Footnotes

Today, CBC is providing comment on New York City's proposed rules to implement Local Law 97—the City's ambitious greenhouse gas (GHG) emissions reductions law for large buildings. CBC recommends the rules be designed to encourage building owners to cost-effectively reduce energy consumption and convert to low- and no-emission sources rather than simply paying penalties. With the initial reporting period rapidly approaching, it is important that building owners have more complete information about compliance.  

The proposed rules generally are a welcome and necessary first step—signaling the right approach—but there are several key aspects of implementation that have not yet been covered. Specifically, CBC recommends that future rules:

• Specify, expand, and continue emission limit adjustments for density and specific uses to alleviate counterproductive disincentives to density and certain economically vital uses by clearly defining adjustment parameters and extending adjustments beyond the first compliance period; 
• Specify and extend need-based building-level adjustments so that building owners can determine their eligibility and adjusted requirements as-of-right, rather than through individual petitions; 
• Expand allowable RECs to offshore wind and a phased-down portion of Tier 2 RECs to provide buildings with flexibility to meet emissions goals while the New York City electric grid remains fossil fuel-powered; and 
• Allow carbon trading within an owner’s portfolio to allow building owners to target the most cost-effective emissions reductions across their assets.