New York City’s Climate Mobilization Act: How does it affect schools?

The City's ambitious effort to fight climate change includes incremental emissions reduction mandates. Strategies and utility incentives are available to help educational institutions meet targets for 2024, 2030, and beyond.

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In April, New York City enacted the landmark Climate Mobilization Act (CMA), a mandate to tackle one of the biggest drivers of climate change through emissions reduction efforts.

Buildings are the most significant contributors of emissions in New York City—71%—thus, starting in 2024, buildings will need to achieve targeted emissions limits, with deeper emissions cuts required from there.

EFFECTS OF CMA ON EDUCATIONAL INSTITUTIONS

Colleges, universities, and schools are likely affected by this legislation in several ways.

The most significant change for colleges and universities in New York City is defined within Local Law 97 of 2019, which places limits on emissions from the following:

  1. Buildings that exceed 25,000 gross square feet, or
  2. Tax lots containing two or more buildings with total area exceeding 50,000 gross square feet

Further definitions and clarifications of emissions restrictions and emissions factors for a variety of building types can be found in §28-320.3, starting on page 9 of Local Law 97 of 2019.

Additional aspects of the CMA may affect New York City educational institutions include Local Law 92 of 2019, which modifies the City building code to require green roofs and/or solar photovoltaic installations on certain buildings; and Local Law 95 of 2019, which adjusts the scoring system for the energy-efficiency benchmarking law already in effect.

SCHOOLS SHOULD BEGIN PLANNING NOW

The limits for 2024–2029 are modest and should be relatively easy to achieve, or have already been achieved, at most school facilities. The limits get much more stringent starting in 2030, however, dropping 40-60% for the occupancy categories most applicable to educational institutions.

Much of that drop is predicated on the anticipation of a much cleaner grid. That’s good news for facilities where electric consumption is responsible for the lion’s share of emissions, but it’s another story entirely for facilities with significant fossil-fuel consumption. Owners of those facilities will need to start planning now to transition toward lower-emission fuel sources.

AVENUES TO EMISSIONS REDUCTION

Implementing energy conservation measures (ECMs) — Reducing emissions starts with building optimization through a thorough investigation of existing heating, cooling, ventilation, insulation, lighting, and finding other potential opportunities to reduce demand.

Buying renewable energy certificates (RECs) — Building owners can offset electric consumption with RECs, but it’s important to note that only RECs from sources “considered by the New York independent system operator to be a capacity resource located in or directly deliverable into Zone J” are eligible. (Zone J is the region of New York’s electric grid covering New York City.)

Buying carbon offsets — Colleges and universities can also buy carbon offsets to credit against your building’s emissions; however, the Local Law 97 rules state that building owners can only offset up to 10% of the building’s emissions limit (based on occupancy type) via offsets. Rules on what constitutes an acceptable offset will be forthcoming, but language in the law signals the City’s intent to be rigorous in ensuring the quality of any offsets allowed within this program.

Site generation — Generating clean energy on site is another option for reducing emissions. Specifics will be forthcoming following the rulemaking process.

Carbon trading — Building owners may also be able to purchase credits from another property that is under its limits. Local Law 97 directs the city to study the concept and report its findings by the end of 2020. While buying credits is not an ideal way to comply, this should provide a mechanism for an owner of multiple properties to trade credits internally, balancing overperforming and underperforming buildings.

WHAT SHOULD I DO NOW?

Fortunately, the data needed is the same data you’re already collecting to comply with the New York City Benchmarking Law of 2016. With this information, building owners can compare their buildings’ greenhouse gas emissions data to the 2024 limits using the greenhouse gas coefficients defined in §28-320.3.1.1 of Local Law 97. A further comparison to 2030 limits—although the emissions coefficients are likely to change—will provide an even greater opportunity to plan ahead.

FURTHER RESOURCES ARE AVAILABLE

Utility incentives — ConEdison offers attractive incentives for energy-efficiency projects, with additional incentives currently available for applicants who complete projects by October 31, 2019. As a ConEdison participating contractor with ConEdison (ID #CE2018-0232), GreenerU can offer custom energy savings solutions at private colleges, universities, and independent schools. Public institutions can contact the New York Power Authority for available incentives.

Financing — There are a number of options for financing energy savings projects. The U.S. Department of Energy’s Better Buildings Initiative has some good concise information to help schools think through their options. Additionally, the New York City Energy Efficiency Corporation (NYCEEC) is a nonprofit dedicated to financing clean energy work in the City. Finally, the CMA included authorization of property-assessed clean energy (PACE) financing in New York City, which allows for long-term loans (up to 20 years) to finance qualifying energy improvements; however, details on NYC’s program have not yet been defined.

GreenerU — We believe educational institutions are uniquely positioned to lead the world in mitigating climate change. Our mission is to help them.

We’d love to have a conversation with you to help you prepare for New York City’s building emissions restrictions. Send us an email or call us at 781-209-5760!


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