Luthin Tunes_LA Confidential_Winter 2020

Navigating Local Law 97 of New York City’s Climate Mobilization Act

A major challenge for building managers in New York City is on the horizon: hard limits on their facilities’ greenhouse gas (GHG) output. New York City’s Climate Mobilization Act (CMA), specifically Local Law 97 (LL97), requires that thousands of non-residential buildings with more than 25,000 gross square feet show that they do not exceed those limits. It covers all commercial and institutional facilities, including industrial properties not involved in producing utility power or steam. Even Foghorn Leghorn, never at a loss for words, had to stop and take a breath after hearing about this new legislation.

LA Confidential January 15, 2020

Passed in April 2019, the CMA’s cornerstone, LL97 takes effect in 2024 for penalties assessed in 2025seeks to greatly accelerate city-wide reductions in GHG emissions. But is it truly a Road Runner, or just another regulatory maze for building managers to navigate?

Assessing Your Facility’s Position

According to City stats, many commercial and institutional properties presently comply with the carbon limits that start in 2024, but many more will not in 2030 when those thresholds are cut roughly in half. To see how far you may need to cut, check your 2018 Portfolio Manager (PM) report, (i.e., your Local Law 84 compliance document), to see your GHG kilograms/SF. You can also go to Urban Green Council’s Metered New York website ( and enter your 10-digit building-block-lot (BBL) number, without its hyphens.

A quick look at a few institutional and office sites found some below – and a few above – 2024’s 8.46 kg/SF/yr. limit, i.e., .00846 metric tons (MT/SF/yr.)., which is about 18.6 lb./SF/yr. That quick look found none that could comply with the law’s 2030 limit of 4.56 kg/SF/yr. (i.e., ~10 lb./SF/yr.). However, if the power grid gets super clean by 2030 from, e.g., oodles of local offshore wind power, meeting such limits may not be impossible.

Violators could see hefty fines, amounting to hundreds of dollars per ton over their annual limits. For a large office building, that could be hundreds of thousands of dollars a year. A consistent failure to comply could elicit a misdemeanor charge.

So, What Do You Do?

One of the most cost-effective options to cut GHG by a few percent often involves tightening up building operations. Have a professional re-commission your energy management system by tuning and fixing existing controls.

Before LL97 takes effect, all NYC buildings should have smart meters that show power use in 15-minute increments. Use them to pinpoint equipment that runs during off-hours that could be shut off, cycled, or timed out.

Asking “What’s up in your ceiling, doc?”, Bugs Bunny points out that upgrading fluorescent lighting to LED could cut that load’s GHG by 50% or more, making it one of the first and most cost-effective options. For more details, read the article “Time to Look Again at Your Lighting” elsewhere in this newsletter.

In the 2024-2029 period, simply switching boiler fuels might help secure compliance, assuming new natural gas service remains readily available in the City. Oil-heated buildings may cut boiler-related GHG by 25% or more using gas which produces less GHG for the same heat output as oil and a higher efficiency burner or boiler.

Never at a loss for clever schemes, Wile E. Coyote suggested going straight to an electric boiler, based on the notion that – someday – grid power will be far cleaner than it is today, and surely cleaner than any fossil fuel. However, as with many of Mr. Coyote’s ideas, switching to electric resistance heat with today’s grid power could make things worse, in this case, due to inefficiencies in power production and delivery.  Do not even ask what Daffy Duck suggested.

While installing combined-heat-and-power (CHP, aka cogeneration) using natural gas generators may actually increase GHG emissions, well designed CHP systems are more energy-efficient overall as they utilize otherwise wasted heat for productive purposes such as hot water and space heat. For many businesses, including financial and transaction processing, hospitals and health care, data management, and research facilities, power quality and reliability are paramount concerns. In such cases installing CHP may be the investment option to ensure the reliability and resiliency or your operations.

Ground-source heat pumps might work for small and low-rise buildings, but skyscrapers lack the necessary footprint to do the job.

Getting Started

A professional energy assessment (aka an energy “audit”) will help you find the most cost-effective options. Be sure that the spec for that work focuses on options that reduce GHG, not just operating costs. While there are many options that do both, some (e.g., those primarily cutting peak demand) may save money but do little to reduce power consumption, and thus the kilowatt-hours (kWh) that lead to GHG production at power plants. Variable speed drives may do just the opposite: while monthly peak demand may not drop by much, total fan and pump kWh consumption may fall significantly.

Be sure that on-site renewable power production from solar panels is considered among the options, especially if roof space is available, regardless of size. Costs for panels and installation have dropped significantly in the last few years, such that replacing utility power with on-site solar is often a good investment.

Once a clear path to compliance with the LL97 is established, you are on your way to having Porky Pig say “Th-th-th-that’s all, folks!”