EPDM Roofs in Silver Spring, MD: What the Downtown Plan Says About Cool Roofs
Downtown Silver Spring has its own adopted plan, and it has a sentence about rooftops: new ones not covered by a green roof or energy generation "should be cool roofs or active rooftop uses." The design guidelines print it twice, as "new rooftops" and as "all roofs." EPDM is a sheet roof, and sheet roofs come in black and in white, so the wording matters to an owner of one.
The two wordings
One roof sentence, printed twice with different opening words
Plan, page 167, and Guidelines, page 39
- The words
- "New rooftops not covered in green roofs or alternative or renewable energy generation should be cool roofs or active rooftop uses."
- Sits under
- The bullet asking for 35 percent green cover on Optional Method Development projects.
Guidelines, page 57, item E, Roofs
- The words
- "As stated in the Sector Plan, all roofs that are not covered in green roofs or alternative or renewable energy generation should be designed as cool roofs or include active rooftop uses."
- Sits under
- Section 2.3.2, which opens "All new buildings in downtown Silver Spring should include some of these elements."
Both documents are guidance and use "should." The guidelines say they are for "development projects and public space improvements." Neither names a re-roof of an existing building. If a sheet roof on your building is being replaced, ask Montgomery Planning which wording applies, at 301-495-4610 (2425 Reedie Drive, 14th Floor, Wheaton).
How it got here
How the roof sentence reached its adopted wording
- Planning Board Draft, winter 2022
The Council's later edits show the draft's words by bracketed deletion: it said "Encourage" a minimum of 35 percent green cover, and "All new" rooftops should be cool roofs or active uses.
- May 26, 2022, County Council
Resolution 19-1297 approved the draft with revisions. "Encourage" became "Require," followed by "where practicable and consistent with Plan objectives," and "All new" became "New."
- June 2 and June 15, 2022
The Planning Board and then the park and planning commission adopted the plan with the Council's changes.
- February 2023, Design Guidelines
The guidelines repeat the sentence at page 39 with "New rooftops" and at page 57 with "all roofs."
The plan's reason: downtown Silver Spring has "a high impervious cover (77 percent) and low mature tree cover (8.6 percent)," and the 2020 street-surface reading it quotes, up to 155 degrees Fahrenheit, is a street figure, not a roof figure.
Who it reaches
Which owners does the roof sentence reach inside the plan boundary?
The plan area is about 505 acres, drawn around a ten-minute walk from the future Silver Spring Library Purple Line Station and running into Woodside, Woodside Park and East Silver Spring. A Silver Spring mailing address outside that line is outside the plan. Three illustrations follow, none of them a real job.
A new mixed-use building under Optional Method review
Situation
A developer uses the county's optional method for more density and goes through Design Review.
What the text says
35 percent green cover, or a roof that is green, generating energy, cool, or in active use.
Still open
Whether a given sheet counts as "cool." That is for the reviewers.
An apartment building with an aging sheet roof
Situation
A board weighs repair, a new coating or full replacement of a low-slope roof.
What the text says
The plan says to "consider a cool roof initiative" for existing owners, painting roofs "with reflective surfaces." It is a "consider" line, not a requirement.
Still open
The 2021 International Building Code lists a protective coating over existing single-ply among recover options, but not on a water-soaked or deteriorated roof. Ask the county about its amendments.
An older building being converted
Situation
A developer reuses an existing building and its flat roof.
What the text says
"Flexibility can be provided for unique circumstances for adaptive reuse of existing buildings."
Still open
Who decides the flexibility, and how much. The text does not say.
Where the text stops
No definition of cool, and a reflectance number for paving but none for roofs
"Cool roof" has no number in either document
The guidelines do give one for paving: light-colored paving with a 3-year aged solar reflectance of at least 0.28 or an initial 0.33 (section 2.1.5, page 32). The roof sentences carry no figure and no definition. EPA calls a high solar reflectance "the most important characteristic" of a cool roof, and the Cool Roof Rating Council says it "does not set a definition for 'cool'" and leaves that to code bodies and programs. The Single Ply Roofing Industry association says sheet membranes come in black, white and many other colors, so color alone does not say what you own or whether it counts.
Green roofs
Six inches, eight inches or more: how deep a green roof has to be
| Where | What it says about depth |
|---|---|
| Plan, page 167 | An "intensive green roof (six inches or deeper)" counts toward the 35 percent green cover. |
| Plan, stormwater recommendation | "Maximize green roof stormwater credit using an eight-inch soil medium or approved equivalent." |
| Guidelines, page 57 | Intensive systems "have a soil media greater than 8 inches"; semi-intensive 5-7 inches; extensive 2-4 inches. |
| Guidelines, page 57 | Intensive systems "require a stronger roof structure." |
So the depth that counts is not the same in every passage, and soil weight is a question for an engineer before anyone changes a membrane. Nothing in either document says which sheet roof sits under a green roof.
FAQ
Questions from owners inside the downtown Silver Spring plan area
Does downtown Silver Spring's plan require every roof to be a cool roof?
No. Both documents say "should," and the plan's sentence is about new rooftops. The only line about existing roofs is a "consider" recommendation.
Does the plan apply when only an existing sheet roof is replaced?
The text read does not say. The guidelines speak of development projects, and the plan's roof sentence sits under Optional Method projects. Ask Montgomery Planning before you assume either way.
Is my Silver Spring building inside the plan area?
Check the plan boundary map on Montgomery Planning's site. The area follows a ten-minute walk from the future Library Purple Line Station, so many Silver Spring addresses fall outside it.
Does "cool roof" in the plan mean a white roof?
The plan does not say. EPA names high solar reflectance as the key trait, and the Cool Roof Rating Council leaves the definition of "cool" to code bodies and programs.
What is an Optional Method project in downtown Silver Spring?
The plan says the CR, CRT and CRN zones allow higher density under the county's optional method but require public amenities in return, with Design Review through a Design Advisory Panel.
Why do the plan and the guidelines name different green roof depths?
The plan says "six inches or deeper" for an intensive roof and an eight-inch medium for the stormwater credit, while the guidelines say greater than 8 inches. Ask which figure a project must meet.
The Silver Spring page covers permits and Takoma Park. For the county energy-code layer, see EPDM roofs in Bethesda and EPDM roofs in Rockville. The regional explainer is flat roofs.
Talk through the next step
Talk through your roof with King's Roofing
Share the address, what you are seeing on the roof and the decision you need to make. We will tell you what to expect before anything is scheduled.
9220 Topaz St, Fairfax, VA 22031
Mon to Fri 7 AM to 8:30 PM, Sat 7 AM to 8 PM, closed Sunday