On Earth Day, NYC’s mayor’s office and city council unveiled NYC’s Green New Deal referred to as “The Climate Mobilization Act,” a package of bills to reduce NYC’s carbon emissions 40% by 2030 and 80% by 2050 (aka 80x50).
The cornerstone of the package is Intro-1253, requiring existing buildings over 25,000 s/f to meet or exceed greenhouse gas emission targets determined by NYC DOB occupancy groups. The bill’s intent has been a popular topic in the building industry since a similar bill, Intro-1745, was originally introduced in Oct. 2017 and focused only on limiting fossil fuel consumption for various building types. City council received comments and recommendations over the following year related to the bill. This feedback included a report called “Blueprint for Efficiency” from the 80x50 Building Partnership—a collection of over 40 leading building and energy stakeholders (including ASHRAE NY, AIA NY, and ACEC) led by Urban Green Council—to help expedite feedback from the industry in a framework aligned with the interests of the bill. In Nov. 2018 a new bill was introduced, Intro-1253, similar in intent but also including emission limits associated with all energy fuel sources. Over the past six months, Intro-1253 slowly became the center of conversation for anyone involved in real estate. It has gone through three revisions since its initial introduction. The most notable changes related to compliance for building owners are:
• Refining role and responsibilities of the newly assigned Office of Building Energy and Emissions Performance, and requiring the appointed director be a registered design professional.
• Refining building emission intensity limits (tCO2e/s/f) per NYC DOB occupancy group rather than bundling groups together to be more representative of how buildings actually use energy.
• Excluding “rent regulated accommodations” from established building emission limits similar to building occupancy group R-2, but requiring an advisory board to provide recommendations as part of their key goals.
• Postponing the first compliance period—originally starting in 2022, now 2024—with emission intensity limits resetting accordingly, permitting building owners more time to strategize retrofit capital planning.
• Prescribing greenhouse gas coefficients of energy consumption per fuel type for calendar years 2024-2029, and acknowledging greenhouse gas coefficients should be re-evaluated and Refined by 2023 for future compliance years, thus helping improve accuracy of electric grid’s contribution in the future when additional renewables are part of electric production.
• Establishing building emission intensity limits for compliance years 2030-2034, initially ending in 2049.
• Refining permitted deductions for compliance years 2024-2029, most notably allowing from 10% originally up to 100% for accepted renewable energy credits as long as they are associated directly deliverable into NYISO’s Zone J load zone.
• Permitting deductions for compliance years 2024-2029 associated with clean distributed energy resources (DERs), allowing electric demand reductions to be part of the plan, as they still play a vital role in carbon reduction given the current electric grid system.
• Allowing adjustments to building emission intensity limit for not-for-profit hospitals and healthcare facilities, reducing the limit by up to 15% for compliance years 2024-2029 and 30% for compliance years 2030-2034.
As engineers who identify, design, and commission primary energy consuming systems within buildings, these new regulations are game-changing in how we go about our business. Gone are the old metrics of comparing operational energy cost to capital costs for energy upgrades or new design alternates. Our approach to the carbon focus includes the following:
• Focus on controls and operational upgrades in existing buildings. Identify how to improve efficiency without major infrastructure changes to limit carbon in the near term, before capital projects are planned.
• Incorporate carbon and energy savings as part of any major capital project.
• Focus on the ability to electrify all buildings. Electricity, now and particularly in the future, is expected to be the cleanest carbon source of energy. This will drive the push for electric heat and hot water systems, previously considered cost inefficient compared to high performance gas boilers. Continue to explore evolving technologies and products, including large-scale electric air source heat pumps, VRF systems, and solar heating. These technologies, not previously common at the scale that will be needed in the future, may well be part of our industry’s carbon-efficient future.
The conversation related to building systems selection will increasingly shift focus towards their resulting carbon emissions for any design alternate considered, and require a more integrated discussion with architects for new buildings, and with operators for existing renovations.
Jeff Rios, PE, is a partner, and Charlie Marino, CEA, is a mechanical engineer at AKF, New York, N.Y.
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