Skip to content

Procedures for Reporting on and Complying with Annual Greenhouse Gas Emissions

Print Friendly, PDF & Email


Rule status: Proposed

Agency: DOB

Comment by date: November 14, 2022

Rule Full Text
Proposed-Rule-Procedures-for-Reporting-on-and-Complying-with-Annual-Greenhouse-Gas-Emissions-for-Certain-Buildings-1.pdf

The Department of Buildings is proposing to add a new section 103-14 to Chapter 100 of Title 1 of the Rules of the City of New York to establish procedures for reporting on and complying with annual greenhouse gas emissions for certain buildings.

Attendees who need reasonable accommodation for a disablity such as a sign language translation should contact the agency by calling or emailing dobrules@buildings.nyc.gov by October 31, 2022

Send comments by

Public Hearings

Date

November 14, 2022
11:00am - 12:00pm EST

Location



Connect Virtually
https://tinyurl.com/Buildings2022Emissions
Meeting ID: 256 526 102 372
Passcode: 4rVtCM

To join the meeting only by phone:
Phone: 646-893-7101
Phone conference ID: 496 987 051#

Disability Accommodation

Online comments: 91

  • Mary Hill

    City housing and housing projects should be required to meet the same standards and deadlines so that the city can determine if such is reasonable as well as the cost.

    Comment added October 14, 2022 9:43am
  • Robert Crooke

    I applaud the attempt to lengthen and smooth out the transition targets but I believe the attempt has failed and the new proposal imposes a more difficult schedule. The original timeline required emissions reductions of 40% between 2024 and 2030; the proposed timeline requires reductions of 50%. This, when the technology and manpower to achieve such reductions is unclear and in short supply. The original timeline required reductions of 65% between 2030-2035; the new proposal suggests 20%, with further reductions beyond 2040. I believe the 2035 targets should require less than a 65% reduction but something greater than 20%. The smoothing should take place in this timeframe, not in the initial 2024-30 period. Beyond 2030 we should all have a clearer understanding of how to achieve the targets and the manpower and skills to apply to the problem. Basically giving more time to achieve the goal is good, but front-loading the reductions required is not good.

    Comment added October 14, 2022 6:32pm
  • Wai-Kin Tong

    On page 25, on-site solar generation is only deductible from 2024 to 2029. Why is the period so short?

    Comment added October 17, 2022 10:57am
  • Wai-Kin Tong

    On page 17, it states in item (ii) Greenhouse gas coefficients for utility energy consumption for calendar years 2030 through 2034… – Utility electricity shall be calculated as generating 0.000145 tCO2e per kBtu. Should this be per kWh?

    Section 28-320.3.1.1 has utility electricity generating 0.000288962 tCO2e per kWh for 2024-2029.

    Otherwise, electricity carries a higher CO2 emission rate in 2030.

    Comment added October 18, 2022 5:15pm
  • Marija Crook

    As a young resident of this city, it is imperative that the administration and Mayor Adams himself ensure that Local Law 97 is fully implemented and enforced. While New Yorkers across the city hand banded together to create safer, healthier, and more climate friendly communities, large land owners continue to do the bare minimum when it comes to reducing building emissions. Local Law 97 is essential to the overall health of a city that faces such an existential threat to the heat waves and flooding that will come with climate change. In order to ensure genuine progress is made on GHG reduction, Mayor Adams MUST set tight limits on the purchase of Renewable Energy Credits (RECs) to ensure we don’t fall into the same trap many energy credit systems fall in to — rich buying themselves out of climate commitments and no real progress on the issue at hand. Mayor Adams must enforce the pollution limits by assessing the law’s full penalties on building owners whose properties pollute over their caps. Another toothless housing law would be disregarded by building owners.

    Comment added October 24, 2022 1:36pm
  • Ben Milbank

    Ecosystem commends the Department of Buildings for providing electrical emissions factors for future periods, therefore bringing clarity on the types of retrofits that will lead to compliance. However, we strongly advise against the 2050 zero emissions mandates. It has become apparent that 80 to 95% decarbonization is technically feasible and cost-effective, while the remaining 5% of emissions prove extremely challenging to eliminate in terms of technical feasibility, resiliency, and cost. Therefore, it is likely that setting the objective to zero will lead to less decarbonization, as the path to full compliance will be several magnitudes more complex. Building owners will be far less inclined to undertake deep decarbonization projects if the result is still non-compliance.

    Comment attachment
    Ecosystem-Public-Comment.pdf
    Comment added October 26, 2022 5:58pm
  • grace irizarry

    MJOR ADAMS NEED TO IMPLEMENT AND ENFORCE THE LOCAL LAW, WE THE PEOPLE DEMAND IT. HE WORKS FOR US.

    Comment added October 30, 2022 1:01pm
  • Phil Fram

    Mayor Adams: Please support full implementation and enforcement of LL 97.

    Comment added October 30, 2022 1:04pm
  • Laura Klein

    As a retired teacher I am well aware of the sad and dangerous conditions in the NYC public schools. Local Law 97 is a well written law that Mayor Adams should be fully implementing and enforcing. He should be making it his business to see that building owners are penalized when they pollute over their caps or otherwise disregard housing laws. The purchase of RECs should, especially, be tightly regulated and the Mayor should be held responsible for lack of such enforcement. Who we vote for matters and we need to monitor his performance in this area!

    Comment added October 30, 2022 1:22pm
  • Roseanne Andrade

    let’s move forward to 100% clean renewable energy in off-shore wind/solar.

    Comment added October 30, 2022 1:36pm
  • nico hammond

    Mayor Adams should fully implement and enforce Local Law 97 to insure large, luxury builders do not contribute to an increase in carbon emissions.

    Comment added October 30, 2022 2:04pm
  • Liz Manning

    Mayor Adams should fully implement and enforce Local Law 97, sets tight limits on the purchase of Renewable Energy Credits, and enforce the pollutions limits by assessing the law’s full penalties on building owners whose properties pollute over their caps.

    Comment added October 30, 2022 2:45pm
  • Beloved Karen

    I believe that every person should be held accountable for their personal and public lives because our lives impact others. Having said that, our representatives should be held to a higher standard. Mayor Adams should fully implement and enforce Local Law 97 and set tight limits on renewable energy credits.

    Comment added October 30, 2022 2:47pm
  • Izzy Goodman

    Mayor Adams, please fully implement and enforce Local Law 97. We as a city have an opportunity to be leaders on this issue. Please enforce the pollution limits by assessing the full penalties on building owners.

    As a Hunter College student I have seen, firsthand, the impact of crumbling buildings on our learning environments.

    Comment added October 30, 2022 2:55pm
  • Jack Gorman

    I am a physician who lives in the Bronx and am deeply committed to improving the health and safety of my community. That means to me that Mayor Adams should fully implement and enforce Local Law 97. I want to see that Mayor Adams sets tight limits on the purchase of Renewable Energy Credits and enforcing the pollution limits by assessing the law’s full penalties on building owners whose properties pollute over their caps. It is urgent that we move quickly to clean energy and I hope Mayor Adams will ensure this happens in our city by enforcing Local Law 97 to its fullest extent. Thank you

    Comment added October 30, 2022 3:07pm
  • Bill Scott

    First of all, Mayor Adams should do his JOB and ENFORCE THE LAW!!! Specifically, Local Law 97 needs to be enforced. No question about it.

    Second, unless Mayor Adams favors the pollution that sickens people and shortens lifespans, he MUST enforce pollution limits. Is that so hard to understand? Protect citizen health and lives by penalizing properties exceeding pollution caps.

    Comment added October 30, 2022 3:12pm
  • Zasu Scott

    I’m passionate that Mayor Adams fully implement Local Law 97 by keeping tight limits on the purchase of RECs. It’s critical that we hold building owners accountable by enforcing pollution limits against building owners that have went over the caps.

    Comment added October 30, 2022 3:15pm
  • Omar Rodriguez

    Mayor Adams needs to pass finally implement NYC’s Green New Deal law. NYC is in need of environmental justice. We have been fighting for years to better NYC and Mayor Adams is actively pushing us back.

    Comment added October 30, 2022 3:26pm
  • Ann Lane

    Local Law 97 is what is going to give my children a LIVABLE future. Mayor Adams should represent all New Yorkers, not just the landlords. I support setting tight limits on the purchase of RECs. I am a co-op owner in Riverdale and I actually support by building’s being held accountable for any penalties we might incur.

    Comment added October 30, 2022 3:37pm
  • Nan Faessler

    LocalLaw 97 is essential for the City of New York to meet its climate goals and help to assist with the whole state of New York to meet the goals of the CLCPA. Do not let the real estate industry push back and weaken this law and it is imperative that the Mayor and all of the City Council members hold firm and not weaken the penalties.

    Comment added October 30, 2022 3:45pm
  • Xaver Kandler

    The building that I’m living in is the first buildling that is fully electric and my indoor air quality is better than any apartment I have ever lived in. Better yet, it is contributing far less to climate change with its efficient building materials!

    To make this a reality for everyone, Major Adams should fully implement and enforce Local Law 97 with very tight limits on the purchase of RECs and ensure that he fines building owners who pollute over their caps. Without real teeth, buildings owners will not comply.

    Comment added October 30, 2022 3:54pm
  • Ann Rauch

    I am writing to urge Mayor Adams to fully implement and enforce Local Law 97. I also urge the Mayor to set tight limits on the purchase of Renewable Energy Credits. Mayor Adams should enforce the pollution limits by assessing the law’s full penalties on building owners whose properties pollute over their caps. NYC can set an example for the rest of the country by becoming a truly sustainable city.

    Comment added October 30, 2022 4:06pm
  • Ryan Madden

    I am a lifelong New Yorker, Brooklyn resident, and climate organizer. I worked to pass New York State’s landmark climate law in 2019, the Climate Leadership and Community Protection Act, and have since been working to ensure its equitable implementation. Local Law 97 is a crucial piece of complimentary legislation to meet the City’s local need to reduce NYCs number one source of greenhouse gas emissions – buildings.

    This is why I want to see the full implementation and enforcement of Local Law 97 with tight limits on the purchasing of Renewable Energy Credits (RECs). The rules setting REC use must limit application so they do not become a method of “buying out” of the law’s requirements. I urge limiting RECs to only electrical use and a maximum 10% of pollution (or equivalent limit).

    Mayor Adams must enforce the pollution limits by assessing the law’s full penalties on building owners whose properties pollute over their caps. Another toothless housing law would be disregarded by building owners. Most buildings will save money through lower utility bills and operating costs over and above the cost of financing energy efficiency upgrades as they work to satisfy Local Law 97 by upgrading to higher energy efficiency – and cutting energy waste.

    There are several steps the city should take to strengthen the law: properly fund the law’s enforcement by hiring additional staff; fund supportive programs to help building owners comply; ensure rule-makings maximize pollution cuts and jobs created; and tightly limit REC use so that building owners cannot evade the law’s requirements with unlimited REC use. The law should not be weakened by weakening penalties or other requirements. Competent, professional staff should not be diverted for special favors to well-connected developers and real estate interests.

    For the safety, comfort, affordability, and health of NYC communities, enforce the strongest provisions of this law without compromise.

    Comment added November 3, 2022 11:25am
  • Bonnie Fultz

    I am 72 years old and recently retired. I’ve lived in New York for over 40 years and expect to die here. I think it’s important as you promulgate the rules for implementing PL97 that you remember what the consequences are likely to be if it is not faithfully and fully enforced. I cannot look at the city’s youngest residents—today’s infants and toddlers—without wondering whether they can look forward to the lifespan I’ve attained, wondering how degraded the quality of their lives will be because of our failure to reverse the momentum of climate change.
    Do not let the self-interest of the powerful dilute the impact of this critical endeavor. Ensure, for example, that the applicability of REC’s is narrowly defined and closely monitored and that the law as a whole is vigorously and equitably enforced. Recall, too, that the residential buildings covered by this law have tenants and not just owners and that the youngest of those tenants are among the greatest stakeholders.

    Comment added November 4, 2022 3:13pm
  • Andrew Karlovich

    • Will LL97 emissions limits be set using the Gross Floor Area on file with the DOF, or per the gross floor area included in the reports? How will the reported GFA be reconciled?
    • Do off-site RECs used for deductions need to be attributable to Zone J or have any geographic requirements?
    • Are there specific third party certification criteria that RECs need to meet (i.e. Green-E certification)
    • Do RECs have to be purchased in the RPS market or could they be purchased in the voluntary national market? This really impacts the cost of RECs, but RECs purchased through the voluntary market will likely have minimal impact on driving new renewable energy for Zone J.
    • What is an example of a “subscription to off-site solar energy generation?”
    o Does this refer to virtual PPAs?
    o Why do subscriptions to off-site solar generation need to serve zone J, while purchased RECs do not?
    • Will a reporting template be provided by the city?
    • Page 17, Paragraph 3, Subparagraph ii.a
    o There appears to be a typo indicating that the 2030-2034 grid electric emissions factor shall be calculated as generating 0.000145 tCO2e per kBTU which would imply a roughly 70% increase in emissions per unit generated energy over the 2024-2029 emissions factor. Need to confirm that the intended units here are kwh and not kBTU.

    Comment added November 7, 2022 10:08am
  • Ella Ryan

    70% of NYC’s GHG emissions come from buildings. It’s time to rip off the bandaid. The sooner NYC begins to implement LL97 the sooner we can deliver on our carbon commitments and provide our residents with cleaner air and safer homes.

    Comment added November 7, 2022 2:16pm
  • Yarden Orly

    Mayor Adams, it is imperative to all New Yorkers – present and future – that Local Law 97 is fully and strictly implemented with deep consideration of environmental and social justice.

    Cap the purchase of Renewable Energy Credits (RECs) and ensure that penalties are fully enforced. Limiting RECs to electricity is a step in the right direction, but without additional restrictions RECs could severely undermine the impact of LL97. There must be a strict cap on the use and availability of RECs for building owners, to ensure that LL97 remains focused on driving on-site improvements in buildings, which will reduce local air pollution, generate thousands of local jobs and make our homes and workplaces healthier and more comfortable. Without additional limits, far too many buildings could choose to comply by purchasing RECs instead of making building upgrades. A strict limit on RECs will assist with aggressively reducing targeted emissions from the building sector.

    Protect tenants so that costs of building upgrades/retrofits are not passed onto them. Tenants, such as individual residents, families, non-profits, and aid organizations, need protections to implement LL97 equitably and avoid unintended consequences like landlords passing on retrofit costs to tenants, displacement, and gentrification. Additionally, the City needs to provide more programs and services for building owners and tenants to better understand LL97, its implications, and crossover with other rights.

    Incentivize building retrofits. The City needs to ensure it is offering incentives to help residential buildings make necessary upgrades. By maximizing the benefits of state and federal programs, NYC can ensure that building owners are receiving all of the possible benefits and have multiple options available to them. The City also needs to provide new financing tools and funding, while supplementing the ones that already exist for building owners, especially small-property owners.

    Comment added November 9, 2022 11:49pm
  • Robert Green

    I think this law is very restrictive and burdensome on older building owners even if it is well intentioned. Will the city be giving money to do the upgrades to reduce emissions? Some small building owners can’t afford to comply by 2025 without going bankrupt in addition to all the other costs in regulations the city has added recently including new lead laws etc

    Comment added November 10, 2022 9:41am
  • John Ingram

    Local Law 97 testimony Nov. 22. John Ingram – East Tenth St. NYC

    In 1982 my wife and I moved to East Tenth St. Manhattan, one block from the East River. On October 29, 2012, Hurricane Sandy hit New York. Over 65 years of living in homes along the New England coast I have experienced most of our major north east hurricanes and was well prepared to ride this one out. But Sandy was clearly different from previous storms. It was huge, and it was not swinging up the coast and out to the Atlantic as previous hurricanes had consistently done. Because of the Greenland Jetstream Block Sandy was being pushed westward directly towards NYC and New Jersey. In addition, the predicted arrival of Sandy’s massive storm surge would coincide with the high tide. On the evening of Sandy’s impact, I was waiting for the surge to come down our street from the East River. My front windows look north directly across the “Drydock Pool” and its park to the Con Ed Peaker plant on East 14th St. Looking out my window at 9:00 pm the power plant’s switches exploded right in front of me from the surge and soon all power was gone. Strangely the surge then came up Tenth Street from the West as the river flooded around to Ave. C and then went eastward. Our basement flooded, and we were out of power for several days.

    What connects my story to the Buildings Bill is that Sandy was a forerunner of various climate related catastrophes now occurring and escalating in scale and intensity around the world. The Greenland Jet Stream Block that made Sandy an anomaly is formed by the melting of the Greenland ice sheet caused by decades of our Greenhouse Gas emissions. This rapidly melting ice sheet and its resulting atmospheric block is becoming a major force in activating changes in global weather and ocean currents. Along with several other critical points of system change around the world our planet is rapidly reinventing itself because of our emissions and has no concern for human survival.

    As the species that continues to damage the climate that sustains all life, we have a closing window to end this disruption. The current scientific consensus is that a complete ending of Greenhouse Gas emissions in a few years will in fact quickly stop the momentum of Climate Change before it is too late.

    We now have very little time to end the use of fossil fuels. The plunge in price of renewable energy is reason for some hope. Buildings in cities around the world are a major source of Green House Gas emissions. We have the technological ability to rapidly cut back these emissions from our cities, but these technologies must be put in place now. Real Estate and citizens will not do this on their own, but can gain in long term benefits if they do. New York’s Local Law 97 is a necessary precedent for the success of all cities in ending our addiction to fossil fuels and our self-destruction.

    1. Mayor Adams should fully implement and enforce Local Law 97
    2. Mayor Adams should set tight limits on the purchase of Renewable Energy
    Credits (RECs).
    3. Mayor Adams should enforce the pollution limits by assessing the law’s full
    penalties on building owners whose properties pollute over their caps. Another
    toothless housing law would be disregarded by building owners.

    Respectfully,
    John Ingram
    434 East Tenth Street
    NYC 10009

    350 NYC

    Comment attachment
    Local-Law-97-testimony-Nov.docx
    Comment added November 10, 2022 9:52am
  • Yachiel Pol

    Since the data on the city’s calculator only provides data from four years ago, it’s difficult to gauge our efforts. Please provide more up-to-date information and also take into account the fact that we are working to lower our usage. We should not pay a fine if we are working to lower our emissions.

    Comment added November 10, 2022 11:17am
  • Leah Kay

    Hi

    Old properties in general will have more emissions, and less income due to the fact that there are still a lot of old rent stabilized tenants. Building owners need grants or at least cheap loans from the government to be able to upgrade those buildings properly to reduce emmissions.
    Some building owners might also spend thousands and then still not meet those stringent numbers. If owners show they tried they should be able to avoid fines. Without providing proper tools, guidance and funds there will be a wave of foreclosures. We ask the honorable Mayor to consider those facts before implementing the law.
    We the people appreciate all the hard work you do to make NYC a safer place for all.

    Comment added November 10, 2022 1:39pm
  • Miri Lei

    Hi

    Old properties will have more emissions, and those buildings don’t have sufficient income as it’s occupied by rent stabilized tenants. Take a 6 family with each tenant paying $800 a month please explain how this owner can follow these expensive upgrades without going bankrupt. Building owners need grants from the government to be able to upgrade those buildings properly to reduce emissions.
    Some building owners might also spend thousands and then still not meet those stringent numbers. If owners show they tried they should be able to avoid fines. Without providing proper tools, guidance and funds there will be a wave of foreclosures.
    PLEASE ENFORCE LAW AND ORDER AND LOWER THE CRIME RATE BEFORE ENFORCING THOSE STUPID EMISSION LAWS THAT’LL PUT MILLIONS OF OWNERS INTO BANKRUPTCY!!!!!!

    Comment added November 10, 2022 2:12pm
  • Brooke Pierce

    We need Mayor Eric Adams to implement and truly enforce Local Law 97. It is also important to set tight limits on the purchase of Renewable Energy Credits and to enforce pollution limits by full penalizing building owners whose properties are polluting over their caps.

    Comment added November 10, 2022 9:45pm
  • Jon Kelly

    Mayor Adams, it is imperative to all New Yorkers – present and future – that Local Law 97 is fully and strictly implemented with deep consideration of environmental and social justice.

    Cap the purchase of Renewable Energy Credits (RECs) and ensure that penalties are fully enforced. Limiting RECs to electricity is a step in the right direction, but without additional restrictions RECs could severely undermine the impact of LL97. There must be a strict cap on the use and availability of RECs for building owners, to ensure that LL97 remains focused on driving on-site improvements in buildings, which will reduce local air pollution, generate thousands of local jobs and make our homes and workplaces healthier and more comfortable. Without additional limits, far too many buildings could choose to comply by purchasing RECs instead of making building upgrades. A strict limit on RECs will assist with aggressively reducing targeted emissions from the building sector.

    Protect tenants so that costs of building upgrades/retrofits are not passed onto them. Tenants, such as individual residents, families, non-profits, and aid organizations, need protections to implement LL97 equitably and avoid unintended consequences like landlords passing on retrofit costs to tenants, displacement, and gentrification. Additionally, the City needs to provide more programs and services for building owners and tenants to better understand LL97, its implications, and crossover with other rights.

    Incentivize building retrofits. The City needs to ensure it is offering incentives to help residential buildings make necessary upgrades. By maximizing the benefits of state and federal programs, NYC can ensure that building owners are receiving all of the possible benefits and have multiple options available to them. The City also needs to provide new financing tools and funding, while supplementing the ones that already exist for building owners, especially small-property owners.

    Comment added November 11, 2022 10:25am
  • Daniel Nallen

    Mayor Adams, it is imperative to all New Yorkers – present and future – that Local Law 97 is fully and strictly implemented with deep consideration of environmental and social justice.

    Cap the purchase of Renewable Energy Credits (RECs) and ensure that penalties are fully enforced. Limiting RECs to electricity is a step in the right direction, but without additional restrictions RECs could severely undermine the impact of LL97. There must be a strict cap on the use and availability of RECs for building owners, to ensure that LL97 remains focused on driving on-site improvements in buildings, which will reduce local air pollution, generate thousands of local jobs and make our homes and workplaces healthier and more comfortable. Without additional limits, far too many buildings could choose to comply by purchasing RECs instead of making building upgrades. A strict limit on RECs will assist with aggressively reducing targeted emissions from the building sector.

    Protect tenants so that costs of building upgrades/retrofits are not passed onto them. Tenants, such as individual residents, families, non-profits, and aid organizations, need protections to implement LL97 equitably and avoid unintended consequences like landlords passing on retrofit costs to tenants, displacement, and gentrification. Additionally, the City needs to provide more programs and services for building owners and tenants to better understand LL97, its implications, and crossover with other rights.

    Incentivize building retrofits. The City needs to ensure it is offering incentives to help residential buildings make necessary upgrades. By maximizing the benefits of state and federal programs, NYC can ensure that building owners are receiving all of the possible benefits and have multiple options available to them. The City also needs to provide new financing tools and funding, while supplementing the ones that already exist for building owners, especially small-property owners.

    Comment added November 11, 2022 11:02am
  • Jan Thompson

    I’m commenting to urge Mayor Adams to fully implement and enforce Local Law 97 and set tight limits on renewable energy credits. As a long time resident of the most populous city in the country I feel we have a duty to work to reduce our carbon footprint, for the sake of our own citizens, and to be a beacon to others around the country. There is nothing we can’t do if we put our mind to it. Kicking the can down the road for future generations was an option maybe 20 years ago, but it’s too late to continue playing that game. Let’s do this— we are New York strong!

    Comment added November 11, 2022 1:22pm
  • Troy Martin

    Provision (e) of the proposed LL97 implementation rules ( “Deductions from reported annual building emissions”) is materially different from §28-320.3.6.1 of LL147 which states: “A deduction from the reported annual building emissions shall be authorized equal to the number of renewable energy credits purchased by or on behalf of a building owner, provided (i) the renewable energy resource that is the source of the renewable energy credits is considered by the New York independent system operator to be a capacity resource located in, or whose output directly [deliverable] sinks into, the zone J load zone for the reporting calendar year; (ii) the renewable energy credits are solely owned and retired by, or on behalf of, the building owner; (iii) the renewable energy credits are from the same year as the reporting year; and (iv) the building that hosts the system producing the energy does not receive a deduction under [§ 28-320.6.3] section 28-320.3.6.3. Covered buildings claiming deductions for renewable energy credits under this section must provide the department with the geographic location of the renewable energy resource that created the renewable energy credits. The department, in consultation with the mayor’s office of long-term planning and sustainability, shall promulgate rules to implement this deduction.”

    LL147 also defines a capacity resource as follows: “The term “capacity resource” means a facility that has the capability to generate and transmit electrical power and sell capacity (i) by bilateral contracts, (ii) in the wholesale capacity market, or (iii) by indirect sales of capacity in the wholesale market in accordance with the schedules of rates and charges of a utility in effect pursuant to section 66 of the public service law.”

    How does the Department of Buildings envisage incorporating the legislative text of LL147 into what is currently provision (e) in its final rule?

    Comment added November 11, 2022 2:41pm
  • Adam Seltzer

    I am a young Manhattan resident who’s deeply invested in seeing meaningful climate action. Mayor Adams should fully implement and enforce Local Law 97
    Mayor Adams should set tight limits on the purchase of Renewable Energy Credits (RECs). Mayor Adams should enforce the pollution limits by assessing the law’s full penalties on building owners whose properties pollute over their caps. Another toothless housing law would be disregarded by building owners.

    Comment added November 11, 2022 2:46pm
  • Gregory Keiser

    Mayor Adams, it is imperative to all New Yorkers – present and future – that Local Law 97 is fully and strictly implemented with deep consideration of environmental and social justice.

    Cap the purchase of Renewable Energy Credits (RECs) and ensure that penalties are fully enforced. Limiting RECs to electricity is a step in the right direction, but without additional restrictions RECs could severely undermine the impact of LL97. There must be a strict cap on the use and availability of RECs for building owners, to ensure that LL97 remains focused on driving on-site improvements in buildings, which will reduce local air pollution, generate thousands of local jobs and make our homes and workplaces healthier and more comfortable. Without additional limits, far too many buildings could choose to comply by purchasing RECs instead of making building upgrades. A strict limit on RECs will assist with aggressively reducing targeted emissions from the building sector.

    Protect tenants so that costs of building upgrades/retrofits are not passed onto them. Tenants, such as individual residents, families, non-profits, and aid organizations, need protections to implement LL97 equitably and avoid unintended consequences like landlords passing on retrofit costs to tenants, displacement, and gentrification. Additionally, the City needs to provide more programs and services for building owners and tenants to better understand LL97, its implications, and crossover with other rights.

    Incentivize building retrofits. The City needs to ensure it is offering incentives to help residential buildings make necessary upgrades. By maximizing the benefits of state and federal programs, NYC can ensure that building owners are receiving all of the possible benefits and have multiple options available to them. The City also needs to provide new financing tools and funding, while supplementing the ones that already exist for building owners, especially small-property owners.

    Comment added November 11, 2022 3:51pm
  • Alayne Cyk

    Mayor Adams, it is imperative to all New Yorkers – present and future – that Local Law 97 is fully and strictly implemented with deep consideration of environmental and social justice.

    Cap the purchase of Renewable Energy Credits (RECs) and ensure that penalties are fully enforced. Limiting RECs to electricity is a step in the right direction, but without additional restrictions RECs could severely undermine the impact of LL97. There must be a strict cap on the use and availability of RECs for building owners, to ensure that LL97 remains focused on driving on-site improvements in buildings, which will reduce local air pollution, generate thousands of local jobs and make our homes and workplaces healthier and more comfortable. Without additional limits, far too many buildings could choose to comply by purchasing RECs instead of making building upgrades. A strict limit on RECs will assist with aggressively reducing targeted emissions from the building sector.

    Protect tenants so that costs of building upgrades/retrofits are not passed onto them. Tenants, such as individual residents, families, non-profits, and aid organizations, need protections to implement LL97 equitably and avoid unintended consequences like landlords passing on retrofit costs to tenants, displacement, and gentrification. Additionally, the City needs to provide more programs and services for building owners and tenants to better understand LL97, its implications, and crossover with other rights.

    Incentivize building retrofits. The City needs to ensure it is offering incentives to help residential buildings make necessary upgrades. By maximizing the benefits of state and federal programs, NYC can ensure that building owners are receiving all of the possible benefits and have multiple options available to them. The City also needs to provide new financing tools and funding, while supplementing the ones that already exist for building owners, especially small-property owners.

    Comment added November 11, 2022 6:58pm
  • Wolfgang Werner

    I am curious about the the omission of addressing the Greenhouse Gas Coefficients after 2034, both in LL97 itself and in the proposed Rules. The coefficients for 2024-2029 were included in LL97 (§ 28-320.3.1.1), and for 2030-2034 they are included in the proposed Rules (in section (3)(ii) on p.17). The Emission Factors (i.e. limits per building type), however are defined all the way through 2050 and beyond.
    Notably the Law itself and the Rules are also silent on how those future GHG Coefficients will be defined (by who? when? etc.), and this strikes me as a curious omission as they are so integral to the math and the compliance/non-compliance outcome for covered buildings.
    Why is there no mechanism described in the Rules for the determination of these future coefficients?

    Comment added November 13, 2022 8:17am
  • Betty Winkler

    I write as a New Yorker who lived through a flood in 1972 which destroyed buildings, businesses and lives. This flood was a combination of a hurricane and corporate corruption from previous decades. The effects of the hurricane were intensified by the corruption. This was my experience of weather turned to disaster by greed.

    In the late 1970s I moved to the California Bay Area. This was both before and during the retro-fitting of buildings for earthquakes. Retrofitting was a new law for building owners, aimed at preventing building collapse during seismic events. Friends and family members grumbled about the costs of it. It was an investment, one that has paid off repeatedly, as none of these buildings have fallen in quakes and tremors occuring since then.

    Similarly, that’s what Local Law 97 is for building owners – a long-term investment.

    Mayor Adams should fiully implement and enforce Local Law 97
    Mayor Adams must set strict limits on the purchase of RECs/Renewable Energy Credits
    Mayor Adams should enforce the pollution limits by assessing the law’s full penalties on building owners whose properties poilute over their caps. Without assessments and penalties, the law would be ignored by biulding owners – to the detriment of the populace.

    Thank you for your time,

    Betty Winkler
    78 Manhattan Ave. #3C
    New York, NY 10025

    Comment attachment
    LOCALLAW97_LETTER.pdf
    Comment added November 13, 2022 11:18am
  • Jeff Levy-Lyons

    The rapid changes we need to make to address the climate crisis asks a lot of us all. And since those changes include ensuring that our buildings are no longer the cause of the worst pollution in our city, we need to ask a lot of the owners of those buildings. Every industry will need to step of and make real sacrifices, yes, that dirty word sacrifice. It’s easy to take the position that, “Hey, we’re only human, we’re only trying to make a living and we should follow sound business practices which generally means incremental change”. And there was a time when that was a winning argument, but that time was about 30 years ago.

    As a resident of Manhattan, as a father raising 2 kids here, and perhaps more importantly as a person of faith, I’m calling on the mayor to hold to the full force of Local Law 97. There is no moral ground for letting the real estate industry dodge the responsibility of cleaning up the city’s most polluting large buildings through the purchase as many REC’s as possible.

    The profitability of a large office tower or apartment complex matters not a damn to an 8-foot rise in sea level and heaven help us if we fail to figure that out very, very quickly. So let me put it as a question directly to the reps of the real estate industry who want to undermine a law designed to protect my children’s future; Do you want to be the villains of this story or the heroes? I know what I want to see when I look in the mirror. What do you want to see?

    Comment attachment
    Testimony-for-Local-Law-97-Hearing.docx
    Comment added November 13, 2022 11:24am
  • Martin G Weiner, Architectural Worker

    Mayor Adams,
    Low income neighborhoods of color disproportionately suffer the effects of greenhouse gas emissions, including vastly higher rates of respiratory disease.

    Low-income communities are often built on flood plains which, as in Hurricanes Sandy and Ida, are a disproportionate risk of flooding due to increased greenhouse gas emission, destroying homes and social cohesion.

    Mayor Adams, make good on your promise to force rich real estate developers to CLEAN UP their dirty luxury residential towers and corporate skyscrapers, and STOP POLLUTING our air! Ensure that those who can afford to, renovate, and not be provided credit transfer loopholes to dodge the law.

    Mayor Adams, Clarify the rules that PROTECT RENTERS, and APARTMENT, AND SMALL BUSINESS OWNERS from bearing the cost of expensive renovations! Fully fund clean conversions, now!

    Mayor Adams, LL97 promises over 140,000 good-paying, local, career-track jobs in design, engineering, and construction to upgrade buildings in every NYC neighborhood. Do not miss this chance to create the greatest jobs program in our city since the New Deal!

    Comment added November 13, 2022 12:16pm
  • Adriane Leveen

    Mayor Adams should fully enforce LL97 to reduce emissions in NYC and not weaken it through rule-making.  Why reopen and weaken a necessary bill that has the support of your voters, Mayor Adams?

    Comment added November 13, 2022 12:39pm
  • Lynn Nevins

    Enforce LL97 fully! NYC should be leading the transformation to sustainable cities.

    Comment added November 13, 2022 12:44pm
  • Ben Orlove

    Let’s make sure that LL97 achieves its purposes of reducing emissions in NYC. The proposed Renewable Energy Credits would not reduce emissions here in the city. Moreover, they fail entirely to address the majority of the emissions from buildings, which come from burning fossil fuels for heating residential space and water. If the city wants RECs, they should be limited to a set level, I propose10% of a building’s energy usage. Allowing more RECs would let NYC continue to be a major polluter. Instead, we should set an example so that other cities will be inspired to join us in the crucial task of keeping the world habitable for future generations.

    Comment added November 13, 2022 12:53pm
  • Judith B Edelstein

    I am very disappointed in the Mayor Adams’ actions regarding the environment. I urge him to consider the immediate future of our city and not bow down to the real estate industry. He must fully enforce LL97 to reduce emissions in NYC and not weaken it through rule-making.

    Comment added November 13, 2022 1:17pm
  • Mary Krieger

    Local Law 97 requires the C02 reductions needed to avert the most catastrophic effects of climate change. There is no time to allow building owners to weaken the law’s emissions reductions requirements by allowing them to buy REC’s instead of greening their buildings. Owners have had since 2019 to plan how they will meet carbon reduction mandates. Penalties should be fully enforced. At the same time, the city should support LL97 by providing more programs and services for building owners and make information about state and federal incentives available to them. Retrofits will reduce energy costs for building owners and create jobs. The Mayor and the City Council should fully fund programs to facilitate the implementation of Local Law 97.

    Comment added November 13, 2022 2:14pm
  • Tamar Yanay

    Fully implementing and enforcing Local Law 97 means a healthier more stable future for all NY residents. Millennials like myself and Gen-Z voters list climate as one of their top two issues when voting. We need a mayor who is a climate champion to lead is into a secure future. We notice what policies are implemented and we vote with our values.

    Comment added November 13, 2022 6:21pm
  • Ian McCollum

    Mayor Adams and the NYC Dept. of Buildings,

    As a young New Yorker, a public high school student, and climate organizer, I am justifiably concerned about the impact that carbon emissions will have on my future and that of our city. I have lived through the devastating events of super storm Sandy which tested our city’s ability to respond to the impacts of a growing climate crisis. The truth is we weren’t prepared, Local Law 97 is yet another crucial step that we must take to combat the crisis from the ground up.

    For my entire career as a student, I have attended schools within one block of Robert Moses era highways. I have seen first hand the impact that carbon emissions has on our young people who suffer with disproportionately high asthma rates. This isn’t just about climate change! In a society that targets marginalized communities to bear the brunt of the crisis we face, we must recognize that climate justice, is racial, economic, and social justice.

    Buildings in NYC account for over 70% of our city’s emissions contributing and fueling the crisis we see ourselves in today. We MUST NOT make excuses in an attempt to bail out the multi-billion dollar real estate industry that continues to sacrifice our future for their own profit. We MUST NOT stall deadlines/emission reduction targets that will only hurt our most vulnerable communities.

    I urge mayor Adams, his administration, and the NYC Department of Buildings to fully enforce and swiftly implement Local Law 97 in it’s entirety. We must also set stringent limits on the purchase of renewable energy credits (RECs) to ensure full compliance by building owners. Finally we should be implementing full penalties for buildings who fail to comply, we must be a model for an equitable transition to a clean city that centers the communities harmed by the crisis, not the profit making real estate industry.

    Comment added November 13, 2022 7:21pm
  • Cindy Hwang

    As a resident of New York City who is deeply concerned about the impacts of climate change, I believe that Local Law 97 must be implemented in full. Weakening the law would be tantamount to a betrayal of the city’s commitment to creating a sustainable future for its inhabitants. It is more than reasonable to ask the city’s heaviest polluters to cut back on emissions, especially when they are well resourced and therefore better positioned to do so.

    Comment added November 13, 2022 9:13pm
  • Karen Ghaly

    Hello my name is Karen Ghaly , I am 16 years old , I am from Egypt and moved to New York when I was 13. I now happily reside in Staten Island New York. I am a junior attending Curtis high school.

    Climate change is a force of anxiety in my life. As a New Yorker I’m reminded everyday through the litter, polluted air and lowering quality of life for inner city children. One of the most lethal meteorological phenomena is heat we all feel in the summer. Somebody should be held accountable for this. Life is at stake when weather and climatic trends change. Laws like local law 97 can not only hold our city accountable for its own actions against this planet but help New York make our real estate industry exceed in innovation.
    This is why I believe Mayor Eric Adams should fully implement and enforce local on 97. New York should also remain motivated to enforcing pollution limits by assessing the laws full penalties on building owners whose properties pollute over their caps.
    Thank you for reading and considering my opinion about the history of this great city.

    Comment added November 13, 2022 9:33pm
  • George Kontaroudis, NYPH

    At New York Passive House our vision is a carbon-neutral built environment for New York City, centered around the broad adoption and implementation of Passive House level building performance, achieving healthy, resilient, and durable buildings for all.

    LL97 is in line with our vision, mission and values and we strongly support the enactment of the law. We also acknowledge and applaud the extensive thought process that has gone into the drafting of the rules.

    We support the trajectory change from 80% to carbon neutrality by 2050, which is in alignment with the goals set by the UN and the Paris Agreement.

    We understand that the DOB is considering factoring occupant density in setting building budgets which we fully support and encourage. This way affordable and low income housing would have a more fair treatment relative to market rate or luxury residential projects that tend to have less density.

    We understand that the DOB is considering factoring in the time of use for electricity which we fully support and encourage as this would greatly benefit the grid. Perhaps emissions budgets could receive a benefit for buildings participating in the Demand Response Program.

    We further encourage the rulemaking process to add flexibility to the rules so that they, and the metrics contained in LL97, may be amended at regular intervals in response to evolving technology and environmental circumstances.

    We see New York City as a global leader in emissions standards and recognize LL97 as a tool of paramount importance.

    Comment attachment
    2022-11-14-NYPH-comments-on-LL97-Rules.pdf
    Comment added November 13, 2022 9:57pm
  • Reed Park

    Mayor Adams and the NYC Dept. of Buildings,

    I am Reed Park, a 10th Grader in New York City. I frequently visit parks in Brooklyn, and I have lived there for most of my life. One of my favorite hobbies is birdwatching, and I have been doing it in New York City for years now. However, global warming is severely affecting birds, threatening half of all species in North America. Local Law 97 is a great step in the right direction to help combat climate change.

    Global warming is a serious threat to migratory birds. Birds have been adapted to the environment for millenia, and are in parallel with the environment, weather, and changing seasons. Global warming will erode and change the natural environment that birds have been used to, and push them out of their natural areas, which will have a devastating effect on bird populations. According to the National Audubon Society, in the next century 314 bird species are predicted to lose 50% of their current range by 2080, and are at risk of extinction. For comparison, 9 bird species have gone extinct in the last 400 years. If nothing is done about climate change, birdwatching could become a thing of the past.

    The buildings of New York emit a substantial amount of carbon dioxide through energy usage like electricity, cooling, and heating. We cannot stall Local Law 97 any longer, we must take action now, for the future generations of New York City and the world. We can no longer value money over our planet, we must set an example for cities around the world and reduce our carbon footprint.

    I ask now, Mayor Adams, his administration, and the NYC Dept. of Buildings, please put Local Law 97 into effect and enforce it in the city. The longer we wait, the more our carbon emissions will affect the world and its environment. We must provide benefits for complying with the new law, and also have strict punishments for those who do not. We must act now, the future of our planet starts with us.

    Comment added November 13, 2022 10:29pm
  • R Small

    Cap the purchase of Renewable Energy Credits (RECs) and ensure that penalties are fully enforced. There must be a strict cap on the use and availability of RECs for building owners, to ensure that LL97 remains focused on driving on-site improvements in buildings, which will reduce local air pollution, generate thousands of local jobs and make our homes and workplaces healthier and more comfortable. Without additional limits, far too many buildings could choose to comply by purchasing RECs instead of making building upgrades.

    A strict limit on RECs will assist with aggressively reducing targeted emissions from the building sector.
    Incentivize building retrofits. The City needs to ensure it is offering incentives to help residential buildings make necessary upgrades.

    By maximizing the benefits of state and federal programs, NYC can ensure that building owners are receiving all of the possible benefits and have multiple options available to them. The City also needs to provide new financing tools and funding, while supplementing the ones that already exist for building owners, especially small-property owners.

    We need training and workforce development opportunities for high-quality, career-track employment and prioritize the communities who have historically suffered from air pollution. The City should take this opportunity to invest in successful union-linked pre-apprenticeships, apprenticeships, and certification training programs to fully support the growing clean energy industry and expand access to good green jobs to workers who have experienced pandemic job-losses.

    To keep alternate compliance dollars in buildings, the City should explore a new option to direct funds to efficiency and electrification in affordable housing. Paired with a limit on compliance through RECs, the city should explore a new option for building owners to pay into a fund that would deliver approved and additional efficiency and electrification upgrades in affordable housing.

    Comment added November 13, 2022 10:49pm
  • Kathy Malone

    A paper published last Thursday by the Department of Energy says we are on course to blow past the 1.5c threshold leading to climate catastrophe unless we ratchet up our climate policies. Read here: ​​https://www.nature.com/articles/s41558-022-01508-0
    Another set of projections also released last Thursday by Carbon Action Tracker said the same thing. Read Here: https://www.bloomberg.com/news/articles/2022-11-10/climate-projections-again-point-to-dangerous-2-7c-rise-by-2100?srnd=green&leadSource=uverify%20wall
    If we blow past our target there will be irreversible human and climate systems collapse. The more off the mark we are, the worse it gets and faster.
    Zoom in a little more to our state and city, if we don’t implement a strong Local Law 97, and tightly limit the handing out of Renewable Energy Credits, we will blow past our New York state climate law (the CLCPA) since buildings in NYC account for 70% of Green House Gas emissions in the city.
    We also put at risk over 140,000 good-paying jobs in the building upgrade and retrofitting industry. With the passage of the Inflation Reduction Act, that jobs number could be even higher.
    As much as we all love the real estate lobby, we must keep Local Law 97 strong for the health of our city and state and for more good-paying jobs.

    Comment attachment
    Keep-Local-Law-97-Strong-1.pdf
    Comment added November 13, 2022 11:31pm
  • Michelle Friedman

    Mayor Adams, I join in urging you to put your energy and that of your staff behind Local Law 97! You care about NYC and you are a smart politician. The climate crisis looms large and more and more voters care about emissions and the health hazards connected to them. Plus, backing LL97 creates good, green jobs for New Yorkers WHO VOTE.

    Comment added November 14, 2022 12:16am
  • Jessica Thompson

    It is imperative that Mayor Adams fully implement LL97 and not weaken it through rule-making. I am a parent of two children; it is our responsibility to put their chance at a livable future over short-term profits for the real estate industry. New York has a chance to lead on this issue, and we need to seize that chance.

    Comment added November 14, 2022 12:39am
  • Bill Murray

    The American Council of Engineering Companies of New York’s (ACEC New York) thanks NYC Department of Buildings for this opportunity to comment regarding the proposed rule.

    ACEC New York represents close to 300 consulting engineering and affiliate firms throughout New York, which collectively employee about 30,000 New Yorkers, with a concentrated presence in New York City. Our members engineer, design and plan the energy, mechanical, electrical, structural, fire protection, plumbing, environmental, civil and technology systems for buildings and infrastructure throughout New York.

    We believe the rule is a major step forward in defining the process for compliance and answering unknowns that had remained since passage of the law. We appreciate the detail and clarity in much of the rule. That said, our Energy Code Committee provides the following observations and recommendations regarding the rule:

    Recommendations:
    • DOB should issue the Reference Guide required by Local Law 97 in form of a DOB bulletin or rule. Local Law 97 establishes an Advisory Board (AB). The law requires the AB to recommend “A reference guide to delineate the responsibilities of the building designer and owners to comply with emissions limits.” Such a guidance document will be critical to stakeholders for various reasons, including to make stakeholders’ responsibilities and necessary coordination clear; and to serve as reference to identify accountability in the case of noncompliance with the law’s requirements, such that corrective measures may be identified. We therefore recommend this reference guide be published in a formal NYC DOB rule or bulletin.
    • Lowered emissions factors may impact capital plans already in progress. For many typologies, the emissions factors for 2030 are significantly lower than originally published, even inclusive of the lower emissions conversion factor for electrical utility consumption. This creates challenges for compliance and may impact capital planning that was set in motion based on the original law due to changes to emission allowances. Continuity related to 2030 penalties inclusive of lower emissions targets and lowered electrical conversion for all building typologies would add clarity and confidence for projects looking to make improvements going forward.
    • DOB should provide more detailed guidance on how to allocate Energy Star Portfolio Manage (ESPM) property types to various uses in the building. For example, how granular of a breakdown is allowed and/or required? How should space types not included in ESPM but included in the law be assigned (e.g. mechanical space, stairwells, etc)? Without clear guidance there will be inconsistencies in the reporting.
    • DOB should maintain responsibility for issuing Time of Use (TOU) hourly factors ILO of industry. The proposed TOU methodology is very complex and requires multiple datasets. Without an authoritative single source of TOU information, building owners will either choose to opt out of using TOU or there will be inconsistencies across the industry in calculation methods.
    • “Good Faith Efforts” should be defined. The proposed rule does not discuss the criteria or demonstration requirements for owners pursuing Good Faith Efforts to comply with the law. This is critical in a timely fashion for buildings facing 2024 penalties.

    Observations:
    • It is unclear how the rule will affect buildings that have already pursued and obtained an adjustment for excessive emissions, special uses, or not-for-profit hospitals. Suggest further clarity on when adjustments remain.
    • Please confirm that gross floor area will no longer need to be consistent with the reported gross floor area on file with the Department of Finance, which excludes below grade spaces and mechanical rooms.

    Comment attachment
    ACEC-NEW-YORK-comments-on-Proposed-Rule-re-LL97-compliance-and-implementation-details.pdf
    Comment added November 14, 2022 9:48am
  • Wendy Seligson

    LL97 is extraordinarily good for NYC as adopted. By mandating that buildings reduce their emissions, it reduces health-harming emissions throughout the entire city, which benefits all children and adults, especially those suffering from asthma. By improving buildings, it creates good green jobs that benefit all New Yorkers. It enbles NYC to do its part in reducing emissions that drive the climate crisis. Mayor Adams needs to get behind the letter and the spirit of the law to the fullest. RECS should not be allowed. If they are adopted, there should be very tight limits on the purchase of RECs and the City must impose fines that deter building owners from polluting over their caps.

    Comment added November 14, 2022 9:56am
  • Joe Rose

    Please Provide better calculating tools so we can be in the know if our investments are worthwhile and are reducing emissions.

    Comment added November 14, 2022 10:32am
  • David Sivin

    As an engineer and energy consultant centering his profession around electrification and energy-conservation of buildings in NYC, I’ve applauded this legislation since Day 1 and am excited to contribute towards curbing climate change in this city. However, I do believe that optics plays a critical role in how non-enthusiastic stakeholders (typically, building owners and landlords) come to the table and do their part.

    I’ve heard several building owners say something to the effect of “LL97 is just another NYC DOB cash grab”. Sure, the annual penalties from LL97 will be a source of necessary revenue for DOB to operate. However, if building owners (and even tenants) see that the aggregate annual LL97 fines from all buildings only contribute to DOB’s operating expenses, how is this revenue contributing to combating climate change, beyond just incentivizing building owners to do the right thing? Is there some sort of stream/mechanism that will funnel fines from LL97 penalties into climate mitigation or energy resilience projects such as using these fines to A) increase funding to energy incentive programs, B) investing in increasing/fortifying ConEd’s electrical infrastructure throughout the city to prepare for increased electrical demand, or C) fund research into clean-heat technologies? The way I see it is, if there are a lot of fines to come in any one year, that’s a strong indicator that buildings overall need some help. That help can effectively mean the fines directly fund energy resiliency projects, and not just stop at NYC/DOB’s operating expenses. As of now, the optics of this law make stakeholders think that their fines end up in DOB and don’t go anywhere further, and the key stakeholders (building owners) will be less inclined to do their necessary part.

    So, I ask, is there some mechanism in place to dedicate the LL97 fines into energy resiliency projects? I think this a proportionally reasonable and ethical facet to the law.

    Thank you,
    David Sivin (PVE Engineering) – New York, NY

    Comment added November 14, 2022 10:44am
  • Wayne Swenson

    1. Topic: Marginal fuel spot price
    o Comment/Question: There are multiple marginal fuel spot price sources, please provide guidance on preferred marginal fuel spot price source.
    2. Topic: Reporting tool
    o Comment/Question: Will DOB provide a Reporting Tool – if so, please provide in advance of 2024.
    3. Topic: Annual emission factors
    o Comment/Question: The DOB did not provide coefficients for every space type available in Energy Star. Most of these are municipal types but some aren’t. Please provide guidance on how to address those.
    4. Topic: Penalties beyond 2050?
    o Comment/Question: Are penalties going to continue beyond 2050?
    5. Topic: Diesel and fuel delivery
    o Comment/Question: Please provide additional guidance on how DOB intends to document/record diesel (and oil) delivery. Deliveries may occur at end of year but is actually consumed in the following year, please provide allowance to reasonably split usage across two years.
    6. Topic: Greenhouse gas coefficient for utility electricity based on time of use
    o Comment/Question: Practically speaking, time-of-use calculations do not seem feasible for direct-metered multifamily buildings unless con Ed provides hourly aggregate data. Please consider this challenge. Will mixed-use buildings be able to take a TOU approach for certain portions of the building building while using standard methodology for the rest?
    7. Topic: Greenhouse gas coefficient for subscription to off-site solar energy generation.
    o Comment/Question: Please provide additional details on how the greenhouse gas coefficient for subscription to off-site solar energy generation will work (e.g. how a building should document).

    Comment added November 14, 2022 10:44am
  • Brooklyn Borough President Antonio Reynoso

    Comments submitted to NYC Department of Buildings
    Rulemaking regarding implementation of Local Law 97 of 2019
    November 14, 2022

    Thank you for the opportunity to submit comments today on the proposed rules for implementation of Local Law 97 of 2019 (LL97). As a member of the City Council in 2019, I supported this transformative legislation, and now as Brooklyn Borough President, I am looking forward to the positive impacts it will have on our city. New York City has the opportunity to become a global model for climate resiliency, and I want to ensure that the proposed rules being considered today include measures to protect tenants and create equitable change.

    LL97 is the most ambitious building emissions legislation passed by any city in the world, and the residents of New York City should be proud to firmly commit ourselves to a greener, more resilient future. Electrifying our building stock, fortifying our city’s resiliency, and reaching zero-emissions should be our top climate priorities, and the pioneering emissions caps enacted through LL97 set us on the right path to achieve these ambitious – but necessary – goals. Buildings are responsible for two-thirds of New York City’s annual emissions, and it is our duty to tackle this to protect our most vulnerable communities and secure an exciting, green New York City for future generations.

    The proposed rules for LL97 provide much to look forward to on our journey to zero emissions. The emissions limits for each property type from 2030-2049, along with the zero-emissions requirement for all buildings after 2050, puts New York City in alignment with global 1.5℃ climate targets. I also support the proposed 2030 electricity carbon coefficients that consider the exciting new clean energy sources coming to New York City over the next few years, and that work to more urgently reach New York State’s decarbonization goals.

    Incentivizing building electrification is crucial to meeting these carbon caps, and any additional incentives for electrifying our building stock are welcome. Also, the availability of renewable energy credits (RECs) for purchase by building owners to offset building emissions is integral to developing strong, local green power. Requiring that these credits only offset emissions specifically sourced from building electricity use guarantees that the RECs will not be used to deduct from emissions due to fossil fuels burned for heat and hot water. These features of LL97 put us on the right path to achieving our climate goals, and I thank climate advocates and City leadership for prioritizing emissions reductions in our collective fight against climate change.

    However, there remain some areas of concern that we, as a city, should make sure to address so we can enact the transformative changes we need to rapidly decrease emissions.

    First, regarding renewable energy credits, allowing for property owners to purchase RECs to offset 100% of emissions creates a dangerous loophole that jeopardizes the law’s productivity. We must be wary of a system that allows for owners to simply pay their way out of doing the difficult work of eliminating building emissions if we want to actualize climate goals with the urgency that the issue requires.

    Second, in the face of substantial building upgrades and retrofits, we must continue to protect tenants, particularly those of lower income and in rent-regulated units. As the scale and cost of capital improvements increases, we want to avoid displacement as much as possible. Investments in clean energy and emissions should never force individuals and families out of their homes; a sustainable future is an equitable one, the choice should never be one or the other. That is why I insist that financing for building upgrades must be tied with tenant protections. To facilitate this and to keep costs down for building owners, New York City should create a fund tying the money raised through enforcement fees directly to supporting more retrofits and lowering the capital costs of transformative building upgrades.

    Lastly, as with any large-scale change, education and outreach remains key. Currently, many building owners do not know about their coming obligations under LL97. They also don’t have easy access to information, such as how to find and afford financing for upgrades and retrofits, or to identify viable contractors. A cohesive energy transition will require much more robust outreach. Building owners’ obligations should be clear to ensure full compliance, and the resources for support should be readily available in multiple languages.

    Local Law 97 provides the groundwork needed to reach New York’s climate goals. We cannot provide a greener NYC to current and future generations without quickly reducing, and eliminating, our buildings’ GHG emissions and electrifying our building stock. Given the importance of this charge, we must make sure the law is as effective, equitable, and sustainable as possible. I am excited and immensely proud about the climate progress that we, as a city, stand to make in the next few years, and I hope these concerns are taken into consideration. Thank you.

    Comment attachment
    BP-Reynoso_Local-Law-97-Comments-Final-11.14.22.pdf
    Comment added November 14, 2022 11:01am
  • Angelina S

    Hello my name Angelina S. and Im a sophomore in high school living in the Stapleton neighborhood in Staten Island New York.
    I was educated on LL97 through my neighborhood local Treeage hive. Laws like local law 97 can not only hold our city accountable for its own actions against this planet but help New York make over 40,000 jobs. Jobs that people in my community need. Mayor Eric Adams should fully implement and enforce local on 97. For the sake on Staten Island and the whole city.

    Comment added November 14, 2022 11:02am
  • Rachel Landsberg

    I am a parent and a proud New Yorker. I care about the future of our city and applaud the efforts we have made in our city to plan for and protect that future; passage of LL97 is an example of steps we have taken in this past time period. Mayor Adams should fully enforce LL97 to reduce emissions in NYC and to create good, clean jobs for our workers.

    Comment added November 14, 2022 11:06am
  • Mordi Tal

    LL97 is very important and should be enforced to reduce our emissions. we need to help the owners to comply and reduce the emissions and if they show proof of work being commenced a reduction of the fines should be given. helping will work much better then just penalizing

    Comment added November 14, 2022 11:12am
  • Chris Halfnight

    Please see the attached comments DOB’s Proposed Rule 103-14 on Procedures for Reporting on and Complying with Annual Greenhouse Gas Emissions on behalf of Urban Green Council, Association for Energy Affordability (AEA), Natural Resources Defense Council (NRDC), New York League of Conservation Voters, and the Regional Plan Association.

    Comment attachment
    LL97-Proposed-Rule-103-14-Comments_UGC-AEA-NYLCV-NRDC-RPA-.pdf
    Comment added November 14, 2022 11:21am
  • Lee Gough

    We cannot allow Blackstone and greenwashed REC project developers to capture NYC regulatory processes as they define GHG emissions rules in regulatory definition processes like this one. Commissioners would be wise to create a strong impression and rule set that does not privilege the economic interests of NYC developers and private equity by reifying a loophole-filled rule that does not substantially lead us further in climate goals. Specifically, Blackstone, other polluters and the real estate industry are seeking to exchange ill-defined RECs for site emissions reductions. This does grave to people and planet in so many ways. For example , in my disadvantaged community that drinks, bathes and books with Hudson River water, Blackstone’s REC-granted transmission project called the Champlain Hudson Power Express will transmit NY ratepayer subsidized foreign owned and generated hydropower (not green, not renewable) to NYC. Trading emissions for such RECS will only lead us further down the path of environmental destruction of a precious and dwindling resource (water and watersheds) while potentially violating the CLCPA’s goals of not creating any sacrifice zones (upstate NY and on unceded First Nations land and water in Canada where the dirty hydro is produced). We can do better by looking very closely at both procedures and reporting of compliance with GHG emission standards. First of all, create conditions for RECs that maximize efficiency at the site level and close all loopholes which exclude mainly building types whose investors have lobbied heavily be excluded from regulation. Second, RECs should be locally produced renewable energy without subjecting people and their communities outside of NYC to injustice.

    Comment added November 14, 2022 12:19pm
  • Georgi Page

    (see attached)

    Comment attachment
    Local-Law-97-DOB-Public-Comment.pdf
    Comment added November 14, 2022 12:34pm
  • Lucas Chen

    Hello.

    My name is Lucas Chen and I am a junior in high school. I also am a member of TREEage, a youth based climate organization.

    I’ve lived in Manhattan since I was three years old and I’ve spent every winter in the city. Each year I have less of an opportunity to go outside and see the snow with my family and friends, and the inconsistent weather due to climate change makes it harder to enjoy the city during the year. I’ve seen increased displacement of familiar faces in my neighborhood as severe weather forces them to move away from our coastal environment.

    Over the years I’ve noticed a lot of changes being made in the city to combat climate change. However, the buildings I pass each day always have C and D energy efficiency gradings, and their energy efficiency gets worse with every year. This is because no one is holding them accountable for their energy emission and increased use of fossil fuels. As our mayor, Eric Adams has the power to enforce this accountability, Local Law 97 was written for this purpose. This is why I urge Mayor Eric Adams to uphold and enforce Local Law 97; for my future and for everyone else’s.

    Comment added November 14, 2022 12:53pm
  • Amy Turner, Sabin Center for Climate Change Law at Columbia Law School

    I have attached detailed written comments about two problems with the Local Law 97 REC compliance mechanism as currently contemplated by the law and these proposed rules: (1) lack of additionality and (2) oversupply leading to too low a price. Both have caused other carbon market mechanisms to fail in meeting their GHG reduction goals. More details are in my written testimony, attached. Thank you.

    Comment attachment
    Amy-Turner-Sabin-Center-DOB-LL-97-Rule-103-14-Testimony-Nov-14-2022.pdf
    Comment added November 14, 2022 1:39pm
  • Noah Gallimore

    I have lived in Coney Island for most of my life and although I do not live there anymore, there are high emissions in the area due to the industrial buildings and factories near by. These factories create a smog that pollutes the local area including the beach and the general quality of the air. With LL97, we can reduce the emissions that are made and increase the quality of life for residents in the area or people who would like to enjoy the local tourist attractions.

    Comment added November 14, 2022 1:48pm
  • Lucia Santacruz

    Urban Homesteading Assistance Board (UHAB) thanks the NYC Department of Buildings for the opportunity to comment. For 47 years, UHAB has been creating, preserving, and supporting resident controlled housing. We work with low and moderate income residents in housing cooperatives, known as HDFCs, as well as tenant associations to build leadership, democratic participation, and community through cooperation.
    UHAB is part of the Climate Works for All campaign because HDFC communities are on the front lines of the climate crisis. Most HDFC residents are disproportionately impacted by the legacies of redlining, disinvestment, and deteriorating buildings, and many HDFC residents live in the areas of the city most vulnerable to rising sea levels and increasingly dangerous urban heat islands.

    We are calling for the city to cap the purchase of Renewable Energy Credits (RECs) and ensure that penalties are fully enforced. Limiting RECs to electricity is a step in the right direction, but without additional restrictions RECs could severely undermine the impact of LL97. There must be a strict cap on the use and availability of RECs for building owners, to ensure that LL97 remains focused on driving on-site improvements in buildings, which will reduce local air pollution, generate thousands of local jobs and make our homes and workplaces healthier and more comfortable. Without additional limits, far too many buildings could choose to comply by purchasing RECs instead of making building upgrades. A strict limit on RECs will assist with aggressively reducing targeted emissions from the building sector.

    Additionally, we want to highlight that to keep alternate compliance dollars in buildings, the City should explore a new option to direct funds to efficiency and electrification in affordable housing. Paired with a limit on compliance through RECs, the city should explore a new option for building owners to pay into a fund that would deliver approved and additional efficiency and electrification upgrades in affordable housing. While exploring an option for such a fund, the City should consider mechanisms that prioritize implementation in EJ communities and do not disincentivize compliance but provide relative relief from fines.

    Comment added November 14, 2022 1:52pm
  • John Moynihan, Chair Northeast Clean Heat & Power Initiative NECHPI

    The Northeast Clean Heat and Power Initiative (NECHPI) respectfully submits the following comments in response to Department of Buildings (Hereafter, “DOB”) proposal to add a new rule 103-14 to implement Section 28-320 Chapter 3 or Title 28 of the New York City Administrative Code by establishing the procedures for reporting on complying with annual greenhouse gas (GHG) emissions limits for buildings (“DOB’s New Rule”).

    Comment attachment
    NECHPI-Comments-on-NYC-LL97-Proposed-Changes-FINAL-2022-11-14.pdf
    Comment added November 14, 2022 2:38pm
  • John Moynihan, Chair, Northeast Clean Heat & Power Initiative NECHPI

    The Northeast Clean Heat and Power Initiative (NECHPI) respectfully submits the following comments in response to Department of Buildings (Hereafter, “DOB”) proposal to add a new rule 103-14 to implement Section 28-320 Chapter 3 or Title 28 of the New York City Administrative Code by establishing the procedures for reporting on complying with annual greenhouse gas (GHG) emissions limits for buildings (“DOB’s New Rule”).

    Comment attachment
    NECHPI-Comments-on-NYC-LL97-Proposed-Changes-FINAL-2022-11-14-1.pdf
    Comment added November 14, 2022 2:43pm
  • Council Member Sandy Nurse

    See comments attached.

    Comment attachment
    CM-Nurse_LL97-Comments-to-DOB_Nov2022.pdf
    Comment added November 14, 2022 2:43pm
  • Daniel Mulligan

    Attached, please find comments on behalf of Steamfitters Local 638 on the importance of limiting REC use for Local Law 97 compliance, and ensuring that implementation and enforcement of the law is a means for both reducing emissions and maximizing job creation for the unionized trades.

    Comment attachment
    LL97-Rules-Steamfitters-Local-638.pdf
    Comment added November 14, 2022 3:03pm
  • Jenna Tipaldo

    We need action on climate change now – we must take actions to mitigate the worst impacts by reducing our greenhouse gas emissions in a timely manner. A large source of NYC’s emissions is buildings and Local Law 97 is critical to ensure that the city can reduce its emissions. This rule can help clarify and implement the law to expedite said emissions reductions.

    I am commenting as an individual who organizes with Sunrise Movement NYC, but I am also someone who has professional familiarity with the subject of climate impacts. My work as a PhD student and as a fellow focuses on the health impacts of climate change, of which there are many, including due to heatwaves, food/water insecurity, infectious disease, and storms. I have read several IPCC reports cover-to-cover and countless peer-reviewed articles about the potential impacts of climate change and the devastation that can be reduced by urgently cutting greenhouse gas emissions locally and across the globe, and am working on my own research on how human health is impacted by anthropogenic climate change.

    As a lifelong New Yorker, I’ve seen the impacts of climate change firsthand as well – my neighborhood and my family were impacted by Hurricane Sandy in 2012, displacing us from our home for 7 months, and some of my friends were severely impacted by Ida in 2021. Experts estimate that for Hurricane Sandy, climate-related sea level rise may have added $8 billion in damages (https://www.nature.com/articles/s41467-021-22838-1). Parts of the city like south Queens experience regular ‘sunny day’ or ‘blue sky’ flooding exacerbated by sea level rise and more frequent/severe coastal storms. Heatwaves have also become more frequent and severe in my lifetime, impacting my asthma and limiting my physical activity.

    Cutting emissions can not only reduce the negative impacts of climate change but it also can have co-benefits for health by reducing the amount of particulate matter and other pollutants in the air that result from burning fossil fuels. Air pollution has major health implications, contributing to excess deaths and exacerbating conditions like asthma (here is a peer-reviewed study that attempts to quantify benefits/ harm avoided by reducing greenhouse gas emissions in NYC: https://pubs.acs.org/doi/10.1021/acs.est.0c00694).

    Thank you for your time and consideration of this rule regarding Local Law 97.

    Comment added November 14, 2022 3:23pm
  • Sean Rustowicz

    Hello, I was wondering if there could be more clarification regarding the TOU calculations, mainly how and where certain required data entries should be acquired. For example, is there an ideal place to pull the GHG Coefficient for a Marginal Fuel at a given hour (g sub n)? Any clarification would be greatly appreciated.

    Comment added November 14, 2022 3:45pm
  • Amit Shah

    I think LL97 should include the ability for buildings who do more than the emission cap requires them to do to be able to trade those carbon credits. This will ultimately allow for them (buildings) to push to do more work up front and help NYC lower their carbon emissions faster. If the building can trade the difference in the extra work, they can help pay off the work and are more likely to take on a bigger expense upfront. We need to help the buildings pay these large assessments off. With interest rates going up, this can be a good way to stop gap and help offset the overall cost.

    Comment added November 14, 2022 4:08pm
  • Solomon Blecher

    My name is Solomon Blecher. Local Law 97 is very important for me because I really care about climate change. At first, I didn’t really know what climate change was. Then, I was told, when I was 7, I believe, that it was “something bad” that “will destroy everything” and also was created by driving. At the time, I was satisfied with that explanation. But later, I wanted to investigate that further. A couple of years later, I learned that burning fossil fuels was the main cause of climate change. This led me to believe that we all need to work together to stop climate change. But I was a kid. Kids couldn’t affect this problem for grown-ups, as society has told us. Maybe in the future. But then I realized that kids can make a change. Maybe not a lot, but they can be inspirational to adults. I guess adults look up to kids who know right from wrong, at a young age.
    So then I started to fight for climate action. Not a lot, but sometimes, and I recognized it as a problem that needs to be fixed. As more research came out about how “Climate Change is Worse than We Originally Thought”, I caught on to the idea that climate change wasn’t an issue affecting a few vulnerable places, but everywhere. If it’s always worse than you thought, experts, then I guess climate change must be worse than you think now. Indeed, it is a worldwide crisis destroying humanity.And LL97 is a way to fight climate change. Making buildings–the most polluting things in New York City, more renewable, is extremely important and urgent. Therefore, I urge you to enforce Local Law 97, fight climate change in New York City; and be a model for other cities as well.

    Comment added November 14, 2022 4:36pm
  • Haym Gross

    I am chair of the NYC 2030 District is a Private / Public Partnership of property owners and community stakeholders which leverages financing, public support and collaborative action to spur sustainable innovation and progress. We implement the NYSERDA-funded, Brooklyn Borough Pres. sponsored Heat/Cool Smart Brooklyn community retrofit campaign:  https://heybrooklyn.org/

    Strict LL97 enforcement to drive retrofits is essential, but more incentives and comprehensive support is required. NYC Land Use and Economic Development policies should be aligned with LL97 goals.   We support the proposed limitation of REC offsets, as recommended by many climate groups, while urging the expansion of clean distributed energy installations in NYC. The projected carbon valuation of grid electricity for 2030 to include anticipated renewable energy resources is too optimistic, and may reduce the incentive of property owners to perform energy efficiency work. The grid’s carbon intensity should only be revised once carbon reductions are achieved. NYC must support climate initiatives at the community scale to engage public-private partnerships; to integrate and streamline access to NYS & NYC programs, bond funding and private financing options; and to bundle small and large projects together to drive climate progress and distribute benefits widely. 

    Community Scale Initiatives are necessary to accelerate successful and innovative projects for buildings, infrastructure, public engagement and behavior.
    Project Aggregation drives implementation of building energy improvements, economic development benefits and workforce training opportunities through critical mass of engagement, economies of scale and streamlined project management.
    Integration of Technologies & Solutions produces complementary performance benefits and whole-building. 

    Multi-family buildings have few resources to meet the targets, particularly Small & Med. sized, and middle & moderate income buildingsAggregated and streamlined programs with substantial funding can move retrofits to high gear, expand equity and economic development benefits.Technical assistance and public education resources are needed to make progress. The NYC Accelerator, PACE financing and carbon trading are not sufficient.

    The implementation of LL97 is an opportunity for Mayor Adams to show vision and to exercise leadership to advance innovation, community engagement and civic collaboration to meet the climate challenge, not to allow property owners to evade the responsible investments to improve building performance.

    Respectfully Submitted,

    Haym  Gross
    A r c h i t e c t
    Founding Member, 
    NYC 2030 District 

    Comment attachment
    Haym-Gross-NYC-2030-District-Testimony.11-14-22.pdf
    Comment added November 14, 2022 4:59pm
  • Ethan Dubin

    This is not about implementing fees and penalties, this is about lowering greenhouse emissions, and eliminating loopholes.

    Local Law 97 needs to be bulletproof. On the recent 10-year anniversary of Hurricane Sandy, the city could barely make the case that it had made repairs, let alone necessary preparations for the next superstorm.

    Local Law 97 is preparation against the next superstorm Sandy. And when that storm comes, the ambitious and demanding pace and scope of this law must continue. Its enforcement and a stringent definition of good faith efforts for buildings must be upheld.

    During the record heat of this past summer, I spent my weekends canvassing in the primary elections. That meant most of my time was in buildings over 25,000 sq.ft. with Energy Star ratings of ‘D’ or ‘F’, in other words, the sleeping giant of LL97. The unventilated and poorly designed hallways of these buildings were so hot I often wondered if I would faint. Air conditioning from costly, inefficient systems could be felt gushing out from under doorways lucky enough to have them. Tenants were miserable and suffering.

    A building owner who recently renovated her home said the sustainability improvements they did made her home feel not just eco-friendly, but “high performance.” The function and feel of such a building improves the quality of life for the residents and their neighbors in vastly under-estimated ways–their physical, mental, and ultimately financial health too, as retrofits are essentially guaranteed to dramatically lower energy bills and recoup money overtime.

    This is just partly why we must ensure that Local Law 97 must not fail to drive on-site building improvements and bring local benefits. Robustly implemented and enforced, the law will reduce air pollution, generate tens of thousands of green union jobs, and could even divert funds towards affordable housing. This is why so many activists are here today, at an otherwise obscure DOB hearing.

    Without further restrictions or perhaps even total removal, RECs remain an extremely significant threat to LL97. I am glad the law now sets a goal of zero-emissions by 2050. But what is the path toward this goal if, as the UGC recently estimated, more than one quarter of multifamily properties currently above their 2030 caps and two-thirds of office properties currently above their 2030 caps could comply with the 2030 limits through RECs alone (without undertaking any building improvements).

    Some flexibility in compliance options for building owners who have demonstrated legitimate good-faith efforts is not a bad thing. But I have zero sympathy or patience for the complaints of the profit-maximizing real estate industry that will exploit any available loophole the Adams administration allows them. I used to work for a property management company in this city and I deliver that opinion from firsthand experience.

    Additionally, alternate compliance dollars should be kept in buildings that need it most–I urge the Mayor’s office to divert this money to efficiency and electrification upgrades in affordable housing. This can be accomplished by an equitable fund that will prioritize environmental justice and keep improvements local. Seattle and Boston have working models of these laws and funds. It can be done, if the Adams administration refuses to entertain the profit-seeking Real Estate Lobby above the needs and hopes of the people of New York City.

    Comment added November 14, 2022 5:06pm
  • Cecilia Pavia Camacho

    Hello my name is Cecilia I am 16 years old and live in West Brighton community on Staten Island. Local law 97 is an important and necessary action New York City needs to take in order to fix our environment. LL97 will also bring hounders of union jobs to my neighborhood. It will also make our buildings more environmentally efficient.
    I’m calling on mayor Eric adams to take action against this crime on the environment.

    Comment added November 14, 2022 5:07pm
  • mya b

    Climate change is happening faster than we all could have imagined. At this point there is almost no reversing it, so we must take every measure we can to help slow it down. Law 97 is a big step in the right direction because of its promise to try and limit greenhouse gas emissions. With this act in place, we are able to track and regulate the harmful gases in our environment.

    Comment added November 14, 2022 5:23pm
  • Amy Fass

    New York can make a major contribution to pollution reduction with Local Law 97. We need to make sure that reduction is as great as possible, so it should not be limited by letting property owners buy Renewable Energy Credits instead of actually taking action to make their buildings emit less pollution.

    Comment added November 14, 2022 9:13pm
  • Elizabeth Larsen

    After reviewing the proposed update to Local Law 97, I have the following questions.
    1. Why, if the City is promoting electrification (via LL154), is the GHG Coefficient for the Electricity Grid higher than those of other fuels? This seems counterintuitive to promoting the use of electricity. As an example, the City of Boston has defined in their BERDO 2.0 language (a similar policy to LL97) an Electricity Grid Emissions Factor that is estimated for 2035 to highlight the need for and promote electrification.
    2. Given the current NYC Fire Codes, are batteries considered a viable option for this law?
    3. How will “good faith efforts” be defined? I find this language will give many the option to get out of fines or other consequences of inaction.
    4. When will reporting structures be defined for this law? We still don’t know how this will be done and this has caused confusion within the building industry.
    Thank you.

    Comment added November 14, 2022 10:39pm
  • yedidye

    We are doing all we can to lower carbon emissions, but will not know whether these efforts are paying off until we see our tenants’ usage at the end of the year. If we show we are taking steps to reach target emissions levels, please take this into consideration and don’t fine us for the following year.

    Comment added November 15, 2022 1:59am
  • Michael Bobker

    Comments are submitted on behalf of the Association of Energy Engineers, NY Chapter (AEE-NY). Comments address various technical procedures outlined in the Rule where we believe improvements are possible.

    Comment attachment
    22-1114-LL97-Rules-AEE-NY-Comments-Submission.pdf
    Comment added November 15, 2022 4:51am

Comments close by November 14, 2022

Add a comment

Notes. "Required" indicates a required field. Your email address will not be made public.