Comments on the Mission, Work and Achievements of the Mayor’s Office of Sustainability Before the Committee on Environmental Protection

The Real Estate Board of New York (REBNY), representing over 17,000 owners, developers, managers and brokers of real property in New York City welcomes the opportunity to provide comments on the mission, work and achievements of the Mayor’s Office of Sustainability.

The Mayor’s Office of Sustainability’s mission is to “create a city where the air is clean, the streets are green and where our 8.5 million residents produce zero waste and zero carbon.”[1]  Given this context, New York is making good progress.  New York State has the lowest rate of greenhouse (GHG) emissions among all states in the country[2], and New York City’s GHG emission per capita is among the lowest of large cities in the world.[3]  From 2005-2014, GHG emissions from New York City’s buildings decreased by 12% due to owners - including many REBNY members - taking on retrofits that make economic sense and building leading-edge sustainable structures.[4]  REBNY and our membership certainly understand and appreciate the threats imposed by climate change.

It is this appreciation of contributing toward a cleaner and greener city that leads REBNY and our members to work closely with Mayor’s Office of Sustainability to promote sustainability and energy efficiency awareness among the larger real estate community.

For example, REBNY collaborated with Mayor’s Office of Sustainability - along with the Building Owners and Managers Association of New York and the Urban Green Council – to launch Sustainability Boot Camp in 2016 to train managers, superintendents, operators and engineers in best building operations practices to achieve maximum energy efficiency.  Over 800 building professionals in multi-family residential and commercial buildings from more than 90 organizations, including nearly 200 New York City Housing Authority staff members, participated in the program to learn key strategies and work practices needed to transition to green building operations.

But ensuring that building operations staff are knowledgeable about sustainable practices is only one factor in promoting a greener and greater New York.  Building tenants, who typically make up 40 to 60 percent of a commercial building’s total energy consumption need to be educated as well.  That is why REBNY partnered with the Mayor’s Office of Sustainability to launch the NYC Carbon Challenge for Commercial Owners and Tenants in February 2017 with a common goal to identify strategies for the coordinated implementation of energy efficiency projects and the reduction of GHG emissions from their buildings by 30% or more, within the next ten years. REBNY is currently exploring ways to further engage tenants to adopt energy efficiency measures within leased spaces during critical lease negotiation opportunities.

REBNY and our members also participated in the 80x50 Technical Working Group that was spearheaded by the Mayor’s Office of Sustainability.  The process culminated in April 2016 with the issuance of the Working Group’s Progress Report outlining nearly 100 Energy Conservation Measures across various building typologies.

These efforts are prime examples of the Mayor’s Office of Sustainability convening and collaborating ability to ensure that New York City is on a greener and greater path toward sustainability.  But with this ability comes the responsibility to ensure that practical policies are put forward that promote, rather than deter, the achievement of other important policy goals.

The City of New York is proposing an ambitious path to limit fossil fuel and whole building energy consumption limit according to building type.  This effort was embodied in Intro 1745 of the City Council’s 2014-17 session which ended a few months ago.  At present, we expect the bill to be re- introduced in the City Council for the 2018-21 Council session.  The effort is well-intentioned in its goal to help New York City achieve GHG emissions reduction of 80 percent by 2050 but, we hope that the bill is the start of the conversation.  Because achieving the fossil fuel limits that Intro 1745 requires necessitates major retrofit investments in primarily multi-family residential buildings - including affordable housing - across the city and in virtually every neighborhood.

Moreover, the bill bases its fossil fuel targets upon Energy Use Intensity (EUI), a blunt metric that does not measure energy efficiency and does not take into account building density – a fact that even the Mayor’s Office of Sustainability acknowledges in prior testimony before the City Council.[5]  Basing energy efficiency on EUI will benefit unoccupied buildings while penalizing more densely occupied environments regardless of how energy efficient the building is. The continued reliance upon EUI could adversely impact our city’s efforts to build affordable housing and create jobs by discouraging density that would result in high EUIs.

REBNY and our members have enjoyed a productive working relationship with the Mayor’s Office of Sustainability since its inception and looks forward to engaging with it to address how the major retrofit investments called for by Intro 1745 could be absorbed by smaller or family-based residential building owners.  Or, in the alternative, we look forward to working with the Office to seek other paths to long-term GHG reductions.

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Carl Hum
General Counsel and Senior Vice President
(212) 616-5233


[1] “About – Mayor’s Office of Sustainability” City of New York, Mayor’s Office of Sustainability.  Accessed 11 April 2018

[2] “Rankings: Total Energy Consumed per Capita, 2015”  Independent Statistics & Analysis, U.S.Energy Information Administration.  Accessed 11 April 2018.

[3] Compilation of data from One City Built to Last Technical Working Group Report, NYC Mayor’s Office; C40, LONDON LEGGI  2014; Los Angeles Climate Action Report 2013; Seattle GHG Inventories; and Chicago 2015 GHG Emissions Inventory

[4] City of New York (2016), One City Built to Last Technical Working Group Report, Retrieved from  Retrieved 11 April 2018

[5] Hearing before the Committee on Environmental Protection, New York City Council, April 27, 2017, (Statement by John Lee, Deputy Director of the Mayor’s Office of Sustainability)