The Real Estate Board of New York to The New York State Energy Research and Development Authority on the Carbon Neutral Buildings Roadmap

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The Real Estate Board of New York (REBNY) is New York City’s leading real estate trade association representing commercial, residential, and institutional property owners, builders, managers, investors, brokers, salespeople, and other organizations and individuals active in New York City real estate. Thank you for the opportunity to comment on the draft Carbon Neutral Buildings Roadmap.

REBNY supports New York State Energy Research and Development Authority (NYSERDA)’s effort to develop carbon neutral buildings and secure the successful decarbonization of the building stock. Further, we are pleased to note that a number of REBNY members are participating in NYSERDA’s Empire Building Challenge and working hard to identify and implement strategies to significantly reduce carbon emissions from their buildings. REBNY offers the following comments for consideration as the roadmap is finalized.

 

Policies at all levels of government must be consistent to result in desired outcomes:

Ensuring a consistent set of rules and regulations for building owners to follow is critical to ensuring the desired outcomes are achieved. The proposed roadmap suggests the adoption of a building performance standard for existing large buildings regulating energy efficiency in 2030 (Day 2 – Slide 48). However, currently the City of New York has adopted a performance standard regulating the carbon emissions of buildings over 25,000 sq/ft. While they may be related, an efficiency metric and a carbon metric are not identical. Different standards across jurisdictions will send unclear regulatory signals that will result in a failure to efficiently or effectively achieve the goals of a decarbonized building stock.

 

Dates for new code and replacement requirements need to be based on detailed analysis of technical feasibility across all sectors of building stock:

The roadmap proposes imposing deadlines for new electric ready and all electric code requirements that would apply to new construction in 2023, 2025, and 2030 along with a prohibition on the replacement of certain equipment in 2030 and 2035 (Day 2 – Slides 45 and 46). We commend NYSERDA for recognizing the importance of phasing in these types of requirements on different timeframes across the building stock. However, we encourage further research to be done as the existing analysis in the roadmap has modeled the impact of certain requirements on mid-rise multifamily (seven story – Day 2 – Slide 19) and commercial (twelve story – Day 2 – Slide 32) buildings. We encourage NYSERDA to analyze the impact of these requirements on a greater variation of buildings including very tall buildings that may pose unique challenges for certain types of electric systems.

 

Greater benchmarking and disclosure of energy performance is warranted:

The roadmap proposes a statewide benchmarking and disclosure requirement for buildings over 10,000 sq/ft statewide in 2023 followed by greater disclosure of energy and emissions performance data in 2025 and 2027 (Day 2 – Slide 47). Benchmarking and disclosure of energy and water data has been an effective policy tool that has been in place in New York City for large buildings for many years and is an essential component of any comprehensive regime to improve building performance and reduce emissions.

 

Address district steam:

While the roadmap is generally very comprehensive, one issue missing from consideration is the future role of district steam. District steam is an important source of energy in many commercial and City buildings in New York City but is currently generated from fossil fuels. While New York State has established clear directives to decarbonize electricity generation and begun implementing policies to do so, no clear plan exists to reduce emissions from the district steam system. Greater attention to the role of district steam and strategies to decarbonize this system is needed as a decarbonized district steam system may be able to play an important role in helping convert existing buildings to less carbon intensive energy sources (including on-site combustion) over time.