NYC Carbon Emissions Penalty Taxes for not-for-profit health centers, hospitals and HIP centers - by George Crawford

New York City has just set limits on carbon emissions for all covered buildings (Int. No. 1253-C). If your building files Benchmarking Reports, your building is a covered building and is required to comply. It is a given that literally every single covered building will need to take some action as mandated by Int. No. 1253-C. These “actions” are designed to reduce carbon emissions, which is a function of the amount of energy consumed, including both electric and heating fuels.

The good news is that if a building can reduce their electric consumption levels, that building will probably meet the first round of the required lower levels of carbon emissions.

One of the required measures that must be taken is to upgrade lighting to LED.  If this required LED upgrade is initiated in a timely manner, then it is possible to determine if the resulting lower level of electric consumption is sufficient to lower the overall building carbon emission levels to meet the required limits. Note that an LED upgrade will lower electric consumption by 50%, on average. An LED upgrade also meets the requirements of Local Law 88.

If the LED upgrade does not lower carbon emissions sufficiently to meet mandated levels, then there would be adequate time to initiate additional energy conservation measures to avoid the Carbon Emissions Penalty Taxes.

Carbon emissions requirements for not-for-profit health centers, hospitals and HIP centers are more forgiving. These facilities are required to reduce their energy consumption by 15% as compared to their consumption in the year 2018. This reduction can be readily achieved by upgrading to LED as required by Int. No. 1253-C. Note there is a filing requirement due on or before July 21, 2021 to qualify for this favorable compliance opportunity.

Below is a “Cheat Sheet” of measures that must be implemented as mandated by the carbon emissions regulations:

• Adjusting temperature set points for heat and hot water to reflect appropriate space occupancy and facility requirements.

• Repairing all heating system leaks.

• Maintaining the heating system, including but not limited to ensuring that system component parts are clean and in good operating condition.

• Installing individual temperature controls or insulated radiator enclosures with temperature controls on all radiators.

• Insulating all pipes for heating and/or hot water.

• Insulating the steam system condensate tank or water tank.

• Installing indoor and outdoor heating system sensors and boiler controls to allow for proper set-points.

• Replacing or repairing all steam traps such that all are in working order.

• Installing or upgrading steam system master venting at the ends of mains, large horizontal pipes, and tops of risers, vertical pipes branching off a main.

• Upgrading lighting to comply with the standards for new systems set forth in section 805 of the New York City energy conservation code and/or applicable standards referenced in such energy code on or prior to December 31, 2024. This provision is subject to exception 1 in section 28-310.3, provided that July 1, 2010 is replaced by January 1, 2020 for the purposes of this section.

• Weatherizing and air sealing where appropriate, including windows and ductwork, with focus on whole-building insulation.

• Installing timers on exhaust fans.

• Installing radiant barriers behind all radiators.

George Crawford is the principal of Green Partners, New York, N.Y.