainable sites,
the social and economic benefits to both the immediate site and the surrounding region may be more
adequately credited. Prerequisites and credits are organized into nine sections that follow the logical flow of
site development (much the way this first course in the GRP curriculum is organized) beginning with Site
Selection and ending with Monitoring and Innovation (Sustainable Sites Initiative, 2009). Green roofs may
contribute to SITES credits in the areas of onsite stormwater management; minimizing building cooling
requirements; providing views of vegetation and quiet outdoor spaces for mental restoration; reducing the
UHI effect; and preserving or restoring appropriate plant biomass on site.
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As a regulatory framework, the IgCC establishes minimum green requirements for new and existing
buildings. The code complements voluntary rating systems, which may extend beyond the baseline of the
IgCC. Jurisdictions may also choose to customize the IgCC to set higher minimum levels of performance.
The IgCC provides definitions for green roofs under three labels: vegetative roofs; extensive roof, and
intensive vegetative roofs.
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It is simultaneously a certification program, advocacy tool, and philosophy, taking an ambitious and holistic
approach to green infrastructure and human accountability to nature. The LBC provides a framework for
design, construction and the “symbiotic relationship between people and all aspects of the built
environment” (ILFI, 2012).
The LBC framework is comprised of seven performance areas (Site, Water, Energy, Health, Materials, Equity
and Beauty), which are subdivided into a total of twenty Imperatives, each of which focuses on one of the
performance areas or “spheres of influence” (ILFI, 2012). Examples of Imperatives include zero net energy,
net zero water, biophilia (see Section 4.0), and democracy and social justice. The Imperatives can then be
applied to nearly any project type, referred to as a Typology within the LBC framework, be it a new
construction or renovation, infrastructure, landscape or community development. The LBC also uses the
New Urbanism Transect model created by Duany Plater-Zyberk & Company to account for a development’s
rural to urban categorization, of interest to planners and developers.
Green roofs fall under the Building Typology whether for a new or existing project. Many, if not all, of the
imperatives for the Building Typology can provide guidance in the myriad decisions made in the design,
installation, and maintenance of green roofs and green walls.
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