Insulation

Angus Crane - Mon Sep 20 12:03:22 2004

VIA OVERNIGHT MAIL

September 20, 2004

Mr. Panama Bartholomy California Division of the State Architect Suite 5100 1102 Q Street Sacramento, CA 95814

Re: EPP Database for Fiber Glass, [Rock and Slag Wool], Cellulose, Cotton Insulation

Dear Mr. Bartholomy:

The North American Insulation Manufacturers Association (“NAIMA”) appreciates the opportunity to submit preliminary comments on the State Architect’s Environmental Preferable Products (“EPP”) Database Project. NAIMA is the association for North American manufacturers of fiber glass, rock wool, and slag wool insulation products. Its role is to promote energy efficiency and environmental preservation through the use of fiber glass, rock wool, and slag wool insulation, and to encourage the safe production and use of these materials.

NAIMA offers the following suggestions on how to define the scope of the above-referenced insulation section:

· The section should include rock and slag wool insulation. Rock and slag wool insulation is produced by a similar fiberizing process used for the creation of fiber glass. Rock and slag wool is a form of man-made vitreous fiber that was developed in the mid-1800s by melting slag or basalt and spinning it into the wool fibers that are used for insulation. In that rock and slag wool insulation is a fibrous insulation product, it belongs in this particular EPP category. Rock and slag wool insulation is used as residential, commercial and industrial insulation, offering batts, blankets, and loose fill (bonded and un-bonded); pipe and boiler insulation (high and low temperature applications); ceiling tiles and panels; fire proofing and fire safing (fire protection); sound reduction and acoustical attenuation in buildings, appliances, and machinery and air handling systems. Rock and slag material is also used as a horticultural growing medium. Rock and slag wool insulation products are available throughout the United States and specifically in California. These last attributes are also true for fiber glass insulation products. · NAIMA strongly urges the State Architect to combine all insulation products together for ease of comparison and tracking in one EPP database. Such an approach also encourages uniform format, but it allows consideration and comparison of unique product attributes. · The State Architect should acknowledge that all insulation products possess environmentally preferable attributes because it increases the energy efficiency of homes and buildings. · The U.S. Department of Energy ranks insulation as the number one way to conserve energy. · The State Architect should acknowledge that insulating is a cost-effective, energy-saving measure that has saved money for individuals and businesses through lower utility bills while increasing the comfort levels for all building occupants. Industrial processes have become more efficient through the insulating of pipes, cutting energy losses and decreasing production costs. By avoiding the added energy generation necessary to heat and cool buildings, insulation continues to be a benefit to the environment in the form of reduced pollution emissions. · NAIMA strongly urges the State Architect to encourage the maximum use of insulation products. NAIMA suggests that compliance with model energy codes and the International Energy Conservation Code (“IECC”) or similar energy codes should be encouraged. · The environmental benefits of building products are the function of many characteristics, including energy efficiency, raw material acquisition, product performance, longevity of product performance, recycled content, use and reuse, and many others. NAIMA recommends that the State Architect’s EPP Database represent this vast array of environmental attributes. The State Architect should avoid the common mistake of placing too much emphasis on recycled content. Certainly recycled content is the most immediately noticeable environmentally beneficial feature of a product, but basing preference solely on this one attribute can be misleading. Indeed, such a narrow assessment of environmental attributes has been discouraged by the U.S. Environmental Protection Agency (“EPA”). The EPA admonished those organizations selecting or endorsing products to be aware that environmental preferability is a function of numerous attributes, not just one or two. The EPA explained that a one-dimensional assessment of a product – for example, recycled content – blinds the evaluator to environmental impacts whose severity may outweigh the benefits exhibited in that one favored aspect. For example, transportation costs can outweigh other benefits if a product is not regionally available. Specifiers should be given the flexibility to choose products based on individual project needs. · A large proliferation of guidelines and standards on what constitutes green or environmentally preferable building products has filled the governmental landscape and commercial marketplace. Instead of providing clarity and greater understanding, these conflicting and competing guidance documents generate confusion. Even within the State of California the number of governmental and public interest groups promulgating such guidance documents rises steadily. The problem is that in this instance more does not mean better. Therefore, NAIMA encourages the State Architect to rely upon other programs that have already been established or gained the recognition and credibility of both the building and environmental community. Reliance upon the EPA’s Guidance on Acquisition of Environmentally Preferable Products and Services is one possibility. EPA’s Guidance documents recognize the multi-dimensional and dynamic nature of environmental preferability. EPA’s more balanced approach offers an objective and fair assessment on the full range of characteristics that constitute what is environmentally preferable about a product. · An essential attribute for any environmentally preferable product – especially insulation – is the ability of that particular product to perform its intended function. As the cost of energy increases, insulation offers a proven and relatively inexpensive means to conserve energy and decrease costs, which makes a substantial contribution to environmental protection. · NAIMA suggests that the State Architect maintain product neutrality. Allow the specifier to select the product based upon the information available through the State Architect and the manufacturers of the products rather than displaying a bias towards one product over another. · NAIMA suggests that compliance with the Federal Trade Commission’s (“FTC”) Guides for the Use of Environmental Marketing Claims serve as another environmentally preferable attribute. By making compliance with the FTC’s Guides an environmentally preferable attribute, it would act as further incentive for compliance with the Guides and also prevent companies who make inaccurate environmental claims from profiting from such parties. See 16 CFR Part 260. · Similarly, compliance with the FTC’s Home Insulation Rule should also constitute an attribute of environmental preferability. Claims of thermal performance should comply with the Home Insulation Rule. See 16 CFR Part 460. · Compliance with the Occupational Safety and Health Administration’s (“OSHA”) Hazard Communication Standard should constitute an attribute of environmentally preferable, too. · NAIMA cautions the State Architect to carefully weigh the credibility of claims that a product is non-toxic, non-hazardous, or without health risks. An inadequately tested or analyzed product should not be given the benefit of the doubt. In other words, the State Architect should avoid awarding preferential treatment to a product simply because a particular product has neglected responsible product stewardship and refused or failed to test its product. Indeed, the failure of a particular product to be adequately tested by its manufacturers should be a critical factor in determining that a product is not environmentally preferable. · The State Architect should stay within its statutory authority and not impose onerous and burdensome reporting requirements. · The State Architect should follow due process in formulating the EPP database.

NAIMA looks forward to the opportunity to comment on the specific suggestions proffered by the State Architect. Again, NAIMA greatly appreciates the opportunity to provide preliminary comments on the scope and direction of this particular section of the EPP Database.

Sincerely,

Angus E. Crane Vice President, General Counsel