Category Archives: Energy Management

NYC’s New LL 97 Climate Change Rule – Part 3 – Compliance

In the last two months, I have written articles containing basic summaries about New York City’s new Local Law 97, a rule to address Climate Change targeted to existing buildings in NYC with specific greenhouse gas (GHG) emission limits, which is defined by the building’s (and the tenant’s) energy usage. The rule defines 10 different types of buildings (permanent – housing – and temporary – hotels – housing, office, retail, industrial, entertainment, etc.) each with its own GHG emission intensity limit (grams of CO2e per square foot). What is unique about this rule is that the fines for not submitting an annual compliance report and for exceeding one’s limit are very high. Potentially high 6 to low 7 figure annual fines!

The rule goes into effect in 2024; the first annual report is due by May 1, 2025. Fines to follow. That seems like a long way away. But if your building needs to make major changes to meet your limit or to lessen the exceedance and fine, then you may need all of these 4½ years to plan, design, and implement the needed changes. So the first – and perhaps the most important – piece of advice is to start NOW to see where your building stands in 2024 when it comes to LL 97. You may be surprised. In unveiling the rule, NYC emphasized they believed that 80% of existing buildings would comply with their limit based on 2016 benchmarking energy submittals. “Only” 20% of existing buildings would need to upgrade. But that is a little deceptive. Energy usage has been growing tremendously recently as businesses grow and demand for technologies – in most cases – that are energy-intensive to serve customers grows, too. Many of those buildings complying with LL 97 based on 2016 energy usage may get complacent and then learn that energy usage has risen in the intervening years due to many factors, including business growth. One must self-assess and be prepared and vigilant NOW!

LL 97 covers not only landlord-responsible functions (common lighting, elevators, space heating, etc.) but also tenant-responsible energy usage (their lighting, plug load, window AC units, etc.). If you are a landlord, this is the time to reach out to your tenants and get an understanding of total energy usage. NYSERDA’s Commercial Tenant Program is an incentive program providing free energy audits for leased office spaces. 4½ years may be necessary to understand your tenants’ energy needs and work together to manage it better. There has been concern that landlords, concerned with LL 97 compliance, may not renew leases of certain tenants that are high energy users (data centers, 24/7 operations) and encourage new tenants which use less energy to move in.

Once you have assessed your total energy usage and understand who is responsible for what usage and for what functions, you can assess whether you are currently in compliance with LL 97 and project the status in 2024. If your building is likely to exceed their greenhouse gas emission limit in 2024, the energy assessment provides the data to intelligently determine strategies to either comply or minimize the exceedance or fine.

The energy assessment can accurately tell you by how much you exceed the standard and can determine exact energy (and greenhouse gas) reductions to get you down to your limit. Then you can determine which combination of potential energy upgrades is sufficient to meet your LL 97 requirements, taking into consideration cost and side benefits, as well. You have time to plan it out and bring in the right experts to do the job.

Besides reducing your actual credited greenhouse gas emissions by reducing energy usage, LL 97 gives you two other ways to reduce your credited annual greenhouse gas emissions: purchasing renewable energy credits (RECs) and/or emission offsets. RECs are credits one obtains for implementing renewable energy, such as solar or wind project. A deduction from one’s annual building emissions equal to the number of RECs purchased by a building owner as long as the source of the renewable energy credits is considered by NYISO to be a capacity resource located in or directly deliverable into zone J load zone (NYC) for the same reporting calendar year; RECs are solely owned and will not be reused (re-sold) by the building owner, the building that hosts the renewable energy system does not receive a deduction under § 28-320.6.3. Information proving these items must be submitted to the Dept of Buildings with the application.

Emission offsets is procuring greenhouse gas emission credits that are certified by an appropriate board. Such offsets are provided to those who have reduced GHG emissions for an amount beyond that required by regulation. For calendar years 2024-2029, deductions for certified GHG emission offsets will be allowed for up to 10% of the annual building’s emissions limit. The deduction is only allowed for credits generated within the reporting calendar year, publicly registered, and retired (not to be re-sold).

LL 97 also allows a deduction from the reported annual building GHG emissions based on the calculated output of a clean distributed energy resource located at, on, in, or directly connected to the building subject to the report. LL 97 is allowing this portion to be amended based on future research and development.

Again, to summarize, 2024 seems like it’s far away, but given how comprehensive and how onerous LL 97 will be, with huge fines for non-compliance, the time to start evaluating where you stand vis-à-vis this rule is NOW!

CCES has the experts and knowledge of LL 97 to perform that early assessment of whether your building meets your 2024 GHG emission limit or not. If you comply now, we can advise you how to prevent energy creep to better ensure compliance in 2024. If you do not currently comply, we can advise you on cost-effective steps to comply on time and we can manage implementation to ensure you get the reductions in emissions you need. This is an onerous rule and with potential major upgrades needed to avoid high fines, 2024 is not that far away! Contact us today at 914-584-6720 or at karell@ CCESworld.com.

Government and Investor “Carrots and Sticks” for Climate Efforts

Governments, investors, and watchdog NGOs are stepping up their efforts to identify companies that are leaders or laggards in the global effort to address climate issues. While most of the effort has been to highlight and publicize those that have reduced or supported reductions in greenhouse gas emissions significantly, there is a growing sense that shame can work, too. Legal & General Investment Management (LGIM), an investment firm that invests in companies that actively address climate matters, puts out annual rankings. In their 2019 list, they voted to divest five firms from their Future World Fund due to unsatisfactory results, including ExxonMobil. Removal may occur for a variety of reasons, such as not meeting climate goals, governance, and lobbying efforts.

Such removals and additions to the list are important as investors use the list as a guide to making investment decisions. Two companies removed from the Future World Fund in 2018 were reinstated in 2019.

In April 2019, for the first time ever, renewables surpassed coal in the US power mix. A combination of the large growth in new wind and solar farms boosting renewable energy output and some coal plants were idled for routine spring maintenance caused this to occur. Hydroelectric dams, solar farms, and wind turbines generated about 68 million megawatt-hours of power that month, exceeding the 60 million that coal produced that month, according to the Energy Information Administration. This is both the most clean power ever produced in the US and the least amount of coal combusted in years.

These trends highlight the growing support for renewable power in the form of incentives and tax rebates by governments and the large number of utilities now encouraging this, too, to lessen their burden. In addition, the cost of building new renewable solar and wind farms has dropped markedly compared to the cost of building new coal-fired plants. And finally, with some exceptions cheap and plentiful natural gas are causing many plants to shift from coal to gas. If these trends continue, Despite the current US Administration supporting the coal industry by gutting environmental rules, other governments and investors are moving away from coal to renewables. It should be noted that April is commonly a month when many coal-fired power plants are shut down for maintenance. This summer, coal combustion at peaker plants should raise the level of coal combustion in the US, putting coal back “ahead” of renewables in terms of electric generation. But the longer-term trends are certainly that government incentives and investor information are causing the long-term growth of renewable power.

CCES has the experts to help your company understand how climate and energy conservation programs can result in many significant financial benefits. We can help you diversify your energy supply, find incentives with direct benefits for you, and find ways to reduce costs. Contact us today at karell@CCESworld.com or at 914-584-6720.

Trump Administration Repeals, Replaces Obama-Era Clean Power Plan

Please note that this is a technical evaluation of current federal regulations. On June 19, 2019, the US EPA issued the final Affordable Clean Energy (ACE) rule replacing and repealing the Obama administration’s Clean Power Plan (CPP). ACE establishes emission guidelines for states to use when developing plans to limit carbon dioxide (CO2) at their coal-fired electric generating units (EGUs). ACE will allow states to set emissions standards for coal-fired plants. CPP, in effect since 2015, developed national standards to address CO2 emissions from power plants, allowing for a transition to cleaner sources of energy by 2030. The US EPA then projected that CPP would result in $26 billion to $45 billion net climate and health benefits, including the avoidance of 300,000 missed work-days and school-days, 90,000 asthma attacks, 1,700 heart attacks, and 3,600 premature deaths annually.

Instead, the new rule, ACE, will relieve the power industry of meeting these emission standards. This will, in particular, benefit the coal industry. ACE will likely face court challenges from several states, as well as environmental groups who see the repeal of CPP and adoption of ACE as steps backward from fighting to reduce greenhouse gas emissions, an accepted Clean Air Act pollutant. Shortly after adoption of the new rule, several state attorneys general signaled their intent to sue the US EPA over ACE.

ACE establishes that efficiency improvement of an electric generating unit is an acceptable approach for emissions reduction of CO2, giving coal-fired plants more options to reduce carbon intensity. The US EPA would consider technical feasibility, cost, non-air quality health and environmental impacts, and energy requirements in determining the most appropriate ways to reduce CO2 emissions. States will establish unit-specific “standards of performance” that reflect the emission limitation achievable through application of improving efficiency. ACE believes that the US EPA’s role is to be a technical advisor of potential strategies to minimize greenhouse gas emissions. The states’ role is to develop plans that establish unit-specific standards of performance that reflect application of best efforts to control emissions, taking into consideration, among other matters, the remaining life of the electric-generating unit. States must submit plans to the US EPA that establish their standards of performance and include measures that provide for the implementation and enforcement of such standards, due in three years. Therefore, states do not have to have any standards currently (CPP has been repealed) and by the time a plan is approved, it can be much longer.

CCES has the experts to provide technical advice on federal, state and local energy and environmental regulations so that you better understand how they impact you. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Rooftop Gardens As A Sustainability Strategy

Some entities understand the financial benefits and would like to be more sustainable, but are under some pressure to have a “showcase” project that is more interesting and picturesque than energy efficiency or upgrading sophisticated equipment. If you are in that situation, consider rooftop gardens as an effective way to be more sustainable, gain benefits, and have a great “photo op.” Particularly in urban areas, rooftop gardens bring some greenery and an area for relaxation into a “concrete” space.
Rooftop gardens are essentially backyards atop one’s building, bringing “nature” into an otherwise sterile space. Rooftop gardens can be either vertical or horizontal and is an effective way to reduce the heat load on your AC system, saving on energy bills.

Rooftops are, by nature, urban heat islands, absorbing the sun’s radiation and giving off energy slowly, resulting in massive pockets of hot air. In an urban environment of many dark-colored roof tiles and concrete streets, cities are particularly prone to higher than normal summer temperatures because of heat islands, which contributes to worse air quality and mental and physical health concerns. In addition, energy being kept in and close to buildings raises the demand for air conditioning and other cooling equipment, making it work harder and for longer causing a significant rise in energy usage and putting a strain on the local energy grid, which some utilities have trouble maintaining. In addition, the building owner pays for the urban island effect big time as more utilities put a premium charge on high peak demand during the cooling season (summer). Even if a building has one 15-minute period in a month of very high cooling demand, it will be charged a very high amount for this single short-term spike in demand. In addition, heat islands damage roofing material, requiring the building owner to upgrade it more often than if a rooftop garden is installed and maintained to protect the building’s materials.

Rooftop gardens can mitigate this effect because the plants absorb the sun’s radiation, not the roof shingles or underneath part and the shade offered by plants reduces heat transport, resulting in cooler temperatures and improved air quality.

A recent study found that an exposed roof can get as hot as 158⁰F on a sunny day while an identical roof with a rooftop garden covering most of the roof stayed relatively stable at a temperature of 77⁰F (https://www.thespruce.com/green-benefits-of-a-roof-garden-1708536). In addition to providing natural cooling, rooftop gardens can provide a natural sound barrier, delay stormwater runoff, and provide filtered rainwater.

It is critical that the building owner bring in an experienced qualified roof garden designer and installer, who can check about any local permits and regulations that must be adhered to in your jurisdiction. Be sure that the designer assesses your building to determine whether it can hold a rooftop garden, that it can be waterproofed, or whether normal temperature extremes in your area may damage a roof garden or roof. It is crucial to choose the right types of plants depending on your local climate, such as winds and temperature extremes. If this is an office building with periods of inactivity, it may make sense to include low-maintenance plants, needing little water or pruning.

The cost of a rooftop garden will depend on many factors, such as size, plants selected, and construction materials used. A rule of thumb range of initial cost is $15-$40 per square foot of space. However, you should quickly begin to save money on energy bills and a payback in a reasonable time is likely, plus it should advance the building’s asset value and attractiveness for other potential tenants.

CCES does not perform rooftop garden design or landscaping. But we can manage professionals in these fields to do the proper work to install one to maximize your benefits. In addition, we can perform a sustainability assessment of your buildings, company, or assets to determine which strategies are most effective to become more sustainable and to optimize the financial benefits. Contact us today at 914-584-6720 or karell@CCESworld.com.

NYC’s New LL 97 Climate Change Rule – Part 2

Last month, I wrote an article with a basic summary about New York City’s new Local Law 97, a rule specifically tailored to Climate Change and reaching NYC’s 40% reduction in greenhouse gas (GHG) emissions by 2030 and 80% reduction by 2050 goals by regulating existing building operations, the City’s largest source of GHG emissions. The rule goes into effect in 2024. The penalties for non-compliance (exceeding a limit) are great, likely annual 6-figure or greater fines. This article provides more details on the application of the new GHG emission limits affecting buildings.

LL 97 covers all buildings in NYC with a gross size of 25,000 sf or greater. There are several exceptions, such as power or steam plants, City-owned buildings, certain rent-regulated buildings, religious institutions, and certain low-income housing projects.

The crux of LL 97 is calculating annual GHG emissions and comparing it to allowable emission intensity in metric tons of CO2 equivalent per sf multiplied by square footage.

Different building types are regulated per Dept of Buildings listed classifications. Please note that this does not provide the full definition of a group or list all exceptions. Note the GHG emission intensity limits provided are for 2024 to 2029, more stringent in 2030.

Group A-1 – A-5. Assembly: the use of a building, excluding a dwelling, for gathering for purposes such as civic, social or religious functions, recreation, food or drink consumption, awaiting transportation, or similar group activities; or when occupied by 75 persons or more for educational or instructional purposes. Examples: theaters, banquet halls, museums, lecture halls, houses of worship, tennis courts, stadiums, etc. Building GHG emission intensity limit: 0.01074 tCO2e/sf.

Group B. Business: the use of a building for office, professional, service-type transactions, or for conducting public or civic services, including the storage of records and accounts and limited quantities of goods for office purposes. Examples: health care facilities, banks, laboratories, libraries, offices, professional services, colleges, etc. Building GHG emission intensity limit: 0.00846 tCO2e/sf.

Group E. Educational: the use of a building by 5 or more persons at any one time for educational purposes offered to children through the 12th grade. Examples: academies, day care facilities where no more than two children are under the age of 2, schools, and school libraries. Building GHG emission intensity limit: 0.00758 tCO2e/sf.

Group I-1. Personal care: the use of a building housing persons, on a 24-hour basis, who because of age, mental disability or other reasons, live in a supervised space providing personal care. Examples: adult day care, assisted living facilities, halfway homes, convalescent facilities. Building GHG emission intensity limit: 0.01138 tCO2e/sf.

Group F. Industrial: the use of a building for assembling, disassembling, fabricating, finishing, manufacturing, packaging, repairing, cleaning, or processing operations not classified as Group H hazardous. Examples: industrial, auto repair shops, printing presses, food processing, etc. Building GHG emission intensity limit: 0.00574 tCO2e/sf.

Groups H (High Hazard), I-2, I-3 (Institutional): the use of a building for child or adult care and treatment of those that are ill. Examples: industrial facilities using compounds considered hazardous, child care facilities, adult homes, hospitals, nursing homes, mental health facilities, etc. Building GHG emission intensity limit: 0.02381 tCO2e/sf.

Group M (Mercantile): the use of a building for the display and sale of merchandise, and involves stocks of goods, wares or merchandise incidental to such purposes and accessible to the public. Examples: department stores, retail and wholesale stores, drug stores, sales rooms, etc. Building GHG emission intensity limit: 0.01181 tCO2e/sf.

Group R-1 (Residential, temporary): the use of a building for dwelling or sleeping purposes when not classified as Institutional. Examples: hotels, motels, rooming houses, club houses. Building GHG emission intensity limit: 0.00987 tCO2e/sf.

Group R-2 (Residential, permanent): the use of a building containing sleeping units or more than two dwelling units that are occupied for permanent resident purposes. Example: apartment buildings. Building GHG emission intensity limit: 0.00675 tCO2e/sf.

Groups S (Storage) and U (Utility and Miscellaneous): the use of a building for storage or any other purpose not listed previously. Examples: warehouses, distribution centers (if it does not contain hazardous material), private garages, sheds, greenhouses. Building GHG emission intensity limit: 0.00426 tCO2e/sf.

Each subject building must calculate its GHG emissions for beginning in 2024. Conversion factors:

Electricity from the electric grid: 0.000288962 tCO2e/kilowatt-hour

Natural gas combusted on premises: 0.00005311 tCO2e/kbtu. (0.005311 tCO2e/therm)

#2 fuel oil combusted on premises: 0.00007421 tCO2e/kbtu (0.01039 tCO2e/gal. #2 oil)

#4 fuel oil combusted on premises: 0.00007529 tCO2e/kbtu (0.01090 tCO2e/gal. #4 oil)

District steam used on premises: 0.00004493 tCO2e/kbtu (0.0000466 tCO2e/lb steam)

Future updates will discuss other ways to calculate GHG emissions and the availability of GHG credits to compensate for emissions.

CCES has the experts and knowledge of LL 97 to perform an early assessment of whether your building meets your 2024 GHG emission limit or not. If you comply now, we can advise you how to ensure compliance into 2024. If you do not currently comply, we can advise you on cost-effective steps to comply on time and we can manage implementation to ensure you get the reductions in emissions you need. This is an onerous rule and with potential major upgrades needed to avoid high fines, 2024 is not that far away! Contact us today at 914-584-6720 or at karell@ CCESworld.com.

Blockchain Applied To Energy Management

Blockchain is the future of information technology and is beginning to be applied to how energy is created and transmitted in the US.

First, a quick review. Blockchain is the direction of information technology is moving toward: how we gather and store data. A blockchain is a collection of records aggregated into “blocks” that are linked to one another in a “chain”. It typically contains a history of a certain process, such as amount of energy generated, what type, when, and under what circumstances, and can also be used to set future actions, such as energy generation, based on history or other circumstances programmed. Blockchain data is usually available in some form in hundreds of distinct copies. While there are privacy guards in case someone attempts to alter the blockchain, a hacker will likely be able to alter only a minority of the copies. Full data from a blockchain is available to those that are permitted to access it, is accurate based on what was entered, and can provide privacy (which person is responsible for what), if need be.

Initiatives spearheaded by energy industry groups and stakeholders are working to create standardization in energy data sharing and blockchains. The North American Energy Standards Board (NAESB) is in the process of developing a standard digital representation of natural gas trading using blockchain. The results and mechanism for developing useful standards may well be replicated in other parts of the energy industry, such as managing electricity generation and renewable energy certificates (RECs). NAESB is industry-driven and organized by areas of interest, such as wholesale gas, wholesale electric, and retail markets to develop the standards for each energy group.

NAESB has developed a joint committee to develop a standard digital representation of natural gas trade events (futures or actual) in order to standardize and communicate smart contracts and trade disputes. A base contract for the sale or purchase of natural gas is being developed for the industry that can be used in a blockchain to keep appropriate and useful records. The actual base contracts are still being developed.

Given that renewable energy generation differs from that of fossil fuel-derived because the nature of renewable energy generation, the sun or wind, is free and, theoretically available to all, the future renewable energy blockchain application will likely focus less on development and futures, but instead on post-generation services, such as storage, distribution, and RECs, from generation to sales and retirement. This should come in handy as tracking RECs currently is a difficult process as records of transactions associated with RECs sales are difficult, given the different organizations and rules concerning RECs. Developing standards with blockchain to track RECs through their lifecycle could encourage renewable energy growth and investment.

CCES can partner with experts on blockchain technology to improve your data management. In addition, we can help you understand and manage your energy demand and usage, which is the first step to being more cost-effective and minimizing risk. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Providing More Information on Energy Applied To Home Sales

Benchmarking is now the rage. More and more local governments are requiring building owners to compile and submit their energy usage data so that prospective buyers and renters have additional information to make their decision whether to bid, how much to bid, and to prepare for their time in the space. But these rules generally apply to large and/or commercial buildings and spaces. Since we spend most of our time in and our money on our homes, why can’t home buyers get access to a prospective home’s utility bills before you bid on it? The city of Portland, Oregon, has a program to give home shoppers such information, enabling the public to consider – if they wish – energy efficiency when buying a home. See https://www.pdxhes.com/ Other cities are looking at similar programs. After all, the energy efficiency of cars is public knowledge and used by many to decide on which brand to buy, why not the bigger investment of a home?

Portland is the first US city to require home sellers to determine and disclose a Home Energy Score through the Better Buildings Program of the US Dept of Energy, which gives a score from 1 to 10 and compares the energy performance of a given home compared to others in the US. Home owners must hire a certified assessor to perform an energy audit to determine the score.

In 2018, about 10,000 homes were assessed in Portland, achieving an average score of 4.6, slightly below average (5.0). This low score occurred presumably because many homes for sale were older, built before building codes set efficiency requirements, greatly reducing the mean. Of course, this brings up to the owners an opportunity to install insulation, replace windows, and/or upgrade HVAC to raise its energy score and, thus, improve the home’s marketability.

Austin, Texas, requires homes that are 10 years or older to have a professional energy audit performed and disclose its results when listing the property. Berkeley, California requires home sellers to develop a home energy score and disclose it to the buyer at or shortly after the sale. Montgomery County, Maryland, and Chicago require disclosure of utility bills to potential home buyers; Chicago also encourages (but does not require) including this information in listings.

Many believe that this can be successful in encouraging energy efficiency, as evidenced by automobile purchase trends. US car buyers now rate energy efficiency as important as price. Home energy ratings, already more common in Europe, has led to the correlation of higher home energy ratings resulting in higher sales prices.

CCES has the experts to help you determine how energy efficient your building is, whether it be your home, a commercial, or an industrial building. We can determine cost-effective ways to raise your score or efficiency, which will save you cost and raise your building’s asset value. Contact us today at 914-584-6720 or karell@CCESworld.com.

Batteries and Energy Efficiency Programs

A few months ago, I posted a blog article on new trends with battery power, including a description of Massachusetts’ latest energy efficiency plan – the first in the nation – which encourages energy efficiency funds to be used for energy storage projects that reduce peak demand, and otherwise encourage the implementation of batteries to store power at a facility.

There has been some criticism of this part of the plan since it was issued. There is no question that batteries are beneficial to reduce peak demand on a grid, to steady the unsteady generation of solar and wind power, to have as a backup in case of a horrendous storm. However, batteries are also inherently inefficient energy-wise. In the process of gathering, storing, and then releasing power, some electricity is lost. Therefore, for every kilowatt-hour of electricity stored in a battery, more electricity must be generated in the first place. Of course, if this electricity is generated from renewable sources, there is no additional cost (no fuel to obtain) and no GHG emissions.

Therefore, batteries are no help for energy efficiency and GHG emission reduction goals, except in the context of solar and wind technologies. An office complex utilizing battery storage will, by itself, not cause less electricity used for the lights, computers, elevators, AC, etc.

Nobody can argue that battery storage can help make the grid more reliable in case of very high peak demand and storm damage. While Massachusetts is unique in encouraging battery development and implementation, other organizations believe the first and perhaps only priority should be in energy efficiency and reducing demand for energy, while growing the economy.

Supporters of battery storage argue that encouraging usage will help maximize the benefits of solar and wind generation, encouraging more clean power nationwide displacing dirtier fossil fuel-generated power, including peaker plants or fuel-generated plants that operate in conjunction with solar and wind plants.

Therefore, the Massachusetts program should be read as a program to encourage smart energy “management”, rather than for efficiency alone. States and nations need to move toward better energy management, which is not only efficiency, but operations and reliability, as well.

CCES has the experts to help your firm or entity manage your energy better, a growing issue as energy costs rise faster than inflation. Whether it is battery power, renewable power, or just being more efficient to be “green” and save costs, CCES can help you reach your goals and save costs. Contact us today at 914-584-6720 or at karell@CCESworld.com.

NYC Enacts New Rule Requiring GHG Emission Limits for Commercial, Residential Buildings

On April 22, 2019, Earth Day, the City of New York enacted the “Climate Mobilization Act” into law (“Intro 1253”). This law will impose mandatory GHG emission limits for large buildings, beginning in calendar year 2024. This new rule is clearly the most ambitious Climate Change rule taken by a U.S. municipality.

Buildings are responsible for about 70% of NYC’s GHG emissions; half of this comes from large buildings. Therefore, NYC has focused on the building sector to meet their 80% X 2050 emission reduction goals, starting with its own energy code and with local laws requiring benchmarking, energy audits, retro-commissioning, and sub-metering.

Rule Overview

Intro 1253 goes further, containing GHG emission intensity limits on nearly all buildings of at least 25,000 square feet of floor area beginning in 2024. The law defines the term “building emissions” as “GHG emissions as expressed in metric tons of CO2e emitted as a result of operating a covered building.” Thus, the limits on GHG emissions will apply not only to Scope 1 or on-site sources (such as those from a building’s boiler) but also include Scope 2 or off-site sources caused by a demand, such as purchased steam or electricity consumed in building operations. The building emissions intensity limits are tailored to specific Occupancy Groups. They will be be ratcheted down in 5-year intervals after 2029 to reduce GHG emissions from covered buildings by 80% by 2050.

The table in the link below summarizes GHG emission limits from different listed building types. https://energywatch-inc.com/breaking-new-york-city-council-passes-first-of-its-kind-ghg-emissions-cap-for-buildings/

Exemptions

A major category exempt from this law is “rent regulated accommodations”, such as those with rent-stabilized units, lest rents may be raised markedly for needed upgrades. Intro 1253 does require the owners of such excluded rental multifamily buildings to implement several prescriptive energy conservation measures, such as repairing leaky heating systems, insulating pipes for heat and hot water, weatherizing windows and ductwork, and installing timers on exhaust fans. Among the other rule exemptions are public housing and houses of public worship. Not-for-profit hospitals and health-care facilities are not exempted from the rule but will need to meet less stringent standards.

Paths To Compliance

Intro 1253 provides a number of pathways to reduce GHG emissions. Thus, reductions may be credited to an owner for “renewable energy credits” (RECs), so long as the RECs are generated by a renewable source located in or directly deliverable to NYC. For calendar years between 2024 and 2029 deductions for up to 10% of reported annual emissions may also be taken for GHG offsets (offsite emission reductions) purchased by a building owner. Additional deductions from a building’s calculated emissions for the output of a clean distributed energy resource must be located at, on, in or directly connected to the building.

This new law does not allow for emissions trading among covered buildings. However, the City is studying the feasibility of such a trading scheme and will report to the Mayor and Speaker of the City Council by no later than January 1, 2021.

Intro 1253 imposes significant civil penalties for exceeding the annual building emissions limit and the degree of excess emissions. These penalties could run into the hundreds of thousands of dollars annually.

What You Can Do NOW To Reduce The Cost and
Aggravation of Complying

Owners of covered buildings should take advantage of the “head start” before the 2024 compliance date to begin developing strategies for addressing the requirements of Intro 1253. Technical experts can estimate whether a building, as it is operating today, would comply with the 2024 limits and, if not, options to achieve compliance in time. The owner has time to choose the best option(s) to comply, reducing costs and risk if the owner waited longer. And future planning is critical. The technical assessment can anticipate the likely operation and emissions of systems in 2024. This early determination of strategies can save a building owner a lot in avoided compliance costs.

Intro 1253 is reality. Building owners in NYC will need to determine their GHG emissions and possibly modify or upgrade energy systems to comply with the standards. Other cities and states will be watching and Intro 1253 could well be a model that others will emulate. Don’t just push this aside to another time or year. Look into this soon, be active, and take steps soon to comply, saving you money and raising your asset value. Watch out for more CCES blog articles on this rule and how to comply as the City of New York provides more details!

CCES has the experts in both energy engineering and greenhouse gas (“carbon”) emissions to help you assess your covered buildings and their compliance status, and can recommend smart and prudent steps to ensure compliance early on, saving you much money, improving asset value, and reducing the worry about compliance. Contact us today at 914-584-6720 or at karell@CCESworld.com.

High Efficiency Transformers – A Demand Side Strategy for NetZero Projects

by Lisa Westerfield, Technical Group Services

The most popular energy efficiency measures to reduce demand side loads include high-performance envelopes, daylighting, glazing, passive solar heating and then some. People often overlook the fact that power losses supplied by inefficient transformers can increase a building’s energy costs by as much as 6-12%.

Locked away in an electrical closet for the life of a building, transformers take high voltage power from the grid and convert it to lower voltage power that can be used by everything that runs on electricity in homes, offices, and manufacturing facilities.

The process of converting (stepping down) voltages involves some waste in the form of heat. Common examples of transformers that step-down power to even smaller voltages, that cell phones and laptops use, are at the cubes located at the ends of chargers. After they’ve been plugged in for a while, they warm up. That warmth is electricity that’s being lost in the form of waste heat.

Prior to 2007, efficiency requirements were non-existent for transformers. Recognizing the impact that inefficient transformers have on the built environment, the Energy Policy Act of 2005 was enacted. The policy required all dry type transformers rated 600V or less to meet NEMA TP-1 requirements by January 2007. In 2016, the DOE amended 10 CFR 431 (DOE 2016). By decreasing losses from 29-36% depending on the size of the transformer, the DOE estimated that that the new energy efficiency standard will save consumers up to $12.9 billion for equipment sold from 2016 – 2045.

While the DOE 2016 standard is a step in the right direction, those looking to do better, lower energy costs, and design NetZero projects need every edge they can get to reduce the demand side load and the renewable footprint. Transformers that are more efficient than the DOE standard exist.to help.

Powersmiths makes transformers with an additional 30-50% less losses than the DOE 2016 standard. These efficiencies are achieved by using a higher grade of steel for the core, using copper for the windings, offering models in each kVA size that are optimized for the application load, and offering more kVA sizes so that the whole system does not need to be oversized. The additional reduction in losses translates into an additional reduction in energy costs and greenhouse gas emissions by 6-12%. Put into perspective – On a NetZero project estimated to use 100 panels, would need 6-12 less panels.

To learn more about “Powersmiths Solutions for NetZero Buildings” go to https://www.powersmiths.com/netzero/

For more information, contact Lisa Westerfield, LEED AP, Technical Group Services at 609-947-1960 or at lisa@tgs-inc.com