Public comments for: Amendment of Rules Regarding Energy Audits and Retro-Commissioning

Comments

Comment:
We’ve carefully reviewed the proposed Amendment of Rules Regarding Energy Audits and Retro-Commissioning to NYC Local Law 87 and we want to show our strongest support for these changes. We praise the department’s Sustainability Unit for providing the much needed guidance and addressing many of the testing procedures that were never clear in the original rules and law. We are committed to working together with the department to accomplish the goals of the Mayor’s office Greater Greener Buildings plan in reducing carbon emissions and its effects on climate change. This amendment provides better clarity on how we can technically implement the required improvements. Furthermore, we support the use of Registered Design Professionals which will help to provide greater oversight over the whole process. We are committed to working with Licensed Professionals as they provide a higher caliber of training, expertise and professionalism. Within our organization we’ve found that we can deliver a quality product at a reasonable price point with the use of technology, good systems, and excellent communication while working with Registered Design Professionals.
Agency: DOB
Comment:
It seems overly restrictive to require that a Registered Design Professional be responsible for submitting energy efficiency reports. These reports do not entail design work, and their accuracy is not a matter of public safety. Indeed, the type of work that goes into energy auditing and reporting on the results thereof wouldn't on its own satisfy New York State's experience requirements towards qualifying to sit for the PE exam - so there are many individuals with years of practical experience, who are highly qualified to perform energy auditing work, but are not even eligible to become Registered Design Professionals. A CEM or CEA certification should be considered sufficient qualification for this purpose if the individual does not have a PE license.
Agency: DOB
Comment:
While I fully support the standardization of testing protocol, sampling requirements, and procedural guidelines for LL87 submissions, it seems counterproductive to further restrict the agent qualifications for those reports. CEM/CEA's - per the AEE's open letter to the DOB - are specifically trained to complete the requirements of the Energy Efficiency report, and are more than qualified to perform the energy assessment portion of this work. By requiring the addition of a design professional to the team, not only will the cost of the study skyrocket for the building owners, but the delivery time for the report will be increased significantly, and it is unlikely that this requirement will necessarily improve the quality of the deliverable. By instead focusing on investing more time and personnel into educating those responsible for completing the studies (e.g. better defined testing and reporting requirements, and a more streamlined/engaging review process), this program will be very successful. The DOB's technical reviewers are highly capable, and need to be given the resources and support personnel to properly evaluate these reports, rather than bottle-necking the service providers with stricter qualifications. In the interest of preserving the spirit of the law, namely promoting energy efficiency in NYC, it makes sense to focus on establishing clear guidelines for compliance instead of adding another qualification barrier to the submission process.
Agency: DOB
Comment:
The amended rule will “Restrict the approved agency qualifications and registration for the submission of energy efficiency reports to Registered Design Professionals”. This would mean CEMs and CEAs cannot submit an Energy Efficiency Report to the city without supervision from a Registered Design Professional. Currently CEMs and CEAs can submit these reports to NYC. As a CEM, CEP and CBCP with more than 25 years of experience in the field of energy management and reporting I believe this is a serious mistake on the part of DOB. Certified Energy Managers and Auditors will be the leaders in this field going forward. We need to expand their roles not restrict them. John B. CEM, CEP, CBCP, CTAB, CHFM
Agency: DOB
Comment:
Building Energy Audits should be performed by Personnel that are specifically trained to perform this service. The Professional that performs the Service should hold a Certification from a Governing Authority and demonstrates competency in the area of Energy Auditing and/or Energy Management. The Professional should successfully pass a Certification Exam in this area of study and be an active member of the Authority that grants the certification. The Certifying Authority should put forth a standard reporting format to be used when performing this service in order to maintain a consistent and uniform method for comparison with industry standards. The Firm that is selected to provide the Energy Performance Report should be Registered as a Professional Company that is regularly engaged for this service. The Report should be reviewed under the direction of a Professional that holds a Certified Energy Manager or Certified Energy Auditor Accreditation from the Association of Energy Engineers (AEE). These Credentials demonstrate the person performing the service has met the educational and professional standards as required to provide a concise detailed energy analysis that is consistent in quality and content.
Agency: DOB
Comment:
I am a Registered Architect and a CEM, CEA, CRM, BCxP. I believe that the opportunity of unlicensed but Certified Energy Auditors who not only hold the certifications by AEE, ASHRAE and BPI but have the expertise to get results will not benefit when they seek the oversight of uninvolved Registered Design Professionals. The body of knowledge and Certifications provided by these organizations inspires people to pursue and practice sustainability measures entailed in rule 103-07. I think the Department of Buildings should not limit submissions only to Registered Design Professionals. If carbon reduction goals are to be achieved practically, than many will lose on this opportunity with this amendment. For those who require a quality review they should be advised individually by the DOB.
Agency: DOB
Comment:
Regarding the Retrocommissioning Agent quailifications, it should be noted that the ASHRAE Commissioning Process Management Professional (CPMP) certification is in the process of being phased out and replaced by the ASHRAE Building Commissioning Professional (BCxP) certification. BCxP meets the U.S. Department of Energy guidelines. Recommend keeping in CPMP for the certifications that are still valid and adding BCxP as this certification will supersede CPMP.
Agency: DOB
Comment:
I don't agree with the need to require a design professional. There is nothing being designed. It is an audit of the as-found conditions for energy savings.
Agency: DOB
Comment:
My team at Green Partners has reviewed this proposed amendment to Local Law 87 and we support these changes. We feel that the requirement for a registered deign professional to perform this work will enhance the quality of Local Law 87 reporting. The Green Partners team feels that this amendment will result in higher quality reports which will result in lowering greenhouse gas emissions. Green Partners has been successful in using registered design professions at reasonable costs.
Agency: DOB
Comment:
1. Filing firms be Professional Corporations (PC, PLLC). 2. A requirement on burner modulation should be added for boilers that are switched to manual mode. 3. DOB should issue standardized Functional Performance Testing checklist for boilers, chillers, cooling towers, AHU, RTUs, Pumps etc. This will help streamline the process. 4. Table 4 should state acceptable CO2 and Excess Air requirements. 5. Define the standard for inspecting low pressure steam traps. 6. Define how light levels should be sampled? Define vertical and horizontal distance from fixture. How hsould light levels in rooms with daylighting should be measured. 7. DOB should describe how ventilation rates should be measured. Single Pitot, Anemometer, Hoods? 8. How should venatialtion rates be addressed for buildings without mechanical ventilation.
Agency: DOB

Pages