Is It Too Late to Start On My Local Law 87 Compliance for 2019?

Before there was a Green New Deal in New York City, there was Local Law 87, which requires an energy audit and retro-commissioning report to be conducted and filed every 10 years. Yes, it still applies, and yes it will help you to understand the most cost-effective retrofits and upgrades to target for compliance with the city’s new energy efficiency requirements. Thanks for asking!

The question we get most this time of year from owners in NYC is, “My building is due for LL87 compliance this year, is it too late to start?!”

Image of Commercial BuildingsAs spring arrives, building owners often realize that time is quickly running out and this is the year that they must submit their building. Compliance with NYC’s LL87 (Local Law 87) can be overwhelming and hard to navigate but we are here to help.

Not sure if you have to file?  Check here.

LL87 requires that a building undergo an energy audit and retro-commissioning of major mechanical equipment. Keep in mind that it takes time to perform the inspections and testing. In fact, your best bet is to start in the year before your deadline, leaving yourself plenty of time for planning, budgeting, and implementing any corrections that may be required.

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What Does NYC’s Climate Mobilization Act Mean for Building Owners?

Image of Existing Buildings in NYC

On April 18th, Introduction 1253-2018 was approved by the New York City Council along with several other major pieces of legislation as part of a Climate Mobilization Act. The Urban Green Council describes it as “arguably the most disruptive in our lifetime of the NYC real estate industry.” We agree. While it will take some time to more precisely gauge impact across the industry, here is an initial primer.

Context

Previous building energy legislation in NYC has focused primarily on providing the market with access to information in the form of benchmarking and audits. In response to increasing demands for more urgent climate action, this new local law will actually require energy performance levels – and significant retrofits in some cases – in most existing buildings over 25,000 square feet between now and 2030 and deeper reductions beyond 2030.

How It Will Work

The law establishes targets for carbon-emissions intensity per square foot for buildings based on occupancy class. For instance, multifamily buildings, office buildings, schools, and storage facilities will have different intensity targets. Mixed-use buildings will have their targets set based on a weighted average of their different spaces. Across all segments, these targets will get ratcheted down over time. Building on the type of data submitted as part of annual benchmarking, all tenant and owner energy used at a particular building will be converted to carbon intensity per square foot.

Starting in 2024, buildings will be fined on an annual basis for carbon footprint that exceeds their targets. Based on their performance today, approximately 20% of buildings exceed the 2024 – 2029 targets while approximately 75% of buildings exceed the 2030 – 2034 targets, according to the City Council’s press release. As an alternative to this performance-based framework, rent regulated multifamily buildings with at least one rent stabilized apartment will be required to implement a prescriptive list of upgrades by 2024. These upgrades include indoor temperature sensors providing feedback to boilers and apartment thermostatic controls.

What It Will Mean to the Market

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ERV + AHU?

Everyone pretty much gets that continuous (or very frequent) ventilation is necessary in high-performance homes. And – at least in theory – most people get why balanced, heat recovery ventilation is better (than unbalanced and/or without heat recovery). But the devil’s in the details.

A couple years ago we started an R&D project with funding from DOE’s Building America program, and one of the first steps was interviewing several developers about ventilation (single- and multi-family residential, mostly on the East Coast). For none of these developers were HRVs or ERVs standard.[i] They all had some experience with ERVs, however, and when asked about these experiences the word “nightmare” came up shockingly often.

The ERVs on the market now can certainly work well in the right application, but we see problems more often than not. One of the biggest challenges is trying to add ERVs on to central heating/cooling systems in homes. Most ERVs aren’t really designed for this, and here’s what we see:

  • Ducts connected to the wrong places! Outlet and inlet ducts get reversed, or the supply air from the AHU getting exhausted (sad how often this happens).
  • ERVs are attached to supply and/or return trunks of the AHU. Unless the AHU fan is running constantly (or whenever the ERV is turned on), outdoor air comes into the AHU and is sucked right back out the ERV exhaust.
  • If the AHU fan is turned on, the relatively small fans in the ERV can’t successfully compete with the big AHU fan. People don’t get the ventilation flow rates they want and/or the flows are very unbalanced.
  • AHU fans can use A LOT of electricity. Hundreds of Watts is common – I’ve measured over 1 kW (though this is changing – more below).

Even if installers follow manufacturer instructions for attaching ERVs to AHUs, they could still end up with low flows, unbalanced flows, or high electricity consumption. Through this DOE R&D effort, we’re trying to do better.
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Here’s What DC’s New Energy Efficiency Requirements Mean for Existing Buildings

Mayor signing legislationDistrict of Columbia Mayor, Muriel Bowser, signed a landmark piece of legislation known as the Clean Energy DC Omnibus Amendment Act this past Friday. With the mayor’s signing, Washington, DC becomes one of the first jurisdictions in the country with a binding, comprehensive law aimed at reducing greenhouse gas emissions. “It allows us to make significant improvements to the energy efficiency of existing buildings in the District,” Mayor Bowser said at the signing ceremony located at the American Geophysical Union (AGU) Building, which is slated to become the first net zero commercial retrofit in DC when it reopens later this year.

The new law has several sections which will impact the buildings in which DC residents and businesses live and work. In this post, we’re going to focus on Title III of the Clean Energy Omnibus Amendment Act, which is designed to make the city’s existing buildings more efficient.

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The Top 10 Party Walls Posts of 2018!

2018 has been a year to remember for SWA’s Party Walls blog. Our consultants have shared their passion for high performance buildings by recounting stories from the field and providing information, new findings, and best practices to improve the built environment.

Whether discussing topics based in New York City or Southeast Asia, here are our fan favorites from 2018…

Collage of blog images

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