In recent years, applicants have been submitting more alternate roof materials for sites due to concerns over fire safety and fire insurance.   Applicants have proposed PVC for flat roofs, green roofs, metal roofs, and composition shingle roofs as alternate materials to the traditional wood shake roof.  Staff is presenting discussion topics for the Planning Commission based on feedback and discussions at the January 15, 2025, February 11, 2025, and March 12, 2025, Planning Commission meetings.  The goal is for the Planning Commission to review the policy and  make a recommendation of adoption by the City Council.     

A resolution (Attachment 1):

a)      Finding that, pursuant to section 15378 of the CEQA Guidelines, the roofing discussion and recommendation of adoption of the roofing policy does not meet the definitions of a project outlined in CEQA Guidelines Section 15378 (a) (1)-(3); and

b)      Recommending adoption of the roofing policy by the City Council.

In recent years, more applicants have been proposing alternate roofing materials that deviate from the Carmel-by-the-Sea Design Guidelines (Residential Design Guideline 9.8 states that metal, plastic, and glass roofs are inappropriate in all neighborhoods).  One of the main stated reasons is concerns over fire safety and risk of losing home insurance coverage.  Applicants have proposed PVC roofing for flat roofs, green roofs, metal roofs, synthetic faux wood and slate, and comp shingle roofs as alternate materials to the traditional wood shake roof.  When a deviation from the Design Guidelines is proposed, the Carmel Municipal Code (CMC) section 17.58.060.D states that “the Director, Historic Preservation Board, or the Planning Commission shall adopt specific findings based on information in the record to show how the deviation from the design guidelines achieves all of the applicable design objectives of CMC 17.58.010 Purpose and Applicability”.  The Planning Commission has approved metal roofs for projects based on their fit with the architecture of the structure and the neighborhood character, and finding that the deviation complied with CMC Section 17.58.060.D.  Similarly, the Planning Commission has approved composite shingle roofs for projects. 

ROOFING SUBCOMMITTEE:

In 2016, the Roofing Subcommittee reviewed alternate roofing materials and provided recommendations on an alternate roofing materials policy.  The main charges of the Roofing Subcommittee were: 1) to consider expanding the City’s list of acceptable roofing materials, 2) to potentially develop new criteria for acceptable alternate roofing materials, and 3) to make a recommendation on changes to the processing of re-roof applications to the full Planning Commission. The subcommittee recommended administrative approval of certain alternate roof materials that “mimic the texture, thickness, and color of natural roofing materials.”  The list that was recommended included synthetic products (CeDUR shakes, DaVinci Shake or Slate, EcoStar Shake Slate, and Metal Tiles) and generic products, in addition to natural material products (clay tiles, ceramic tiles, and light-weight concrete tiles).  In addition to these lists, it was noted that all approvable materials would be limited to earth toned colors.  The discussion on roofing occurred at the February 2016 Planning Commission meeting and the policy was adopted at the March 2016 Planning Commission meeting.  The list of administratively approvable products has remained the same with the addition of low SRI metal standing seam metal roofs.

RESIDENT FEEDBACK:

Some residents have expressed concerns about metal roofs and high contrast composite shingle roofs.  These residents have stated that the metal roofs are inappropriate for all neighborhoods and believe that they are eroding the village character of Carmel-by-the-Sea.  These residents have also expressed their distaste with the abundance of high contrast color schemes (black composite shingle roofs and white siding).  The Planning Commission has previously set precedents for the staff to approve earth tone metal roofs and composite shingle roofs.  Some residents have continued to voice their concerns over earth tone metal roofs, leading staff to refer all metal roofs to the Planning Commission once again.

At the January 15, 2025, Planning Commission meeting, many residents expressed their support for metal roofing throughout town.  There was discussion of the recent fires down in Los Angeles and the merits of metal as noncombustible, as opposed to fire resistant, roofing material.  There were also residents that expressed their continued concern about the seeming abundance of proposed metal roofing for recent projects.  They stated that the metal roofs contradict the design guidelines and erode the character of the village and are inappropriate in all neighborhoods (per the Carmel Design Guidelines).

ROOFING MATERIALS DISCUSSION

For this discussion, Staff has provided topics for the Planning Commission and residents to provide insight and direction.  Staff also compiled a list of items the Commission requested at the January 15, 2025, Planning Commission meeting for review.  This agenda item is for discussion only and no action is being taken.  The intent is for Staff to present a draft policy to the Planning Commission, received feedback on the policy, and return at a future date with a final draft of the policy.  An example of directions from the Planning Commission would be to refer all alternate roof material projects to the Commission for review or to create criteria for when staff can approve/deny the applications administratively.    

Direction from Previous Planning Commission Meeting:

1.      Bring feedback from insurance companies on preferred roofing materials.

2.      Have representation from the Fire Department to Speak at the next Planning Commission meeting.

3.      Provide roofing material samples.

4.      Provide a list of architectural styles where a metal roof is appropriate.

5.      Provide draft standards/guidelines for roofing policy in line with the Design Traditions Committee.

Insurance Companies:

Staff spoke with Mathew Little from Carmel Insurance regarding fire insurance and roofing materials.  He stated that roughly 80% of insurance agencies would not provide fire insurance for homes with wood roofing.  The other 20% would provide insurance if the wood shake is fire treated regularly, and that there is no guarantee of continued coverage long term.  There are concerns about the length of time that fire treatment will last on wood roofs and how often it will need to be treated.  Additionally, Little speculated that wood roofs might be more insurable outside of forests.  He stated that roofs with class A assembly utilizing metal, composite shingle, terra cotta clay tiles, slate, and membrane roofing are all insurable for approximately 20-25 years before a new roof would be required.  He stated that there was the possibility of insuring roofs for a longer period if a contractor prepared a report stating that the roof is in good condition.  He did not indicate any preference from insurance companies on non-wood roofing material. 

Based on the conversation with Carmel Insurance, staff has determined that all class A assembly non-wood roofs would be able to obtain fire insurance, as well as some wood roofs. However, there is no indication that there are any alternate materials that are more insurable than any others. 

Fire Representation:   

Staff reached out to Monterey Fire to request their attendance during the March Planning Commission meeting to discuss alternate roofing materials.  Interim Deputy Fire Marshal David Brown and Fire Chief Justin Cooper with Monterey Fire attended and answered questions relative to how Fire Departments view alternate roofing materials.  They also answered any questions regarding general procedures for responding to fires.  They provide information on the State Fire Marshal’s approved roofing materials list as well as materials that are not listed but are viable in the Very High Fire Severity Zone. 

Roofing Material Samples:

Staff provided roof samples for the Commission to look at in person.  Staff provided samples of composite shingles, metal, faux slate and wood, and PVC with gravel ballast.  Samples will be available in chambers for review during the meeting for the June 11, 2025, Planning Commission meeting.  As requested by Commissioner Allen, staff is obtaining a Zinc roofing sample that should be available for the meeting. 

Architectural Styles for Metal Roofs:

The Planning Commission asked for a list of architectural styles where metal roofs would be appropriate.  Staff determined that metal roofs are most appropriate on modern architecture and industrial architecture.  However, Council Member Bob Delves mentioned that on a trip to Australia he noted that many of the home of all different style had metal roofs due to fire concerns.  He stated that the metal roofs were tailored to the architectural style of the building and therefore fit with any style fairly well.  In Carmel-by-the-Sea, the typical architectural styles that have been approved for metal roofs are modern architecture (i.e. Bay Area Regional Modern, Ranch, and Post-War). 

Two metal roofs were recently appealed to the City Council.  The City Council did not support limiting metal roofing based on the amount of other metal roofs in the immediate vicinity.  They also expressed concerns about discretionary decisions supported by a finding that metal roofs fit the architectural style of building.

Draft Design Standard/Guidelines for Roofing Policy:

Staff has used the alternate roofing materials policy adopted by the Planning Commission on March 2016, as a starting point for a draft roofing policy.  Standing seam metal roofing and more notes on earth tones have been added.  Staff removed any mention of SRI from the roofing policy.  Discussion with the Design Traditions Steering Committee and the City Council have been around the fact that SRI is not a good metric for reviewing the glare of a roof, but instead relates to insulation.  All allowable metal roofing will be a non-glossy/matte finish.  The Design Traditions Steering Committee recommended that all alternate materials that are proposed should be designed to look like the material they are and not mimic other natural materials.  This was taken into account when creating the draft roofing materials policy.  However, there are some faux wood, terra cotta, and slate roofing materials that are on the list because their weight, look, and cost make them a good alternative to their natural counterparts.  If the Planning Commission deems the faux materials as inappropriate, they can be removed.

*Acceptable Synthetic Alternatives

CeDUR shakes

DaVinci shake or slates

EcoStar shake or slates

**Earth tones shown in figure 1 below

Figure 1

Staff recommends, pursuant to CEQA regulations, that the Application be found “not a project” pursuant to section 15378 of the CEQA Guidelines.  The roofing discussion and draft policy does not meet the definitions of a project outlined in CEQA Guidelines Section 15378 (a) (1)-(3).