NYC Energy Reporting Blog

NYC Property Owners Are Being Set Up to Lose: LL97, Bad LL87 Advice, and the Financial Trap of Blind Electrification

Mon, 24 Aug 2026 17:24:25 GMT

New York City property owners are entering a period in which bad energy advice can do far more financial damage than the regulations themselves.

For years, Local Law 84 benchmarking and Local Law 87 energy auditing were treated across much of the industry as administrative exercises. A consultant collected utility data, entered numbers into the required software, generated an audit, identified a collection of Energy Conservation Measures, filed the required forms and moved on. The Department of Buildings was principally concerned with whether the filing complied with the law. Owners were principally concerned with avoiding violations. Consultants were paid for producing technically acceptable reports. Whether the recommended ECMs actually created durable, measurable financial value for the building was too often treated as a secondary question. That approach was never good asset management. With Local Law 97 now imposing direct financial consequences on annual building emissions, and with electricity and fuel costs capable of moving operating expenses by hundreds of thousands or millions of dollars, it has become indefensible.

The timing makes this especially urgent.

Owners who properly obtained an extension for their 2026 Local Law 97 report face an August 29, 2026 filing deadline. DOB has confirmed that date. At the same time, Compliance Pathway 1 properties are already accumulating the energy consumption that will determine their first LL97 compliance result. CP1 buildings are subject to Article 320 beginning January 1, 2026, and their first annual report is due May 1, 2027. That means the gas burned, oil delivered, steam purchased and electricity consumed during 2026 is not merely an operating expense. It is creating the regulatory record that will be reported next spring. The first CP1 filing may occur in 2027, but the financial performance being reported is happening now.

Then comes December 31, 2026, the Local Law 87 deadline for buildings assigned to this year's Energy Efficiency Report cycle. DOB requires covered properties to undergo an energy audit and retro-commissioning every ten years, with the EER summarizing the findings and recommendations. The current rule requires the audit to be at least equivalent to an ANSI/ASHRAE/ACCA Standard 211-2018 Level 2 audit. Retro-commissioning is different: applicable base-building systems must be tested, deficiencies identified, and required deficiencies corrected before submission. Failure to file the EER can produce a $3,000 penalty in the first year and $5,000 for each additional year until the filing is completed. The law therefore gives owners a recurring, mandatory opportunity to take a hard look at how their buildings actually consume energy. Wasting that opportunity on generic recommendations and boilerplate modeling is no longer merely disappointing. It can be extremely expensive.

There is an important distinction between the two halves of LL87.

Retro-commissioning is overwhelmingly concerned with whether existing systems work properly. A failed sensor should be calibrated or replaced. A leaking steam valve should stop leaking. A failed steam trap should be repaired. A boiler control sequence should reflect actual load. Simultaneous heating and cooling should be eliminated. Equipment should not run unnecessarily when the building is unoccupied. Pipes and tanks that should be insulated should be insulated. Operating schedules and setpoints should make sense. DOB itself defines retro-commissioning as the process of ensuring that energy systems function as intended and according to the owner's operational requirements. Much of this work is not controversial decarbonization strategy. It is competent maintenance and operations. A building wasting gas because a valve is stuck open is wasting money whether LL97 exists or not.

The energy-audit portion is where owners need to become substantially more skeptical. LL87 requires the auditor to identify opportunities to reduce energy consumption, but those recommended measures are not generally mandatory capital projects. ReDocs itself explains that the energy audit identifies recommended energy-saving measures, while retro-commissioning addresses deficiencies that must be corrected for compliance. That distinction is critical. An energy audit is supposed to provide useful investment information. It is not supposed to be a catalogue of technologies that can theoretically reduce energy under a standardized set of assumptions.

An ECM does not become a good investment because someone labels it an ECM.

It does not become a good investment because it appears in the New York State Technical Resource Manual. It does not become a good investment because NYSERDA will support a study, because Con Edison offers an incentive, because NYC Accelerator promotes a technology, because an advocacy organization believes the technology is important to decarbonization, or because an engineer with an impressive list of credentials can produce a sophisticated model showing savings. Those resources can all be useful. Some are extremely valuable. None is a substitute for proving that the particular measure makes economic sense in the particular building where the owner's money will actually be spent.

The New York State Technical Resource Manual illustrates the distinction perfectly. The TRM exists to establish standardized, fair and transparent methodologies for estimating energy and demand savings in efficiency programs. Standardization is necessary for administering programs across thousands of projects. It is not a guarantee of realized cash savings at any one property. NYSERDA's FlexTech program similarly supports objective, site-specific studies intended to help owners evaluate energy opportunities, but NYSERDA expressly states that the program cost-shares the study, not implementation, and that implementation of recommendations “may” lead to lower annual utility costs. Even NYSERDA's historical impact evaluation distinguished between savings predicted in FlexTech studies and savings actually realized after implementation. In that evaluation, realized savings were materially different from study recommendations, particularly for natural gas. The lesson should not be that FlexTech is ineffective. The lesson should be that a professional study is still a prediction until the project is implemented and measured.

Consider a classic ECM that can look excellent in an audit model: roof insulation.

The physics of conductive heat transfer is straightforward. Heat flow through a roof assembly can be approximated from its U-value, area and temperature difference. Improve the R-value, reduce the U-value, and conductive heat loss through that assembly falls. That statement is unquestionably true. It does not follow that adding roof insulation is necessarily a good investment in a particular building.

Imagine a multifamily building with an old steam heating system that chronically overheats apartments. The windows are operable. Tenants respond exactly as human beings respond when their apartments are 82 degrees in January: they open the windows. At that point, enormous quantities of warm indoor air are being replaced by cold outdoor air. The heat required to warm that infiltration air can dwarf the incremental conductive savings available from another layer of roof insulation. A consultant can produce a technically elegant roof-loss calculation while missing the actual building operating condition that determines the gas bill. The roof may be the easiest ECM to model. It may be the wrong ECM to implement.

The rational sequence in that building may be to balance the steam distribution, correct master venting, replace failed traps, repair control valves, optimize outdoor reset, install appropriate apartment-level controls, reduce boiler pressure and stop systematically overheating the building. Once residents no longer need to regulate indoor temperature by opening windows in freezing weather, the owner can reassess the envelope. Spending major capital on insulation while conditioned air is intentionally being dumped through operable windows is not energy strategy. It is treating the model as more important than the building.

Other audit recommendations can fail for similarly obvious reasons.

A condensing boiler may be modeled at excellent efficiency, but if the existing distribution system continuously requires return-water temperatures too high to permit meaningful condensing operation, the modeled seasonal efficiency may never materialize. A variable-frequency drive can generate substantial savings on a centrifugal pump where flow genuinely varies and the system is dominated by frictional head, but a simplistic affinity-law analysis can badly overstate savings where static head dominates or minimum flow requirements keep the pump operating near full speed. A control-system project can claim large savings by assuming equipment is currently operating twenty-four hours per day when the superintendent is already manually shutting it down every night. Two ECMs can each take credit for the same underlying reduction and double count the savings. A heat pump can have an impressive rated COP while operating in a real building at high supply-water temperatures and low outdoor temperatures where the actual seasonal efficiency is dramatically worse. The audit is only as good as its assumptions, and an assumption does not become true because it appears in a professional report.

When these recommendations fail, the financial responsibility is not distributed evenly among everyone who encouraged the project. NYSERDA does not pay the mortgage. Con Edison does not fund the owner's capital reserve because a measure underperformed. DOB does not reimburse the building if an electrification project increases operating expenses. NYC Accelerator does not take responsibility for the property's net operating income. Urban Green Council does not purchase the asset if a decarbonization investment makes it less competitive. The consultant generally does not acquire the building and assume its debt. The property owner pays the contractor, the utility bill, the mortgage, the taxes, the maintenance, the LL97 penalties and the cost of correcting a project that did not perform as expected.

This is why a bad ECM can damage far more than one year's operating budget. Commercial and multifamily real estate is fundamentally valued on income. If an energy project permanently increases annual operating costs without creating a corresponding and durable regulatory or revenue benefit, it reduces net operating income. A persistent $100,000 annual loss of NOI capitalized at 5 percent represents approximately $2 million of value. At a 4 percent capitalization rate, it represents approximately $2.5 million. Real valuation involves many additional variables, but the relationship is fundamental. A consultant who recommends a permanent change in a building's energy system is potentially influencing the long-term value of the asset, not merely the next Con Edison bill.

Local Law 97 makes that responsibility far more serious.

Article 320 imposes annual building emissions limits, and the statute provides for a civil penalty of up to $268 for each metric ton of CO2e by which reported annual emissions exceed the applicable limit, subject to the law's enforcement and mitigation provisions. For CP1 properties, those limits apply beginning in 2026, with the first report due in 2027. There is therefore real money on the line, and in many buildings the potential exposure can be substantial.

It is equally important to state what LL97 does not do. The law does not generally order a market-rate building owner to remove a gas boiler and install a heat pump. Article 320 is fundamentally an emissions-performance regime rather than a universal equipment mandate. Nevertheless, the economics of the law can push owners toward electrification because direct fossil-fuel combustion contributes to building emissions while the treatment of grid electricity evolves under the City's regulatory framework. That economic pressure has caused electrification to become one of the dominant themes of the LL97 compliance discussion. The problem is that the regulatory preference for lower-carbon energy does not repeal the laws of utility economics.

For many New York properties, natural gas remains exceptionally inexpensive compared with electricity on a delivered useful-heat basis. The exact result depends on the building's gas rate, electric service class, supply contract, boiler efficiency, heat-pump COP, outdoor temperature, distribution temperature, equipment sizing and operating profile. Those details matter. But an owner evaluating a deep electrification project encounters a brutal financial Catch-22. If the owner assumes that the current LL97 structure, carbon coefficients, penalty values and compliance incentives will remain sufficiently strong for the life of the project, a project with mediocre pure-energy economics may still appear financially rational because avoided penalties create additional value. If the owner assigns a meaningful probability to future amendments that reduce that advantage, the same project can become a permanent operating-cost liability.

That regulatory risk is not theoretical. LL97 is current law and owners must comply with it, but proposals to modify it continue to be introduced. In 2026, for example, legislation was introduced in the City Council that would delay the law's emissions-reduction requirements and related penalties by seven years. That bill remains a proposal rather than current law, and owners should not base decisions on an assumption that it will pass. Its existence nevertheless proves the larger investment point: legislation can be contested, amended, delayed or restructured over the useful life of a twenty- or thirty-year mechanical system. A prudent owner cannot simply assign a zero percent probability to regulatory change.

That creates a potentially extraordinary asset-risk scenario. Imagine two similar buildings. One retains a highly efficient gas-fired heating plant. The other spends millions of dollars converting its heating infrastructure to an electrical system that is materially more expensive to operate before LL97 benefits are considered. If the full regulatory advantage assumed in the electrification underwriting remains intact, the electrified building may be fine. If the regulatory benefit is subsequently reduced, the electrified building can be left with structurally higher operating expenses than its gas-fired peer. Those expenses reduce NOI year after year and can therefore reduce asset value year after year. The owner has made a capital decision that may be extremely expensive to reverse. That is not a normal ECM. It is a long-duration regulatory and commodity-price bet embedded in the mechanical infrastructure of the property.

ReDocs does not believe owners should be asked to take that bet blindly.

The most defensible ECMs are measures whose economics remain compelling under both scenarios. They should create value if LL97 remains aggressive, and they should still create value if the law is materially revised. An LED replacing a higher-wattage lamp in a fixture operating around the clock is a simple example. If illumination requirements are maintained and connected wattage falls from 32 watts to 12 watts, the direct reduction is 20 watts. At 8,760 operating hours per year, that is approximately 175 kWh of reduced annual consumption per fixture before secondary effects. The political composition of the City Council does not alter that arithmetic. Repairing a steam leak has similar logic. Eliminating unnecessary equipment runtime has similar logic. Correcting simultaneous heating and cooling has similar logic. These are the measures that should dominate the front end of an investment plan because the core savings mechanism is physical and direct.

Deep heating electrification is more complicated, but it can be approached with the same discipline. The crucial fact is not simply how efficiently electricity can create heat. The crucial fact is when the electricity is consumed. Con Edison's current SC 9 Rate II General-Large Time-of-Day tariff creates an unusually powerful opportunity for eligible high-tension customers. Under the tariff effective in 2026, high-tension customers are billed demand delivery charges during specified weekday periods, including 8:00 a.m. to 10:00 p.m., with an additional summer component from 8:00 a.m. to 6:00 p.m. The separate demand charge applying during “all hours of all days” applies to low-tension service only. For high-tension SC 9 Rate II service, there is therefore no demand delivery charge created by incremental consumption between 10:00 p.m. and 8:00 a.m. The base energy delivery charge is only $0.0079 per kWh, although actual all-in electric cost still includes supply, applicable adjustments, taxes, riders and other charges.

That ten-hour window should completely change the way an intelligent consultant approaches electrification. The objective should not be to electrify the heating plant and then allow it to operate whenever the thermostat calls. The objective should be to concentrate the electric energy input into the 10:00 p.m. to 8:00 a.m. window to the maximum extent technically and economically possible, when high-tension SC 9 Rate II customers can add load without creating the daytime demand-delivery charges that can destroy project economics. Energy should be purchased when the tariff is favorable and stored until the building needs it. For major heating electrification, time is not a secondary variable. Time is one of the most important engineering variables.

The problem is obvious: a building does not stop needing heat at 8:00 a.m. If the favorable charging opportunity is roughly ten hours and the expensive weekday period continues until 10:00 p.m., the energy system must be capable of carrying the heating load across approximately fourteen hours. That makes long-duration storage central to the economics. A small buffer tank that shifts an hour or two of load is not the same thing. A serious design must evaluate the hourly load curve, identify the thermal energy required through the daytime and evening period, account for design weather, operating reserve and losses, and size the charging plant and storage system accordingly.

The most direct approach is thermal energy storage.

Electricity consumed during the overnight window can operate heat pumps, electric boilers or another electric heat source and convert that electricity into stored thermal energy. The storage medium can be hot water, rock, concrete, phase-change material or another engineered medium. Hot-water storage is conceptually simple and well understood, but tank volume can become enormous at modest usable temperature differentials. Rock and other sensible-storage materials can be inexpensive and durable but require careful heat-transfer design and sufficient usable temperature range. Phase-change materials can provide greater energy density by storing latent heat, but cost, cycle life, material stability, heat-transfer characteristics and transition temperature all matter. There is no universal best medium. There is a universal requirement to model the actual building and the actual tariff.

The correct storage calculation is not annual. It is hourly. The engineer needs the building's heating-load profile from approximately 8:00 a.m. through 10:00 p.m., the design-day load, the expected part-load profile, domestic hot-water requirements where relevant, storage losses, usable charge and discharge temperatures, heat-exchanger approach temperatures, equipment COP as a function of source and sink temperature, charging-system capacity, redundancy requirements and operating reserve. A system that looks attractive on annual kWh but cannot carry the building through a cold January afternoon without turning on several megawatts of new electric demand has failed the most important economic test.

There is another way to store the overnight electricity

Convert it into chemical energy. Standard Carbon 's e-methane platform, the Carbon Bridge, is designed around this concept. The system converts captured CO2 and electricity into storable methane that can subsequently be used through existing gas infrastructure. Standard Carbon describes the platform as intentionally operating around periods when electricity is least expensive and converting that power into a storable low-carbon fuel. In time-domain terms, the logic is similar to thermal storage: purchase electrical energy during the favorable window, convert it into a form that can be stored, and consume the resulting energy later when the building actually needs heat.

The choice between thermal and chemical storage is a site-specific engineering decision. A property with abundant basement or mechanical-room space may find hot-water storage attractive. Another may have structural or spatial constraints that make a huge water tank impractical. A building with existing steam or hot-water boilers may place a high value on retaining proven gas-fired distribution infrastructure. Another property undergoing a major central-plant replacement may have a stronger case for direct thermal storage. Rocks, water, phase-change materials and e-methane are not interchangeable technologies. They are different tools for solving the same central economic problem: separating the time when the building buys electricity from the time when the building needs heating energy.

What should be unacceptable is a consultant recommending major heating electrification without engaging this issue at all. An analysis that presents annual kWh, annual therms, annual carbon and a seasonal COP while ignoring the Con Edison service classification is incomplete. An analysis that does not distinguish high tension from low tension is incomplete. An analysis that does not model the building's fifteen-minute demand profile is incomplete. An analysis that recommends a multi-megawatt electric heating plant without asking how much of that load can be shifted into the 10:00 p.m. to 8:00 a.m. window is incomplete. An analysis that ignores the amount and duration of storage necessary to avoid daytime operation is incomplete. When millions of dollars of capital and potentially millions of dollars of asset value are at risk, incomplete analysis is not an acceptable standard of care for an owner's investment decision.

This is the central contradiction that too many decarbonization discussions avoid. Electrification can reduce LL97 exposure, but poorly timed electrification can simultaneously increase energy costs. A building can improve its carbon calculation while damaging its NOI. A consultant can therefore produce an environmentally attractive recommendation that is financially destructive. The owner's responsibility is to refuse to confuse those two outcomes.

NYSERDA , Con Edison , NYC Accelerator , NYC Department of Buildings , Urban Green Council and other organizations have legitimate roles in New York's energy transition. They produce useful research, administer regulations, design incentive programs, standardize technical methodologies and encourage technologies that serve broader public-policy goals. Property owners should use those resources. They should not outsource fiduciary judgment to them. Public policy is necessarily concerned with system-wide outcomes. A property manager is responsible for one balance sheet, one mortgage, one operating statement and one asset. Those perspectives overlap, but they are not identical.

That distinction becomes especially important when incentives are involved. A project receiving a subsidy can still be a bad project. If a $2 million measure receives a $400,000 incentive but creates only $80,000 per year of verified savings and carries meaningful maintenance and replacement risk, the existence of the $400,000 check does not resolve the investment question. The owner still needs to evaluate the remaining capital, financing cost, useful life, operating savings, equipment degradation, residual value and risk. Incentives can improve economics. They cannot repeal economics.

The same is true of advanced modeling. Complex models are indispensable where the physics is complex, but sophistication can create false confidence. A forty-tab spreadsheet containing hundreds of assumptions is not automatically more reliable than a simple calculation based on measured load. The correct hierarchy is to use measured data wherever possible, direct physical calculations where appropriate, calibrated models where necessary and explicit sensitivity analysis where uncertainty cannot be eliminated. The model should serve the decision. The decision should not be made to validate the model.

Every significant ECM should therefore be tested against multiple scenarios. At minimum, ReDocs believes an owner should understand the economics with the current LL97 framework and the economics with materially reduced LL97 value. The analysis should identify what percentage of project return comes from energy savings, what percentage comes from avoided penalties, what percentage comes from incentives, and what assumptions drive each component. If removing the $268-per-ton penalty assumption causes the entire financial case to collapse, the owner deserves to know that they are making a regulatory bet. If the project still produces an attractive return without LL97, then LL97 is upside rather than life support.

This approach also changes the purpose of Local Law 84.

Benchmarking should not be a May paperwork event. It should become part of the verification system. DOB requires covered buildings to report annual energy and water data through ENERGY STAR Portfolio Manager. That longitudinal dataset should be used to determine whether the building is actually becoming more efficient. If gas consumption rises after an ECM was installed, someone should investigate. If electricity consumption falls but peak demand increases dramatically, someone should determine whether the project actually reduced cost. If a heat-pump conversion reduces fossil-fuel use while total utility expense jumps, the owner should understand why. If an insulation project produces no measurable weather-normalized improvement, that result matters. LL84 can provide the ongoing measurement that exposes the difference between predicted performance and actual performance.

This is why ReDocs' position is intentionally more demanding than “complete your compliance filing.”

ReDocs describes itself as a company that goes beyond paperwork and understands both compliance and the business of operating real estate. That principle has to mean something when the recommendations become difficult. It means telling a client that a fashionable ECM is a poor investment when the numbers do not work. It means questioning a roof-insulation project when open windows dominate the heat loss. It means refusing to pretend that electrification is automatically cost-effective because it reduces carbon. It means analyzing the actual Con Edison tariff rather than applying a generic electricity rate. It means evaluating long-duration storage rather than pretending a large heating load can simply be moved onto the grid without consequences. It means treating the building as an economic asset, not as a demonstration project.

For CP1 owners, there is no time to postpone that discipline. Their first Article 320 compliance year is already underway. Energy consumed in January, February or August 2026 cannot be retroactively eliminated when the engineer prepares the May 2027 filing. The utility meters are creating the compliance record every day. For owners with a December 31, 2026 LL87 deadline, this creates an unusually important opportunity. They are already required to open the mechanical rooms, review the utility history, inventory systems, perform the audit and complete retro-commissioning. The incremental value of turning that mandatory process into a genuine capital and operating strategy is enormous compared with the cost of commissioning a separate study after the filing is complete.

The first priority should be measures that eliminate obvious waste. The next priority should be measures whose economics are direct enough to remain attractive across different regulatory futures. Major fuel-switching investments should then be evaluated under the actual tariff and with explicit regulatory sensitivity. For a large heating load moving toward electricity in Con Edison territory, the central question should be how much electrical input can be concentrated in the high-tension SC 9 Rate II 10:00 p.m. to 8:00 a.m. window and how that energy can be stored until the building needs it. If the answer is thermal storage, size it properly. If the answer is chemical storage such as e-methane, analyze it properly. If the answer is that the load cannot be economically shifted, tell the owner what the project actually costs during peak periods and how dependent the return is on LL97.

Property owners have been told for years that decarbonization is primarily a technology problem.

It is not. It is an optimization problem constrained simultaneously by physics, tariffs, regulation, capital, space, operations and asset value. Anyone can recommend a heat pump. Anyone can recommend insulation. Anyone can calculate a theoretical reduction in annual energy use. The hard work is determining whether the project will actually make the property financially stronger after the contractor is paid and the consultants have left.

That is the standard the LL87 industry should be held to now. A technically compliant report that leads an owner into a financially destructive project is not a success. A sophisticated model that fails to predict the utility bill is not a success. A project that only works if no material element of LL97 changes for the next twenty years is not a low-risk ECM. A carbon reduction that permanently destroys more NOI than the regulatory exposure it avoids is not intelligent asset management.

The 2026 LL97 filing season should mark the end of the old compliance mentality. The August 29 extension deadline is arriving. CP1 properties are already creating the numbers they will report in May 2027. LL87 reports are due December 31 for this year's cycle. There is too much money at stake for property owners to continue purchasing studies whose primary accomplishment is producing a filing confirmation.

ReDocs will comply with the law, understand the law and explain the law.

We will also challenge assumptions that do not survive contact with the building's actual economics. We will use agency guidance where it is useful without pretending that guidance is a guarantee. We will use sophisticated modeling where sophistication is necessary without hiding basic economics behind complexity. We will evaluate ECMs under both regulatory and non-regulatory cases. We will analyze the utility tariff before recommending a major electrical load. We will prioritize direct, measurable savings over fashionable assumptions. Most importantly, we will remember who ultimately bears the risk.

The property owner pays the energy bill, pays the mortgage, pays the LL97 penalty, funds the capital project and owns the result. Every LL87 recommendation should be written with that fact in mind. Anything less is not serious energy consulting.

Straightforward LL87 Compliance for Gas-Fired Buildings: Avoid Fines & Assess 2030 Risk

Thu, 13 Aug 2026 09:58:08 GMT

For owners of gas-fired buildings in New York City, heating costs may not carry the extreme price volatility of heating oil or district steam.

As a result, energy compliance often slips down the priority list until a Department of Buildings (DOB) deadline is right around the corner.

However, Local Law 87 (LL87) remains a strict legal requirement for buildings over 50,000 square feet. Failing to file on time results in immediate $3,000 baseline penalties from the city, followed by $5,000 annual recurring fines until compliant.

If your building runs on natural gas, your strategy should be simple: get compliant smoothly, avoid city fines, and get a clear picture of your 2030 Local Law 97 (LL97) risk.

The Misconception About Gas Buildings and LL97

Because natural gas is a cleaner-burning fossil fuel than oil, many gas-heated building owners assume they are completely safe from Local Law 97 carbon penalties.

While gas-fired buildings generally fared well under the initial 2024–2029 LL97 caps, the emissions caps drop substantially in 2030.

Many modern gas-fired properties that easily passed the 2024 limits will cross into penalty territory in 2030 unless baseline energy waste is addressed today.

Keeping the LL87 Process Simple & Straightforward

You don't need a bloated, overly complex engineering proposal to satisfy Local Law 87. You need an efficient team that knows how to navigate DOB filings accurately without disrupting your building's operations.

A streamlined LL87 process for gas-fired buildings delivers three core results:

100% Legal Compliance: Completing the required Energy Audit and Retro-commissioning ($RCx$) filing to keep your building in good standing with the city.
Identification of Easy Gas Savings: Finding simple control fixes, insulation gaps, or burner calibrations that keep gas bills low.
2030 Carbon Limits Forecast: Providing a clean, easy-to-read benchmark of where your building's gas emissions will stand when the stricter 2030 LL97 limits take effect.

What We Look For in Gas-Fired Buildings

When auditing a gas-heated property, we focus on high-efficiency operational adjustments that keep the process straightforward:

Boiler Cycling & Staging: Optimizing multi-stage or modular gas boilers to ensure they fire at peak efficiency matching actual outdoor demand.
Water Heater & Domestic Hot Water (DHW) Controls: Checking hot water storage temperatures and circulation loops to eliminate continuous gas consumption.
Thermal Envelope & Vent Seals: Inspecting louvers, dampers, and common area doors to prevent heated air from escaping the building envelope.

Protect Your Asset from Avoidable Penalties

Don't let a simple filing deadline slip into an expensive administrative headache. By completing your Local Law 87 work on time, you protect your building from immediate DOB fines while securing a clear, risk-free plan for 2030.

Next Steps: The first step is simply making sure your building is compliant and avoiding a fine. Reach out to our team today to schedule your hassle-free LL87 compliance review.

Cutting Fuel Costs in Oil-Fired Buildings: Using LL87 to Fight Rising Bills & LL97 Fines

Thu, 13 Aug 2026 09:54:22 GMT

Owners and property managers of oil-fired buildings in New York City are facing an uphill battle.

Heating oil prices continue to fluctuate dramatically, turning winter operating budgets into unpredictable financial stresses.

On top of soaring fuel delivery costs, oil-fired heating systems carry some of the highest carbon emission factors under NYC’s Local Law 97 (LL97).

If your building relies on No. 2 oil or biodiesel blends, compliance with Local Law 87 (LL87) isn't just a legal check-the-box exercise—it is an essential operational strategy to cut fuel consumption and avoid massive 2030 carbon penalties.

Why Oil-Fired Buildings Face the Highest LL97 Risk

Under Local Law 97, carbon penalties are calculated based on the greenhouse gas intensity of your fuel source. Because burning heating oil releases significantly more carbon per MMBtu than natural gas or electricity, oil-fired properties reach their emissions thresholds much faster.

This puts oil-fired building owners in a double squeeze:

Immediate Risk: High monthly fuel purchasing costs that erode operating margins today.
Upcoming Risk: Severe annual Local Law 97 fines starting in 2030 if oil consumption isn't drastically reduced or transitioned.

Using Local Law 87 to Find Immediate Oil Savings

Local Law 87 requires an Energy Audit and Retro-commissioning (RCx) process every 10 years. Rather than looking at this audit as an unwanted overhead expense, oil-fired building owners should use it to locate every drop of wasted fuel.

Even a modest 5% to 10% reduction in oil consumption through low-cost retro-commissioning can deliver thousands of dollars back to your operating budget in a single heating season.

What We Look For in Oil-Fired Buildings

During an LL87 energy audit for an oil-heated building, our goal is to find practical ways to improve efficiency without forcing immediate, multi-million-dollar plant overhauls:

Combustion Efficiency & Burner Tuning: Adjusting oil burner air-to-fuel ratios to ensure clean, full combustion without excessive soot buildup or heat loss up the stack.
Boiler Control Optimization: Upgrading or recalibrating outdoor reset controls and aquastats to prevent boiler short-cycling.
Storage & Pre-Heating Systems: Inspecting fuel line pre-heaters and oil storage pumping setups to prevent excessive power draw.
Draft Controls & Flue Dampers: Ensuring automatic barometric dampers are functioning properly to hold heat inside the boiler pass rather than losing it up the chimney.

Plan Your Fuel Transition on Your Own Terms

Whether your long-term plan involves switching to natural gas, installing heat pumps, or optimizing your existing oil boiler plant, waiting until the last minute will cost you significantly more.

Use your Local Law 87 report to build a clear, step-by-step roadmap that reduces oil consumption today and prepares your building for future LL97 compliance on your own timeline and budget.

Next Steps: Even a modest reduction in fuel oil use can make a major financial difference. Contact us today to evaluate your oil-fired building's efficiency options.

Taming ConEd Steam Bills: How NYC Building Owners Can Use LL87 to Stop Wasting Energy

Thu, 13 Aug 2026 09:45:43 GMT

Steam rates in New York City have skyrocketed, making space heating and domestic hot water two of the largest operational line items on your building’s budget.

If your building heats with Con Edison district steam, you don't need a reminder of how punishing monthly utility bills have become.

When Local Law 87 (LL87) compliance comes around, many district steam building owners view it as just another bill from the city.

That’s a mistake. In a steam-heated building, your mandatory LL87 audit is actually your best tool to uncover hidden mechanical waste, slash utility bills, and shield your asset from escalating Local Law 97 (LL97) carbon penalties.

The ConEd Steam Reality: High Rates + System Inefficiency

We can’t control Con Edison’s steam rates. What we can control is how much steam your building needlessly consumes—and wastes—every single day.

District steam systems are inherently complex. Over time, valves stick, sensors drift, vacuum pumps fail, and steam traps blow out. Unlike standard gas or oil boilers where inefficiencies slowly bleed money, a malfunctioning steam system burns through cash at an alarming rate due to high fuel costs.

Worse yet, steam carries a heavy carbon coefficient under Local Law 97 rules. Every pound of wasted steam isn't just an inflated ConEd bill today—it's a potential carbon fine tomorrow.

Turning Mandatory LL87 Work into Steam Cost Relief

Local Law 87 mandates an Energy Audit and Retro-commissioning (RCx) process every 10 years for qualifying NYC properties. While many view this as administrative friction, a steam-focused LL87 audit provides immediate operational value:

Pinpointing Hidden Steam Losses: Identifying failed steam traps that allow live steam to blow straight into condensate return lines without heating the building.

Optimizing Control Strategies: Fixing miscalibrated outdoor air reset controls and steam station pressure regulators that over-supply steam during mild weather.
Insulation & Heat Recovery: Spotting bare steam piping and uninsulated valves in mechanical rooms that radiate expensive heat into unconditioned spaces.

What We Look For in District Steam Buildings

When auditing a steam-heated building, our priority is finding practical, high-ROI fixes that immediately trim your ConEd statement:

Steam Trap Testing & Auditing: Identifying leaking traps that drain thousands of dollars per month in live steam.
PRV & Control Valve Performance: Checking pressure reducing valves (PRVs) to ensure the system operates at the lowest safe pressure.
Condensate Return Health: Evaluating condensate tanks, pumps, and heat exchangers to recover maximum heat energy before water leaves the system.
Zone & Radiator Valve Regulation: Resolving localized overheating issues that force residents to open windows in the dead of winter.

Stop Paying for Steam You Don't Use

You don't have to accept staggering ConEd steam bills as an unchangeable cost of doing business in NYC. By using the required Local Law 87 process strategically, you can identify mechanical failures, reduce steam consumption, and build a buffer against 2030 Local Law 97 emissions caps.

Next Steps: Let’s use your mandatory LL87 evaluation to find out where your building is losing steam and cash. Contact us today for a steam system performance review.

Navigating Energy Laws in Mixed-Unit NYC Buildings: Finding the Balance Between Compliance and ROI

Thu, 13 Aug 2026 09:31:57 GMT

Managing a residential property with a mix of rent-regulated and market-rate units requires a delicate balancing act.

You are operating under two distinct financial models under one roof: market-rate units that benefit directly from value-add capital improvements, and regulated units where cost-recovery options are strictly capped.

When energy mandates like Local Law 87 (LL87) and Local Law 97 (LL97) enter the picture, a one-size-fits-all energy strategy simply will not work.

To protect your asset's valuation without overspending, you need an energy compliance plan tailored specifically to your building’s unit mix.

The LL87 Dilemma for Mixed-Unit Properties

Every 10 years, qualifying NYC buildings over 50,000 square feet must file an Energy Efficiency Report (EER) under Local Law 87. The required audit generates a long list of operational tune-ups (RCx) and capital expenditure recommendations.

For mixed-unit owners, the challenge isn't the audit itself—it's deciding which recommendations to implement and which to ignore.

If you spend too little: You risk missing operational savings that directly boost market-rate unit value, or worse, you set the building up for massive Local Law 97 carbon penalties down the road.

If you spend too much: You risk sinking capital into system-wide upgrades that cannot be recouped through the regulated portion of your rent roll.

Evaluating Capital Improvements Against Unit Mix

When evaluating your LL87 findings, every potential upgrade must be run through a simple filter: Does this improvement lower operating costs enough to justify the capital spend across the entire building?

Here is how strategic owners categorize their LL87 action items for mixed properties:

High-Priority, Low-Cost Tune-Ups: Basic retro-commissioning fixes (like steam trap repairs, sensor re-calibrations, and pipe insulation) that lower overall utility bills across all units with minimal capital outlay.
Targeted Market-Rate Upgrades: In-unit or floor-specific efficiency improvements (like smart thermostats, modern lighting, or sub-metering) that enhance tenant appeal and boost Net Operating Income (NOI).
Whole-Building Central Plant Work: High-ticket capital expenditures (boiler replacements, electrification, envelope sealing) that must be carefully calculated against your 2030 Local Law 97 carbon limit thresholds before committing capital.

What We Look For in Mixed-Unit Assets

Our goal when auditing mixed-unit buildings is to provide clear financial clarity before any expensive scopes of work are signed:

Unit-Mix Utility Allocation: Understanding how heating and cooling energy is distributed between market-rate and regulated lines to pinpoint direct waste.

LL97 Penalty Exposure vs. Upgrade Cost: Calculating whether impending carbon fines actually exceed the cost of doing a central plant upgrade.
Non-Invasive Operational Gains: Identifying central mechanical adjustments that improve tenant comfort across all units without requiring invasive in-unit work.

Don't Let Energy Recommendations Drive Your Asset Strategy

An energy report should serve your financial strategy—not the other way around. Before investing in major building-wide upgrades, make sure your compliance team understands how your unit mix impacts your return on investment.

Need a Strategic Review for Your Mixed Building?

Let’s evaluate your building’s unit mix, energy profile, and LL97 exposure before anyone recommends expensive work. Contact us today for a tailored compliance consultation.

How Rent-Regulated Building Owners Can Navigate Local Law 87 Without Overspending

Thu, 13 Aug 2026 09:26:46 GMT

Between statutory rent caps, rising insurance costs, and increasing property taxes, property managers and owners must evaluate every single capital expense with extreme care.

When energy regulations like Local Law 87 (LL87) come due, the immediate concern for most rent-regulated owners isn't "How do we make this building net-zero?"

It’s: "How do we comply legally without burning cash on upgrades that offer no realistic return?"

The reality of LL87 for Rent-Regulated Buildings

Every 10 years, qualifying NYC buildings over 50,000 square feet are required by law to submit an Energy Efficiency Report (EER) consisting of an energy audit and retro-commissioning (RCx) process. Failing to file results in immediate DOB fines ($3,000 in the first year, plus $5,000 every subsequent year until filed).

The filing itself is non-negotiable. However, implementing every recommendation inside the report is not.

Standard energy engineering firms often hand owners a 50-page binder full of high-cost capital improvement recommendations—solar panels, boiler replacements, deep retrofits—without considering whether the building’s rent structure can ever support that expenditure.

How Do I Know What's Mandatory for Compliance vs The Optional Upgrades?

The core goal for a rent-regulated property is simple: satisfy the legal filing requirement, avoid non-compliance penalties, and insulate the building from unnecessary project costs.

When evaluating your LL87 process, it helps to break the findings into two distinct buckets:

Mandatory Retro-Commissioning (RCx) Measures: Minor operational tune-ups required to pass the filing (e.g., repairing broken steam traps, fixing damaged pipe insulation, adjusting basic sensor calibrations). These keep you compliant at minimal expense.
Capital Improvement Recommendations: Suggested long-term projects (e.g., fuel switching, system overhauls). For a rent-regulated property, these should only be pursued if they yield immediate, predictable reductions in operating utility bills.

What We Look For in Rent-Regulated Buildings

Our objective when auditing a rent-regulated asset is to protect your bottom line by pinpointing quick-payback efficiency gains while filtering out fluff:

Low-Cost Operating Adjustments: Fine-tuning heating schedules to prevent over-heating top floors without running up fuel bills.
Basic Maintenance Fixes: Replacing worn boiler controls, air vents, or insulation that actively drain cash every month.
Targeted Waste Reduction: Identifying specific points of utility waste where a small fix creates an instant reduction in monthly operating overhead.

Compliance Without Capital Strain

Local Law 87 doesn't have to turn into an unmanageable project. You can meet your city requirements, keep the Department of Buildings off your back, and protect your cash flow by focusing strictly on what is legally required and financially sensible.

Before signing off on an expensive scope of work, make sure your energy partner understands your building’s financial structure.

Ready to File?

Let’s confirm what your building actually needs so you can satisfy Local Law 87 without taking on unnecessary costs. Reach out today to discuss a practical, low-friction compliance plan.

How Market-Rate Building Owners Can Turn Local Law 87 Compliance into Local Law 97 Protection

Tue, 11 Aug 2026 13:38:17 GMT

For market-rate building owners and property managers in New York City, local energy mandates can easily feel like a recurring financial headache.

Every ten years, Local Law 87 (LL87) requires qualified buildings over 50,000 square feet to conduct an Energy Audit and Retro-commissioning ($RCx$) study, file a Energy Efficiency Report (EER), and pay for the process out of pocket.

Too often, owners treat LL87 as a "check-the-box" requirement—paying for an engineering report, filing it with the Department of Buildings (DOB), and stuffing the findings into a desk drawer.

That approach is a missed financial opportunity—especially with Local Law 97 (LL97) enforcement ramping up.

How Do I Know When My Building Is Due for a Local Law 152 Inspection?

Wed, 05 Aug 2026 10:28:52 GMT

How to check your Community District schedule, estimate costs, avoid DOB fines, and streamline your gas safety compliance.

If you manage or own real estate in New York City, keeping track of building compliance can feel like a full-time job in itself. Among the city's stringent safety mandates, Local Law 152 (LL152) requires periodic inspections of exposed gas piping systems across thousands of properties.

Missing your window can trigger heavy fines and administrative headaches. Here is everything you need to know about building requirements, inspection due dates, checking the NYC Covered Buildings List (CBL), standard costs, penalties, and how to stay compliant.

Building Requirements: Does Your Property Need an LL152 Inspection?

Under NYC Department of Buildings (DOB) regulations, nearly all NYC buildings must undergo a gas piping system inspection every four years.

Local Law 152 covered buildings

Multi-family residential buildings (co-ops, condos, apartment buildings, and 3+ family dwellings).
Commercial and retail properties.
Mixed-use and institutional buildings.
Buildings with gas for heating only (e.g., central boilers with no cooking gas in individual tenant spaces).

What buildings are exempt from Local Law 152 Gas Pipe Inspections?

Occupancy Group R-3: One- and two-family homes are exempt from periodic LL152 inspections.
New Construction: Newly constructed buildings receive an initial grace period, with their first inspection due in the 10th year following the issuance of their Certificate of Occupancy.

Buildings Without Gas Service: Buildings that do not have a gas piping system are not automatically off the hook. The owner must file a Certification of No Gas Piping signed by a Registered Design Professional (Architect or Engineer) once every four-year cycle.

Where can I find the NYC Covered Buildings List (CBL) for Local Law 152?

The NYC Department of Buildings publishes an annual Covered Buildings List (CBL) for Local Law 152 gas inspections.

Access the annual CBL Excel document directly from the NYC Department of Buildings' Periodic Gas Piping System Inspections page. Find and download the document where you see "View list of properties..."
Search the list by pressing CTRL + F and typing in your building address.

If you suspect your building classification or BBL data on DOB records is inaccurate, owners can submit a CBL Dispute Ticket via the NYC BEAM portal.

Infamously, The DOB does not want you relying on their published CBL lists to determine if and when you are due.

Find your LL152 deadline

To determine your exact deadline, you need to verify two main identifiers: your Community District (CD) and your Borough, Block, and Lot (BBL).

Locate Your Community District. NYC's LL152 schedule is organized by Community District across all five boroughs. Use NYC Planning ZoLa (Zoning and Land Use Map). Type in your address at zola.planning.nyc.gov to instantly see your Community District, Block, and Lot numbers.
DOB Building Information System (BIS) or DOB NOW: Look up your property profile to review your BBL, BIN (Building Identification Number), and assigned district.
Find your due date according to the chart below.

LL152 Due Dates: The 4-Year Inspection Schedule

LL152 operates on a rotating 4-year cycle. Your mandatory submission window opens on January 1st and closes on December 31st of your designated cycle year.

Key Rule: Inspections cannot be performed more than 60 days prior to your submission, and your Licensed Master Plumber (LMP) must submit the final GPS2 Certification to the DOB within 60 days of the physical inspection date.

Standard fees & budgeting expectations

DOB filing fees

When budgeting for LL152 compliance, factor in both DOB regulatory filing fees and the cost of the physical inspection itself:

DOB GPS2 Filing Fee: $35 (submitted electronically through DOB NOW: Safety).
DOB Extension Request Fee: $35 (if you require a 180-day filing extension before December 31st).
Certification of No Gas Piping: $375 (for buildings certified as having no gas piping).
Documentation for Inactive Gas Service: $480 (for buildings with piping but no active service).

Inspection & professional services

Professional fees can vary depending on the square footage, number of risers, point of entry, and mechanical complexity of the building. Typically, physical inspections range from $1,000 to $3,000 for standard residential or commercial properties.

Penalties and fines for non-compliance

The NYC Department of Buildings strictly enforces LL152 deadlines with civil penalties and violation notices: up to $1,500–$5,000 per cycle for standard commercial and multi-family buildings that fail to submit a GPS2 certification on time.

Streamline Your LL152 Compliance with JTG Master Plumbing

Navigating Department of Buildings filings, scheduling certified field technicians, and avoiding $5,000 violations doesn't have to be stressful. JTG Master Plumbing Corp (NYC Licensed Master Plumber #1697) provides complete, end-to-end Local Law 152 compliance management across all five boroughs. From initial gas testing and report preparation to submitting final certifications to DOB NOW, JTGMP handles the heavy lifting so your property stays fully compliant. Best of all - JTGMP actually WANTS you to pass your inspection. Learn more now.

Why NYC Plumbers Are Quitting LL152 Inspections

Fri, 31 Jul 2026 20:06:36 GMT

And why our partner JTG Master Plumbing won't.

If you own or manage a building in New York City with a gas piping system, you likely know the drill: Local Law 152 (LL152) requires periodic inspections every four years based on your community district.

However, if you've recently reached out to your usual licensed master plumber (LMP), you might have noticed a frustrating trend: more and more NYC plumbers are dropping LL152 inspections from their service offerings entirely.

Why are plumbers running away from a law that guarantees recurring work? More importantly, who can you rely on to get your building certified safely and on time?

Let's break down why traditional plumbers are opting out, and why JTG Master Plumbing remains fully committed to keeping your building compliant.

3 Reasons NYC Plumbers Are Backing Away from LL152

The Department of Buildings (DOB) has significantly tightened its oversight over LL152 compliance. What used to be a straightforward inspection process for plumbers has turned into a legal and administrative minefield.

1. Surprise DOB Audits Put Plumber Licenses at Risk

The DOB is no longer just processing paperwork— DOB auditors are actively showing up to LL152 inspections alongside plumbers.

For general plumbing contractors who cut corners, skip steps, or aren't 100% fluent in the nuanced rules of LL152 code, these surprise site visits can present a massive risk. A single mistake, skipped room, or misidentified pipe condition during an audited inspection can disciplinary actions, or the loss of their Master Plumber License. For many plumbers, the risk simply outweighs the reward.

2. The DOB NOW Filing Process Is Overly Complicated

The administrative burden of LL152 has escalated dramatically. Recent changes to the DOB NOW portal require building owners to create their own accounts, log in, and personally attest to the repairwork alongside the plumber.

Managing client onboarding, guiding confused building owners through portal attestation, and chasing down electronic signatures has created massive administrative bottlenecks. Plumbers without dedicated filing teams are swamped with back-office work they aren't equipped to handle.

3. Strict New Rules on Filing Fees

Under updated DOB regulations, vendors and plumbing firms are not allowed to pay LL152 filing fees on behalf of property owners. Every fee structure must be handled separately and directly by the owner or authorized representative. This change adds another layer of administrative back-and-forth that frustrates traditional plumbers who just want to turn wrenches and move on to the next job.

Why JTG Is Still the Gold Standard for LL152 Inspections

While other plumbing vendors are stepping back, JTG is stepping up. We haven't shied away from stricter enforcement—we’ve refined our entire workflow around it.

Here’s why NYC property managers and building owners trust JTG for their Local Law 152 compliance:

Unmatched Confidence & Code Expertise

We don't fear DOB auditors showing up at our inspections, because we do things right every single time. As a trusted, specialized industry leader, JTG’s licensed team maintains full confidence in our field work and documentation. Your building stays 100% compliant, and our spotless record means zero head-scratching when the DOB walks in.

Streamlined End-to-End Filing

While other plumbers throw their hands up at the new DOB NOW requirements, we’ve continuously optimized our submission process. We take the administrative burden entirely off your plate—guiding you seamlessly through owner attestations and portal steps so your filings are certified quickly and without friction.

Competitive, Transparent Pricing

Because LL152 compliance is a core focus of our operations, we’ve built unmatched efficiency into our scheduling and inspection protocols. That allows us to keep our pricing as low as possible, offering top-tier compliance without inflated service fees.

Don't Wait Until Your District Deadline Passes

Failing to complete your LL152 inspection within your designated year can result in severe DOB penalties, ranging from $1500-$3000 per violation.

If your regular plumber has stopped offering LL152 services, don't let your building fall out of compliance. Partner with a team that has the scale, expertise, and filing infrastructure to handle it effortlessly.

Need to schedule your LL152 inspection? Contact our partner JTG Master Plumbing today for a seamless, hassle-free inspection and filing.

How to Determine Your NYC Local Law 97 Compliance Pathway

Thu, 16 Jul 2026 20:45:35 GMT

Whether you are a property manager, a co-op board member, or a commercial real estate investor, Local Law 97 (LL97) is no longer a distant regulatory abstract. It is actively reshaping the New York City real estate landscape, representing one of the most aggressive municipal carbon reduction mandates in the world.

If your building fails to hit its targets, the financial consequences are steep: an annual penalty of $268 for every single metric ton of carbon your property emits over its assigned limit. For a mid-sized commercial building or a large multifamily complex, these fines can easily scale into tens—or hundreds—of thousands of dollars every single year.

However, LL97 is not a one-size-fits-all law. The City of New York recognizes that a luxury market-rate high-rise faces entirely different financial, regulatory, and structural realities than an income-restricted or affordable housing development. Because of this, the law branches into several distinct compliance pathways.

Determining your exact pathway is the critical first step to mapping out your capital improvement pipeline and protecting your asset's bottom line. Here is exactly how to find where your building stands.

Step 1: Confirm If Your Building is a "Covered Property"

Before spending time diagnosing a specific pathway, you must first verify if your building meets the legal threshold of a "Covered Property" under Article 320 of the law.

LL97 automatically applies to any property that matches at least one of these criteria:

A single building that exceeds 25,000 gross square feet.
Two or more buildings located on the same tax lot that together exceed 50,000 gross square feet.
Two or more condominium buildings governed by the exact same board of managers that together exceed 50,000 gross square feet.

�� The Quick Check: Do not rely on marketing brochures, architectural blueprints, or your own estimates for square footage. The NYC Department of Buildings (DOB) publishes an official Covered Buildings List (CBL) every year. This list pulls directly from the Department of Finance records. If your BBL (Borough, Block, and Lot) number is on that list, you are legally required to comply.

Step 2: Identify Your Specific Compliance Pathway

Once you establish that your property is covered, look at its occupancy type, funding mechanisms, and legal structure to determine which of the four primary pathways it must follow.

1. The Standard Pathway (Article 320)

The Target Audience: Market-rate multifamily buildings (co-ops, condos, and traditional rental properties) as well as commercial office buildings, hotels, and retail spaces.
The Mechanism: This is a strict emissions-cap pathway. Your building is assigned a hard carbon limit based on its specific Energy Star Portfolio Manager property use type (the law utilizes over 60 distinct occupancy classifications). Your annual carbon footprint is calculated by multiplying your actual utility consumption (gas, electric, fuel oil) by specific greenhouse gas intensity coefficients.
The Timeline: The initial compliance caps are active, with annual reporting required through the city's BEAM portal. However, the real cliff occurs in 2030, when the carbon caps tighten dramatically. Buildings that easily glide under the current limits may find themselves facing massive structural fines if they do not begin retrofitting immediately.

2. The Prescriptive Pathway (Article 321)

The Target Audience: This pathway covers a massive percentage of New York’s affordable, rent-regulated, and income-restricted housing stock. This includes:
Buildings where more than 35% of the dwelling units are rent-regulated (rent-stabilized or rent-controlled).
Housing Development Fund Corporation (HDFC) cooperatives.
Buildings receiving federal project-based housing assistance (such as Section 8 or HUD programs).
The Mechanism: Recognizing the capital constraints of affordable housing, Article 321 provides a massive variance. Instead of trying to hit moving carbon targets, these buildings generally can choose between two compliance tracks:
Track A: Implement a strict checklist of low-cost, high-impact Prescriptive Energy Conservation Measures (PECMs) designed to tighten building performance without requiring deep-energy retrofits.
Track B: Explicitly demonstrate that the building's emissions are already safely below the city's established 2030 carbon limits.

3. The 2026 Delayed Pathway

The Target Audience: This track is designed for properties with a smaller footprint of rent-regulated housing—specifically, buildings where rent-regulated units exist but make up 35% or less of the total building.
The Mechanism: Because these properties are transitioning into the carbon-cap framework, they receive a delayed initial timeline. Instead of the general 2024 start date, their active emissions limits take effect in 2026 , pushing their first mandatory annual carbon reporting deadline out to May 1, 2027.

4. The 2035 Delayed Pathway

The Target Audience: Strictly defined affordable housing properties that are under specific, long-term regulatory agreements with the NYC Housing Development Corporation (HDC) or the Department of Housing Preservation and Development (HPD).
The Mechanism: To prevent capital improvement costs from triggering housing instability or displacement, these properties receive a long-term deferral. They are completely exempt from standard emissions caps until December 31, 2035, at which point they will step into a modified compliance and reporting framework.

Step 3: Action Plan to Map Your Compliance Pathway

Once you suspect which path your building falls under, you must formalize it. A mistake here can lead to retroactive fines or wasted capital on unnecessary upgrades.

Audit Your LL84 Benchmarking Data

Log into your building's Energy Star Portfolio Manager account. Review your historical Local Law 84 (LL84) filings. Because LL84 requires annual energy benchmarking, this data is the exact foundation the city uses to calculate your LL97 carbon footprint. If your data is messy or inaccurate, your LL97 outlook will be flawed.

Perform a Carbon Gap Analysis

Take your actual utility consumption data and run it against the LL97 target caps for your occupancy code. Free, public calculators—like the one provided by the Building Energy Exchange (BE-Ex)—can show you exactly how many metric tons of carbon you are over or under your target, mapping out your projected financial liability.

Assess Financing and Utility Incentives

Explore available state and utility-level financial frameworks before locking in contracts. Investigate NYSERDA programs, Con Edison commercial incentives, or specialized clean energy financing tools like PACE (Property Assessed Clean Energy) loans, which can tie retrofit financing directly to the property's tax bill rather than requiring heavy upfront board capital.

Retain a Registered Design Professional (RDP)

The final, non-negotiable step is hiring a licensed energy engineer or architect. No matter how clean your internal data is, the NYC Department of Buildings requires that all official Local Law 97 compliance reports be formally stamped, certified, and submitted by a Registered Design Professional.

The Core Exceptions: Are Any Buildings Completely Exempt?

While LL97 impacts the vast majority of the city’s large real estate footprint, a few specific property types are fully exempt from the law under the current text:

Federal and State Properties: Buildings owned directly by the United States federal government (such as federal courthouses or military facilities) or New York State are exempt from local municipal building code mandates like LL97.
Low-Rise Residential Structures: Detached or semi-detached residential buildings (like traditional one-to-three-family homes) that stand three stories or less and utilize fully independent, localized HVAC and hot water systems.

The Federal Lease Distinction: It is critical to note that this exemption applies strictly to ownership. If a private landlord owns a building but rents space to a federal agency, the building is currently not exempt. The private owner remains legally responsible for the building's overall emissions and any resulting city fines. While there are ongoing discussions and pushback regarding the logic of penalizing private owners who host federal tenants, the law as written only clears government-owned deeds.

Summary for Owners and Boards

If your property is on the Covered Buildings List, doing nothing is the most expensive option available. Start by pulling your building's historical energy data, verifying your housing classification, and determining whether you are chasing a strict carbon cap or executing a prescriptive checklist. Knowing your pathway changes your strategy from a reactive scramble into a managed, cost-effective capital plan.

Stopping the Bleed: How the NYSERDA FlexTech Program Cuts the Cost of Compliance

Wed, 15 Jul 2026 20:47:23 GMT

Curing "Paralysis by Analysis" and Escaping LL97 Penalties

You have probably heard the term "FlexTech" floating around New York City real estate circles lately. The city loves a new program that sounds overly technical, but behind the jargon, it actually boils down to one simple question: Who is paying for your energy audit?

Specifically, the New York State Energy Research and Development Authority (NYSERDA) FlexTech Program is designed to split the bill with you when you decide to take a look at how your building actually functions - from the boiler room to the roof.

The $30,000 Hard Pill to Swallow

We've been there. You know the building is hemorrhaging heat in the winter, or the summer electric bills are skyrocketing. However, shelling out $20,000 or $30,000 just to have an engineer tell you exactly what you already suspect feels like a tough pill to swallow. It is money out of pocket before you even lay a finger on a valve or replace a single motor.

FlexTech changes that dynamic. It is a cost-sharing setup where NYSERDA covers up to 50% of the cost of an eligible energy study .

The state's goal is to find systemic inefficiencies so they can move the needle on carbon emissions. Your goal is to get a professional, data-backed roadmap for your building's mechanical systems at half the standard market price.

Beyond the Standard Walk-Through: What FlexTech Covers

This is not a superficial walkthrough. The FlexTech program is broad enough to cover the heavy-duty engineering studies that commercial and multifamily owners actually need.

Depending on your portfolio's vulnerabilities, a subsidized study can look into:

Deep-Dive Energy Audits: ASHRAE Level 2 or Level 3 assessments that map out exactly where energy is wasted.
Water Saving Studies: Identifying massive drops in efficiency across domestic water and mechanical cooling loops.
Specialized Systems: Exploring complex setups like Combined Heat and Power (CHP) or electrification readiness.

The primary objective is to equip you with actual, defensible data. Instead of guessing which upgrade might stop tenant complaints, you have concrete numbers to prove what works.

Curing "Paralysis by Analysis" and Escaping LL97 Penalties

For property managers and boards, the toughest hurdle is often the "paralysis by analysis" phase. When you work through the program, you hire a technical consultant—chosen from a pre-approved list of vetted engineering firms—to do the heavy mathematical lifting for you.

They calculate the exact payback period, upfront capital requirements, and long-term utility savings. If you are debating whether a new heat pump system makes sense, the final report will prove it one way or the other.

Crucially, this data is your best weapon against Local Law 97 (LL97) penalties, which are no longer a distant problem - they are here, and they carry real financial consequences. It makes board meetings or owner updates much quieter when you can point to an independent, subsidized study rather than a gut feeling.

Checking Your Eligibility

If you are looking for the fine print, the official NYSERDA FlexTech Program Overview is the place to start. They outline the specific sectors that qualify, but since most multifamily and commercial buildings in the city cross the state's size thresholds, there is a very high probability your portfolio fits the criteria.

For broader compliance help, the NYC Accelerator Resources on Local Law 97 can help map your FlexTech findings directly to the city's carbon limit targets.

The Bottom Line

Ultimately, leveraging this program is about keeping the Department of Buildings (DOB) off your back while ensuring you aren’t overpaying your utility providers. It is one of the rare instances where the state puts its own skin in the game to lower your upfront risk. It won't fund the final construction bill, but it makes the first step vastly less painful for the annual budget.

NYC Local Law 97: What Article 320 Means for Your Building

Sun, 01 Feb 2026 19:00:27 GMT

Article 320 is the core Local Law 97 compliance pathway for most covered private buildings in NYC, requiring annual emissions reporting and compliance with building-specific greenhouse gas limits.

What is Article 320?

Article 320 is the part of Local Law 97 that applies to most covered private buildings in New York City. It sets greenhouse gas emissions limits for covered buildings and requires owners to file annual emissions reports with the Department of Buildings.

Iif your building is covered under Article 320, the city wants to know how much carbon your building is producing. If your building is over the allowed limit, you may face penalties. Article 320 is supported by DOB rule 1 RCNY §103-14 , which explains how the Department of Buildings enforces the law.

The big takeaway

Article 320 is the primary Local Law 97 compliance pathway for most private buildings. If your building falls under Article 320, you need to:

Understand your emissions limit
Track your annual greenhouse gas emissions
File an annual report with the Department of Buildings
Have the report certified by a registered design professional
Reduce emissions if your building is over the limit
Keep documentation organized
Plan ahead for stricter 2030 limits

This is not just another “file it and forget it” requirement. Article 320 can directly affect your operating costs, capital planning, and penalty exposure.

Who falls under Article 320?

Article 320 generally applies to most private covered buildings under Local Law 97.

This can include:

Individual buildings over 25,000 gross square feet
Two or more buildings on the same tax lot that together exceed 50,000 gross square feet
Two or more condominium buildings governed by the same board that together exceed 50,000 gross square feet
Large multifamily buildings
Commercial buildings
Mixed-use buildings
Co-op and condo buildings
Other private properties that meet the covered building criteria

If you own or manage a large private building in NYC, there is a good chance Article 320 applies. The very first step is confirming whether your building is covered and whether Article 320 is the correct compliance pathway.

Article 320 vs. Article 321

LL97 is broken into different articles because not every building follows the same rules. Here’s the simple version:

Article 320 applies to most covered private buildings.
Article 321 applies to certain affordable housing properties and houses of worship.
Article 320 focuses on annual greenhouse gas emissions limits.
Article 321 offers prescriptive energy conservation measures.

What does Article 320 require?

Article 320 requires covered buildings to comply with greenhouse gas emissions limits. Building owners must report their annual emissions to the Department of Buildings. The report must be certified by a registered design professional, such as a licensed engineer or architect.

For Article 320 buildings, owners generally need to:

Calculate annual greenhouse gas emissions
Compare emissions against the building’s applicable limit
File an annual emissions report with DOB
Certify the report through a registered design professional
Take corrective action if emissions exceed the limit
Maintain supporting documentation
Prepare for stricter emissions caps in future compliance periods

The first compliance period began in 2024, and the emissions limits become more strict in 2030. That means a building that is compliant today may not stay compliant forever.

What is the Article 320 reporting deadline?

Article 320 covered buildings must file an annual greenhouse gas emissions report with the Department of Buildings. The first report for the 2024 calendar year was due by May 1, 2025. After that, reports are due every year by May 1.

The report must be certified by a registered design professional. This is important because Article 320 is not just about doing the work. It is about proving the work, documenting the numbers, and filing correctly.

What happens if your building is over the emissions limit?

If your building exceeds its Article 320 emissions limit, you may need to reduce emissions or face penalties. Common next steps may include:

Reviewing your building’s current energy use
Identifying which systems are driving emissions
Improving heating system performance
Upgrading HVAC equipment
Improving lighting efficiency
Optimizing controls
Improving insulation and air sealing
Upgrading domestic hot water systems
Evaluating electrification options
Considering renewable energy where practical
Creating a longer-term decarbonization plan

The right path depends on the building. A large multifamily building, an office property, and a mixed-use property may all require different strategies. The goal is not to throw money at upgrades randomly. The goal is to reduce emissions in the smartest, most cost-effective way possible.

What are the penalties under Article 320?

Article 320 can carry real financial consequences. If a covered building exceeds its emissions limit, the annual penalty is generally calculated based on how far the building is over its limit.

The maximum annual penalty for excess emissions is calculated by multiplying the building’s excess emissions by $268 per metric ton of CO2e.

There are also penalties for reporting problems, including:

Failure to file: $0.50 per building square foot, per month
False statements: fines up to $500,000

In other words, missing the mark can get expensive quickly. As limits tighten in 2030, more buildings may find themselves at risk if they do not plan ahead.

What is Good Faith compliance?

The Good Faith compliance pathway was created to give certain building owners some flexibility during the first compliance period. If an owner can show they are actively working toward compliance, they may be able to avoid or reduce penalties during the 2024–2029 period.

Good Faith compliance may involve:

Filing required reports
Staying current with other energy-related laws
Retaining qualified professionals
Creating a decarbonization plan
Beginning work to reduce emissions
Demonstrating real progress toward compliance

Beware. Good Faith is not a free pass. DOB can still enforce penalties if the owner does not follow through or cannot show meaningful action. Think of it as the city saying, “We’ll give you room to fix it, but we are absolutely keeping the receipt.”

Why Article 320 matters for building owners

Article 320 matters because it turns building emissions into a direct compliance and financial issue. For NYC owners and property managers, this affects:

Annual reporting obligations
Operating costs
Capital planning
Building systems strategy
Future retrofit decisions
Penalty exposure
Property value
Long-term compliance planning

Article 320 compliance checklist

If your building falls under Article 320, you may have to:

Confirm whether your building is covered by Local Law 97
Confirm whether Article 320 applies
Identify your building’s occupancy type
Determine your applicable emissions limit
Gather utility and energy usage data
Calculate your annual greenhouse gas emissions
Compare your emissions against the legal limit
Work with a registered design professional
Prepare and certify the annual emissions report
Submit the report to DOB by the required deadline
Identify whether your building is at risk for penalties
Review possible efficiency upgrades or operational improvements
Create a plan for the stricter 2030 emissions limits
Keep supporting documentation organized

Common mistake: assuming Article 320 is just another filing

Article 320 is not just a reporting rule. It is an emissions-limit law with financial penalties attached. So, if you are on the covered buildings list then yes, you need to file.

While many property owners believe they are on track because they comply with Local Law 84 benchmarking, this is a dangerous misconception. LL84 merely requires you to report your energy data; Article 320 of Local Law 97 penalizes you based on that data.

Article 320 and the 2030 problem

The 2024–2029 limits are only the first phase. The bigger challenge comes in 2030, when emissions limits become stricter. That means some buildings may pass today but fail later if they do not make improvements. Building owners should use the current compliance period to understand their exposure, plan upgrades, and avoid being boxed into expensive last-minute work.

Local Law 97 Article 321: Compliance for Affordable Housing & Houses of Worship

Thu, 01 Jan 2026 19:10:40 GMT

Local Law 97 is not one-size-fits-all. Under LL97, different buildings follow different compliance pathways depending on their use, ownership, and classification.

Most private buildings fall under Article 320. But certain affordable housing properties and houses of worship may fall under Article 321, which has its own rules, requirements, and compliance options. If your building qualifies under Article 321, you may have an alternative path to compliance. But let’s be clear: Article 321 does not mean you get to ignore LL97. It just means the city gave you a different maze.

What is Article 321?

Article 321 is part of Local Law 97 and applies to certain buildings that are treated differently from standard private buildings under Article 320. Article 321 generally covers:

Affordable housing properties
Certain rent-regulated buildings
Houses of worship
Buildings with specific housing or occupancy characteristics

Article 321 is supported by DOB rule 1 RCNY §103-17 , which explains how the Department of Buildings enforces this compliance pathway.

The big takeaway

Article 321 buildings may have a different compliance path than Article 320 buildings. But different does not mean exempt.

If your building falls under Article 321, you still need to:

Understand your requirements
Complete the right work
Submit the proper report
Keep documentation in order
Work with the right qualified professional

Article 321 vs. Article 320

LL97 is broken into different articles because not every building is treated the same way. Here’s the simple version:

Article 320 applies to most covered private buildings.
Article 321 applies to certain affordable housing properties and houses of worship.
Article 320 focuses heavily on annual greenhouse gas emissions limits.
Article 321 offers alternative compliance pathways, including energy conservation measures.

Who may fall under Article 321?

Article 321 may apply to certain buildings that are not handled the same way as standard private buildings under Article 320.

This can include:

Affordable housing buildings
Rent-regulated buildings
Houses of worship
Mixed-use properties with qualifying housing or religious use
Properties with specific ownership, occupancy, or regulatory characteristics

This matters because two buildings can look nearly identical from the sidewalk but have completely different compliance obligations once you review the details. The question is not just: “Does LL97 apply to my building?”

The better question is: “Which LL97 pathway applies to my building?”

What are the Article 321 compliance pathways?

Article 321 buildings generally have two main ways to comply.

1. Performance-Based Compliance

Under this pathway, the building demonstrates that it meets the applicable greenhouse gas emissions limits. This usually means showing that the building’s emissions are within the required limit.

2. Prescriptive Compliance

Under this pathway, the building completes required Prescriptive Energy Conservation Measures, often called PECMs.

Instead of only focusing on whether the building is under an emissions cap, the owner shows that specific energy-saving improvements were completed.

What are Prescriptive Energy Conservation Measures?

Prescriptive Energy Conservation Measures are specific upgrades or improvements that help reduce energy use and emissions.

Depending on the building, these may involve:

Lighting
Heating systems
Cooling systems
Ventilation
Insulation
Domestic hot water systems
Controls
Building envelope improvements

The goal is simple: make the building more efficient and reduce waste. The city’s version is less simple, obviously. It involves rules, reports, certifications, and probably at least one spreadsheet that makes someone sigh audibly.

What is the Article 321 deadline?

Article 321 covered buildings were required to submit a compliance report to the Department of Buildings by May 1, 2025. The report depends on which compliance pathway the building follows.

For the prescriptive pathway, the report generally shows that the required energy conservation measures were completed.

For the performance-based pathway, the report generally shows that the building meets the applicable emissions requirements.

Either way, documentation matters.

This is not the kind of rule where “we upgraded some stuff a while back” is enough. The filing needs to match DOB requirements, and the work needs to be properly documented.

Who certifies Article 321 compliance?

Depending on the compliance pathway, Article 321 reporting may need to be certified by a qualified professional. This may include:

A registered design professional
A qualified retro-commissioning agent
A licensed engineer or architect, depending on the filing requirement

The important part to know here is that owners should not treat this as a self-attestation. DOB expects the report to be properly prepared, reviewed, and certified.

Are Article 321 buildings exempt from LL97 penalties?

Not automatically. Article 321 may provide an alternative compliance pathway, but covered buildings can still face enforcement risk if they:

Fail to submit the required report
Submit an incomplete report
Miss required deadlines
Fail to complete required measures
Choose the wrong compliance pathway
Do not maintain proper documentation

The safest move is to confirm the building’s status early, identify the correct pathway, complete the required work, and keep records organized.

Why Article 321 matters for affordable housing owners

Article 321 matters because it may provide a more realistic compliance path for certain affordable housing properties. Instead of forcing every building into the same emissions-limit structure as standard private buildings, Article 321 may allow qualifying buildings to comply through required efficiency measures. That can be helpful. But it is not automatic.

Owners still need to know:

Whether Article 321 applies
Which pathway they qualify for
What work must be completed
What report must be filed
Who needs to certify it
What documentation must be kept

Getting this wrong can lead to missed deadlines, unnecessary penalties, and the kind of last-minute scramble nobody wants.

Why Article 321 matters for houses of worship

Houses of worship may also qualify under Article 321. This matters because religious buildings often have:

Unique layouts
Older systems
Irregular occupancy patterns
Limited capital budgets
Mixed-use spaces
Historic or hard-to-upgrade building systems

A single property may include:

A sanctuary
Offices
Classrooms
Community rooms
Residential space
Event areas

That can make LL97 compliance more complicated than it looks on paper. Article 321 may offer a compliance pathway that better reflects how these buildings actually operate. Houses of worship should not assume they are automatically exempt just because they are religious or nonprofit properties. The building still needs to be reviewed.

Article 321 compliance checklist

If your building may fall under Article 321, start here:

Confirm whether your building is covered by Local Law 97
Determine whether Article 320 or Article 321 applies
Review whether your building qualifies as affordable housing, rent-regulated housing, or a house of worship
Determine whether your building must meet emissions limits or complete prescriptive energy conservation measures
Gather energy and building system documentation
Work with the right qualified professional
Prepare the required compliance report
Submit the report to the Department of Buildings
Keep records in case DOB requests support later

Local Law 97 (Article 321) Prescriptive Measures

§ 28-321.2.2 Prescriptive energy conservation measures. By December 31, 2024, the owner of a covered building shall ensure that the following energy conservation measures have been implemented where applicable:

Adjusting temperature set points for heat and hot water to reflect appropriate space occupancy and facility requirements;
Repairing all heating system leaks;
Maintaining the heating system, including but not limited to ensuring that system component parts are clean and in good operating condition;
Installing individual temperature controls or insulated radiator enclosures with temperature controls on all radiators;
Insulating all pipes for heating and/or hot water;
Insulating the steam system condensate tank or water tank;
Installing indoor and outdoor heating system sensors and boiler controls to allow for proper set-points;
Replacing or repairing all steam traps such that all are in working order;
Installing or upgrading steam system master venting at the ends of mains, large horizontal pipes, and tops of risers, vertical pipes branching off a main;
Upgrading lighting to comply with the standards for new systems set forth in section 805 of the New York city energy conservation code and/or applicable standards referenced in such energy code on or prior to December 31, 2024. This provision is subject to exception 1 in section 28-310.3, provided that July 1, 2010 is replaced by January 1, 2020 for the purposes of this section;
Weatherizing and air sealing where appropriate, including windows and ductwork, with focus on whole-building insulation;
Installing timers on exhaust fans;
Installing radiant barriers behind all radiators.

Common mistake: assuming Article 321 means “we’re exempt”

This is the big one. Article 321 does not mean LL97 disappears. It means your building may have a different way to comply.

That difference matters, especially for affordable housing properties and houses of worship. But owners still need to take action, file properly, and document the work. If you are not sure which article applies to your building, don't guess! LL97 has too many trapdoors for guessing.

I received an "N" letter grade, what does it mean?

Mon, 16 Oct 2023 19:58:02 GMT

What does this mean?

Per LL33, buildings that receive an “N” grade will not receive a label, and DO NOT need to

post by the end of October.

Are there any resulting ramifications/penalties for an “N” Grade?

No.

Your building may have received an N grade for any of the following reasons:

Number of Residential Living Unites under 20
Building has secondary retail space less than 5,000 sqft
Building has secondary retail space comprised by more than one individual store
Building has secondary office space less than 1,000 sqft
Building is “Mixed use” – building features multiple property use-types, none of which represent 50% of gross floor area or more.
Building is characterized by a primary use type that is not eligible to receive an Energy Star 1-100 score (Ex. Manufacturing/Industrial Plant, Parking garage)

Rent Stabilized Properties and LL97 Emissions Law

Mark@Redocs.com (Mark Balsam) — Fri, 16 Jun 2023 14:03:46 GMT

At first glance, NYC’s Local Law 97 emissions law seems to offer rent stabilized properties an olive branch.

Unlike their counterparts, rent-regulated buildings (defined as buildings with >35% rent regulated units) are provided with two “alternative compliance pathways” in which they can file a “one and done report” and be free of LL97’s requirements and emissions limits in perpetuity.

Here's why the alternative pathways are great on paper but not so great in reality:

One pathway is to demonstrate by May 1, 2025 that the property is already under the 2030 emissions limits, an unlikely scenario given that 80% of all NYC buildings already exceed that threshold.

The second is to implement (again by May 1, 2025) a list of thirteen prescriptive measures , a seemingly benign checklist that, upon closer inspection, reveals itself to be quite onerous and expensive.

While the prescriptive measures are “low hanging fruit” and beneficial, the price tag is likely to give pause to rent regulated property owners already reeling from the 2019 HSTPA, rising interest rates, and tougher credit conditions.

Replacing steam traps or installing TRVs or “smart radiator covers” are definitely advisable, but multiply them by all the radiators in a building and add some master venting on the steam risers and mains, pipe insulation on all water lines, etc and we find that that the low hanging fruit may not be so reachable after all.

And herein lies the problem...

The alternative pathways dangle the relief of a one-time report, but the trade-off is having to meet the stringent 2030 emission standards five years ahead of other buildings OR having to implement a potentially six figure list of prescriptive measures RIGHT NOW.

Rent stabilized buildings may want to play for TIME right now which is something the alternative pathways lack.

More time would allow...

for buildings to wait until 2027 when it is expected that they will be able to purchase “Renewable Energy Credits” to offset some of their emissions.

for buildings to wait for rules on purchasing “Carbon Offsets” and “Off-Site Solar” which could further offset emissions.

for buildings to wait for rules on obtaining extensions.

for buildings to wait for a potential change in the political winds. Currently there is legislation to extend the compliance deadlines for seven years.

for newer and better financing options for upgrades than what exist today.

for more rules on the process of which there are precious few right now. Do buildings really need to do the prescriptive measure in every unit? How does DOB propose getting access to units?

So what's the best move for Rent Stabilized properties here?

If you haven't read my initial opinion on Local Law 97, you can read it here .

We’re offering an affordable program built specifically for rent-stabilized buildings. Call us at 212.650.1591 or email us at Sales@Redocs.com .

Local Law 97 Q & A - ReDocs Roundtable - Ep 02

Mon, 12 Dec 2022 13:45:02 GMT

President of ReDocs, Mark Balsam, sits down with Marketing Director Kate Hoffer to discuss questions that customers and building owners alike are asking about Local Law 97.

Quick Summary:

It's hard to determine what LL97 is going to cost each building. It's unique to the building's needs.
Financing for energy efficiency is growing and it's availability is increasing.
Buildings with rent stabilized units will have to comply with a set of prescriptive measures.
Energy letter grades may help push building owners to improve on their score, depending on the building type.

Don't feel like reading the transcript? Click here to watch the Round Table.

Full Transcript

Mark Balsam

Okay. All right. Kate, you've been here with ReDocs now for about eight months. And I understand you have some questions about Local Law 97. What it is, what it means for buildings in the city.. So, fire away!

Kate Hoffer

Yeah, sure. So, amongst my research and seeing what our customers are asking, I gathered some questions for us to discuss Local Law 97 that I think would be really insightful for us to get your opinion and your position on some of these questions.

Mark Balsam

Sure.

Kate Hoffer

Will the buildings be able to afford the upgrades? Or do you think that they're gonna have to just get stuck with the fines and where do you think that they're gonna get this money from?

Mark Balsam

Right. It's a good question. Well, first of all, let's just take a quick step back and you know, just to bring everybody up to the same level. Local Law 97, which has now been in the books for a few years but hasn't actually come into effect just yet. Basically puts emissions caps on buildings in New York City over 25,000 square feet.

So the idea is that through some sort of reporting mechanism, buildings will have to report what their emissions are each year and they have to be below preset caps. Otherwise they'll be subject to fines which can, in some cases be quite substantial.

So to answer your question, Kate, you asked me about the expense of it. And you know what, in other words, what happens if a building is above their cap? What can they do about it and is it expensive? Was that the question?

Kate Hoffer

Yes.

Mark Balsam

Yeah. Well, it's a good question, I think, to a large extent, because as I said, the law is in effect, yet. They haven't even written all the rules yet of how it's going to work. We don't even know what the forms look like or the web portal for how you're going to disclose to the city what your emissions are. But, you know, it could be expensive, depending on how far over the cap you are. You know, the the fines themselves can get quite substantial. You know, it may come down to replacing systems doing a major retrofit of the building, or it may be something simpler. You know. The other thing we don't know yet is that there seems to be some plans for provisions which will allow buildings to buy credits to offset some of their use their emissions as opposed to actually doing work. However, we don't know exactly what that's going to look like yet.

We do know that the plan is to only allow buildings to apply the credits to grid purchased electricity. In other words, they couldn't apply the credits to emissions resulting from oil or natural gas or something like that. So it's really hard to say what the costs are going to be.

Assuming that for some buildings, it is a large cost. The financing world for energy efficiency has come a long way. Right now there's something called PACE financing, which is it's something that's authorized by individual municipalities and now it's been authorized by the City. And that basically allows lenders certain lenders who have signed up for the program to lend to buildings on energy and emissions reduction, upgrades and then the payments are secured through an on bill mechanism, an on tax bill mechanism, whereby the the billing to the the building owner or Co Op or condo what have you is done through their tax bill. And so the idea is that lenders are more comfortable with the risk because, you know, it's being paid as part of that their loan is being paid back as part of the tax bill.

So more mainstream lenders are starting to get more interested in, you know, at what lending might look like, even, you know, banks that land on acquisitions of buildings are more interested now. And, well, maybe there's a benefit to us for the building to also be energy efficient. So there's a lot of interesting things brewing but again, it's kind of early in the game. And that's a long answer for you.

Kate Hoffer

No, that's good I'm wondering along the same lines of building owners being able to afford these these upgrades and you're talking about different lending opportunities.

What about - I was reading in the New York Daily News recently that somebody had suggested a program called the E 51 program, which will allow for partial property tax abatements. For those that use energy conservation measures, and I don't think that's defined, what do you think about that? Have you have you read up on this?

Mark Balsam

It's funny, I hadn't heard that term before. You asked me about it just before we got on, but I kind of knew with and then I did take a look at the article you're referencing and I kind of knew already, what it was. Basically it was a suggestion made, which may or may not be a good one that maybe the City implement something similar to what many building owners would know as the J 51 program. Where you know, in the J 51 program, building owners would do capital improvements to the building to upgrade the building and would get tax abatements in return. So the idea with this E 51 thing. And by the way, this is just it looks like it's just one person suggestion. I don't think there's anything real about it. But the idea behind the E 51 abatement would be that you would spend money on energy upgrades and get a property tax abatement on the building. I would be even if that were to come into effect. I would be very, very skeptical of it.

Building owners have been through quite a number of problems with the J 51 program which we don't have to get into but I would be worried that the same problems would exist with an e 51. Program. Interesting thing, you know, the E 51 idea, though. Yeah.

Kate Hoffer

Do you think that it's fair that building owners are going to have to comply with this if they don't have the resources, the financial resources to be able to keep up with the upgrades that in time for their due dates?

Mark Balsam

Yeah! I mean, look, there are a couple of things. So one is the law already has a carve out for buildings with rent stabilized units. I believe if a building has 35% of its units are rent stabilized, meaning that there's a pretty good chance it's, it's in somewhat of a, you know, an affordable or it it's providing some level of affordability.

In those cases, the building won't be subject to the emissions requirements, they will have to take a certain set of what are called prescriptive measures. Unclear if they'll have to do it yearly, or if they'll have to do it once and show it, but there's basically a laundry list of, maybe 12 or so low hanging fruit, pipe insulation, things like that, which these building owners will have to do.

But they don't have to worry necessarily about being over the cap and getting fines or having to do some sort of major retrofit to get there. So there's that.

There's also, as I mentioned, there's going to be some level of credits involved in this where a building owner can buy credits to offset some of their emissions, which presumably would be less expensive than doing some sort of energy upgrade.

And then, you know, you have some good faith provisions where if you can show good faith that you're trying and you haven't gotten there, although we don't really know anything about how that's going to work, but it allegedly, there will be some mechanism for showing that you have tried or that you have some sort of hardship, which is impeding your ability to reach the emissions goals. So there are some things and it looks like there are more and more as we get closer to the law being rolled out where the City is taking some steps to try to alleviate some of the pain which might result from this.

Kate Hoffer

Right. Right. Interesting. I think that's a little more comfortable to hear for building owners that there'll be practical steps that you can take rather than

Mark Balsam

Yeah, yeah, well, if you've heard me say it, it's why I don't have a a firm piece of advice for buildings as a whole. It's really building my building. I think that there are certain cases where it might make sense for a building to just take a wait and see attitude on this law. For a variety of reasons.

One, as we said, there are going to be energy credits. We don't know how it's going to work, how much it'll be helpful. That has to play out. We're still about a year away from 2024. When this actually comes into effect, a lot can happen in the rulemaking process and in the law.

There's certainly an argument to be made for some people to like, slow down. Let's see how this progresses. But then there's also an argument to be made. I've heard some people say that look, contractors are going to be scarce when you're going to need them the most. If you wait, you know, I don't know if I buy that. But that's that's one argument.

Some buildings have the funds, you know, they have the vision, the forward thinking. They want to be at the forefront of this. And for those buildings, it may might make sense to you know, start dealing with this now. You know, what I can tell you in our own business is that you know, we've been consulting on this with our clients a lot more in the last year and you know, it's become more being a New York City energy consultant has become more than just doing the benchmarking and just doing the Local Law 87 energy audits. I mean, that's important.

But, you know, I think it's reasonable for a client to expect that they that for the price of doing the benchmarking and for the price of doing the Local Law 87 and energy audits that they should get some sophisticated consultation on Local Law 97, on the energy letter grades, which I know you had a question for me about as as well.

And so yeah, I think that's reasonable to expect, you know, and we certainly do that with our clients. I mean, we're providing, you know, a no additional cost, Local Law 97 penalty analyses we're doing letter grade analyses, I mean, basically, where we're helping in all, all areas associated with, you know, the benchmarking and the and the audit and just New York City Energy compliance.

Kate Hoffer

Right, right. So that leads me to my next question perfectly about the energy efficiency grade analyses. So, my question was going to be do you think that the energy efficiency grades are going to be a motivation factor or more of a nuisance, but if you could explain, it sounds like you break down the whole entire grade per building with your customers, if you could tell me how you feel that benefits them? That would be really interesting.

Mark Balsam

Yeah. So it's important to note, first of all, I think people are understanding this more than they were a year ago. But the energy letter grades are different from the Local Law 97 emissions requirements.

The energy letter grades are basically each year you do your Local Law 84/133 Energy Benchmarking, which has been on the books now for many years. And based upon that data, and how efficient or not efficient your building is, you are basically given a letter grade, which you then have to post somewhere conspicuously at your building. So, and that is truly about energy. It's based on total energy usage, not on emissions, then the Local Law 97.

While of course, there's a lot of overlap between energy efficiency and emissions. It is different in that it's a law first and foremost, to reduce emissions. It's separate from the letter grade. The cap and the letter grade don't have anything actually to do with with each other in practical terms, but is it a motivation? It's interesting, I thought, when they first when the City first rolled out the letter grades that nobody would care. And I was mistaken! I think it's, what it has done is - Yeah, sure. It is a nuisance. Every regulation is a nuisance on buildings and I do get that.

But it's also, what I think it's done is it's stirred the conversation. It's brought more awareness and more of a spotlight to the conversation around energy efficiency. It's kind of like you know, if you saw it, it's like the restaurant letter grades for you know, cleanliness, it's something that's hard to ignore. And yes, there are a bunch of buildings that really, you know, they don't want a D or a C or anything less than an A on their building.

And, you know, it really, it's again, it's building by building but I do think it has stirred the pot in a certain way to different extents for different buildings.

Kate Hoffer

Yeah. So instead of thinking that somebody gets their letter grade on their building, you thought that everybody would brush it under the rug. It's just a thing, a requirement that we have to post up now.

Now, you've seen that it's generated all this conversation and that people actually do care and that they are interested in improving that number. And do you think that people want to improve that number because of the tenants that are in their building? Or what is their motivating factor?

Mark Balsam

Great, great question, I mean, I again, it's a building by building thing. So you have buildings, certainly office buildings, we know more and more companies. have made a commitment to, you know, environmentally friendly practices. ESG. And so certainly for office buildings, I think it's becoming more and more important to the tenants.

I think, you know, definitely a co op or condo where the residents own their units. it's becoming more and more important to, you know, first of all feel like they're living in an efficient building. And also there's also a cost element to it, too. You have to pay your portion of the maintenance or the common charges.

And so to know that your building is operating efficiently, is a good feeling from a financial standpoint, too. Then there are areas in buildings where I don't think tenants care that much, you know, it's more of you know, it's more of a consideration over rent, what's reasonable, what's not just like always, so.

Kate Hoffer

Right. Yeah, that makes a lot of sense. From a tenant's perspective. Yeah. Mark, thank you for taking the time to answer my questions.

Mark Balsam

Yeah. Thank you.

Standard Carbon - ReDocs Round Table - Ep 01

Wed, 30 Nov 2022 16:04:08 GMT

What is Standard Carbon and how can NYC building owners benefit from it? And most importantly, does it make sense financially? Also, find out how you can decarbonize a 100-year-old NYC building with their existing boiler system. Mark Balsam sits down with Nathan Winkler to discuss Standard Carbon in ReDocs' very first roundtable.

Quick Summary:

Standard Carbon changes the carbon dioxide coming out of the chimney into natural gas.
It can be utilized in industrial and commercial facilities, as well as residential, such as NYC apartment buildings.
Use in tandem with solar panels and off-peak hours, it can be well worth the investment.
Installing this system can qualify for a number of tax credits.

Don't feel like reading the transcript? Click here to watch the Round Table.

Full Transcript:

Mark Balsam

So Nathan, you have a I don't even know what to call it a product? A system? You're one of the founders of something called Standard Carbon?

Nathan Winkler

It's a product at this point, yeah.

Mark Balsam

Can you tell me what it is? And, what it does?

Nathan Winkler

Yeah. Standard Carbon takes what's coming out of the chimney of your boiler and it removes the carbon dioxide from that exhaust going out the chimney and turns that carbon dioxide into natural gas. And it does that using electricity. Which ideally will come from a renewable source.

Mark Balsam

Got it. And I actually saw one of your videos - I forgot if it was on your website or if you posted it on LinkedIn - but you actually had, you are connected to a car's exhaust ..

Nathan Winkler

My car!

Mark Balsam

.. and then on the other end, you lit a cigar! I'm assuming it's the same process. You're capturing the exhaust and then creating natural gas which then is a, you know..

Nathan Winkler

Correct! When we tested the system we hooked it up to my car, put a brick on the gas pedal. Of course it's a lease, so whatever damage you do the engine, it's on the leasing company, not me. And then the natural gas reproduced at the other end. We wanted to create a visual so in the efforts of being politically correct, we thought Cuban cigars would be the most appropriate way to show off natural gas that we produced from the carbon dioxide emissions coming out the tailpipe of the car.

Mark Balsam

Right. And is there an application for New York City buildings? I know that just in separate conversations, you said that the ideal candidate is some sort of industrial or commercial facility. But, you know, does it work for a New York City apartment building?

Nathan Winkler

Absolutely. The best application is like you said probably larger scale but actually the origins of the idea was my work in New York City. The issue with New York City buildings is that they're 100 years old, oftentimes, and it's really difficult to keep them other than with the existing boiler steam system and everything you have in place. And so, if you can keep that boiler and steam system exactly as is and then just remove the carbon dioxide from it and do something useful with that carbon dioxide. You can essentially decarbonize the heating system of your building without demolishing what's already there, and that's a huge advantage. And that's where what we're doing is applicable because we can install our product right next to the existing boiler, capture the exhaust from the boiler, convert the CO2 in the exhaust into natural gas, feed that natural gas back to the boiler, and run the whole thing off off-peak electricity or from solar panels on the roof. Electricity from another source.

Mark Balsam

But that's a good point. My understanding is that in order to recycle the exhaust gases back into into natural gas, you're using a process called "electrolysis," is that right? Is that the term for it?

Nathan Winkler

So, diving into the technical aspects, there are three main processes inside the Standard Carbon box. There's carbon capture to separate CO2 from everything else in the exhaust gas, and isolate it, so you have pure CO2 that we can work with. There's electrolysis, which is the using electricity to split water into hydrogen and oxygen. So we have hydrogen. And then there's a third part, methanation, where we combine hydrogen and carbon dioxide together to produce methane. And methane is the primary constituent of natural gas.

Mark Balsam

Sure, so there is a considerable amount of electricity that this product consumes in order to - provide - to turn it back into methane.

Nathan Winkler

Absolutely. It continues -

Mark Balsam

Is that a deal breaker for a lot of buildings. Is it going to pencil out?

Nathan Winkler

So, assuming that you can get electricity from the grid at off peak times, or that you can install solar panels then it's a home run. So, I was shocked. I looked at the locational-based mean pricing from Manhattan. And -- more than 20% of the time the price drops below two cents a kilowatt hour in Manhattan. So it's possible to get off-peak, really cheap electricity. Also, if you're generating electricity on site with solar, that solves the whole issue as well.

Mark Balsam

And you're doing or you're discussing a project currently in a New York City apartment building where solar is a component of it? I understand.

Nathan Winkler

So, the project that we have the informal 'go ahead' is a multifamily building in Brooklyn. And actually, it's a complete home run because they're going to install our system with solar panels. So, all the electricity that's needed is going to be generated on site. They're gonna get the full value of the solar if they didn't have us then they'd have to export to the grid and get paid pennies on the dollar relative to the value of the electricity they're producing. And because it's coming from solar, they're gonna get the full Inflation Reduction Act tax credits. So we're looking at a simple payback of less than two years for the whole system to decarbonize the building. So, the building is going to be carbon neutral, and they're gonna make a fortune in the process.

Mark Balsam

And presumably, that plays into Local Law 97 as well and has some benefits there and that the emissions are averted.

Nathan Winkler

We're not even taking into account the fact that we eliminate their Local Law 97 penalties in our analysis because the value of essentially producing free natural gas for the boiler from solar panels on the roof, plus the tax credits is so enormous that we didn't need to even discuss Local Law 97 penalties kicking in in 2030 to justify the investment.

Mark Balsam

And I understand that this building that you're in discussions with they are also they've optimized their steam heating system. And so that was one thing that allowed this to work for basically their solar installation to provide enough to cover the load, essentially.

Nathan Winkler

Yeah, these owners have done everything possible to take a building built in the 1930s and make it as efficient as possible, so their annual gas bill of about $30,000 a year, that includes domestic hot water, and heating for a 50-unit multifamily building. That's about half of what we typically see for a building that size in New York City. And the reason why it's so low is because of the work they've done to make it as efficient as possible. If they had not reduced their load to that extent then we wouldn't be able to make the building carbon neutral. It's really because they've done the hard work of doing all the boring stuff already over the years, now we can come in with something really exciting, and push them to 100%.

Mark Balsam

Right. Now I'm curious, let's say they were more typical. And they hadn't reduced their fuel usage as much. Understanding that they couldn't become carbon neutral, does it still work? The numbers.

Nathan Winkler

So, the financials would still work.

Mark Balsam

Right

Nathan Winkler

What makes it work financially is the fact that the electricity is coming from on site solar panels.

Mark Balsam

Right.

Nathan Winkler

The wild card with a building, which doesn't have rooftop solar, is we don't know if we're getting electricity from the grid, what that means as far as tax credits. We also then have a more complicated task of getting off-peak electricity pricing. So, it's really simple and a home run, if you have on site solar.

Mark Balsam

Might that be a viable package moving forward that, you know, in future applications, you know, you actually might want to do the solar in tandem with this?

Nathan Winkler

Absolutely. They did not do solar in the past because they had no place to use the electricity. So this gives them the load to justify the solar investment and the solar developer will finance the entire deal. So, that's really a win for everybody. They go to one bank, so to speak, the folks that are putting in the solar panels, and those guys are more than happy to finance this as well because this is what's justifying the whole solar project. So, packaged together, it makes the whole thing work. And they said they would not have done the solar project if it wasn't for what we're bringing to the table. They're installing everything at the same time.

Mark Balsam

Interesting.

Nathan Winkler

So I would say the only difference with a typical building is if, you know, we could perhaps drop the carbon emissions by half as opposed to eliminate them entirely, if the building's not as efficiently operated, so it's still worth it to do the boring stuff, like I said.

Mark Balsam

Right. Wow! That's something! And then you get, you mentioned, you get the Biden Inflation Reduction Act, tax credits. Well, you get the tax credit on the solar side, which my understanding is back to being, you can actually redeem cash for it?

Nathan Winkler

Yes, it's a credit. It's -

Mark Balsam

You don't need a tax appetite in order to -

Nathan Winkler

Mark Balsam

Right

Nathan Winkler

It's money in your pocket. I don't think many people appreciate yet how much money is on the table with the Inflation Reduction Act Right In so many different areas. So, in our case, we're talking about our hydrogen production aspect. That's where the subsidies or the tax credits are through the roof. But in so many other areas as well, energy efficiency measures, carbon capture, you name it, they literally have opened the floodgates to an enormous amount of money,

Mark Balsam

Right

Nathan Winkler

that is going to really change the landscape.

Mark Balsam

Well, now what's the other one I wanted - so you have the - assuming you were to do solar and Standard Carbon, so you have the solar investment tax credit, but there's also, as you were mentioning, the hydrogen production credit? Is that the other thing that you would be -

Nathan Winkler

Correct! You'll get the hydrogen the Clean Hydrogen Production tax credit, the solar tax credit , potentially the Carbon Capture tax credit in our case, as well. So as I said, it's just a fantastic amount of money from Uncle Sam. I always joke when I speak to folks about this in Europe, and they criticize the United States, when it comes to climate issues. I say, "Yeah, perhaps the US is slow. But when we do do things, we do it on a scale, like the likes of which the world can't imagine and has never seen." And that's definitely the case. The Inflation Reduction Act is so much money, it's literally caused the European Union now to pass legislation to match the rebates because all of their manufacturers are saying there's no point in us doing business in France, because we just want to sell in Texas because of this new law. It's a huge opportunity.

Mark Balsam

Very cool. And so if someone wanted to, someone listening to this said, Hey, I've got a multifamily, let's say in in New York City, what would be the next steps that they would take? What would be the next steps on your part?

Nathan Winkler

I would tell them, if they have the ability to install solar in the building or they already have solar in the building, then it's a home run and we should do something. If they don't, then it's a more complicated analysis. Still worth exploring, especially if they are looking at very large Local Law 97 penalties.

Mark Balsam

Sure. Oh, and finally, how big is this thing?

Nathan Winkler

About the size of the boiler itself? So smaller boiler, our equipments gonna be smaller. Larger, more boilers will take up more space, but it more or less matches one to one in terms of space.

Mark Balsam

Very interesting. Very cool. Well, thank you. Thanks for walking me through it.

The Truth About Local Law 97

Mark@Redocs.com (Mark Balsam) — Thu, 09 Sep 2021 18:14:28 GMT

Enough with the Local Law 97 fear mongering.

Do a Google search for LL97 and you’ll find consultants offering to help you avoid HUGE penalties and fines by helping you comply with Local Law 97.

Update your building with energy, renewables and retrofits because the energy savings pencil out. But don’t incorporate phantom LL97 fines into your underwriting.

We’re still two years away from this law coming into effect, which in City government terms is more like two dog years. DOB and DEP have yet to write a single rule as to how the law will be implemented. Without rules, there is no game, so consultants telling you they know how to play are disingenuous, at best.

There are no forms, websites, portals or any other mechanism for actually “complying.” 80% of NYC buildings are ALREADY below the emissions threshold – which means no penalties . This will change in 2030 when the emissions thresholds are tightened, but now we’re talking at least EIGHT years away.

Add to this, the City is already showing signs of softening on the law in response to considerable political opposition. And Cuomo (granted he doesn’t have a lot of political capital right now) is pushing a system that would allow buildings to avert emissions penalties by purchasing renewable energy from upstate.

The following advice probably hurts my business, but then again I’m in the business of giving the best possible advice to NYC buildings, so who knows.

At this time, I would advise NYC buildings to NOT SPEND too much effort on the upcoming Local Law 97 carbon emissions law AKA the “Climate Mobilization Act.”

To be clear, I’m NOT suggesting that buildings completely ignore this. Some planning should take place. Your LL84/L133 consultant should provide you with a snapshot of your emissions. ReDocs does.

I’m also not suggesting that climate change is unimportant. Quite the opposite. It is the issue of our time. But I don’t want buildings to waste time, money, or effort on something so distant and nebulous.

Can I Self Certify Mold Violations?

Mark@Redocs.com (Mark Balsam) — Fri, 29 May 2020 20:54:39 GMT

When Can I and When Can't I Self Certify an HPD Mold Violation

An HPD mold violation cannot be self addressed or self certified if both of the following conditions exist:

Class B or Class C Violation(Class B is mold > 10 sf and Class C is mold > 30 sf)
Building is ten (10) units or more.

In this scenario, the building needs to involve a NY State Licensed Mold Assessor AND a SEPARATE NY State Licensed Mold Remediation Contractor. You can read more about this here.

If, on the other hand, the violation does not meet one aforementioned conditions, than the building may self address and self certify.

Lead Paint Apartment Turnover Requirements

Mark@Redocs.com (Mark Balsam) — Fri, 29 May 2020 17:20:11 GMT

Required Lead Paint Turnover Records

1. You need to show documentation that the unit was inspected upon vacancy and that the following conditions were assessed.

Are friction surfaces(window frames, doors, door frames) painted?
Are there any underlying defects and/or hazards?(chipping/flaking paint, teeth marks on chewable surfaces, damage to painted surfaces)
Are there window wells,, window sills, and/or floors that are NOT smooth and cleanable?

2. If any of the above conditions existed during inspection, than you need to to show documentation that you followed all of the work practices discussed here.

3. If none the above conditions existed during inspection, that documentation showing that the unit was inspected for these conditions will suffice.

NYC Buildings will be Graded on Energy Usage

Mark@Redocs.com (Mark Balsam) — Tue, 26 May 2020 17:32:54 GMT

NYC Buildings will be Graded on Energy Usage

You've seen letter grades in restaurant windows and soon you'll see them posted in your building's windows.

Starting in 2020, under Local Law 33 of 2018, NYC buildings over 25,000 square feet will need to post an energy efficiency letter grade, A-F, in a "conspicuous" location.

A building's grade will be based upon the information reported in its annual Local Law 84/133 benchmarking report to the City. The website through which the benchmarking information is reported, EPA's Portfolio Manager, will calculate an EnergyStar score 1-100 based on the energy usage and building data reported. The higher the EnergyStar score, the higher the letter grade. And vice versa.

In speaking with a lot of my clients, there's a mix of different feelings about these letter grades. Some people care. Some don't. Some think the grade will make a building more or less attractive to potential tenants or buyers. Some think it doesn't make a difference.

What is clear is that the LL84/133 energy benchmarking data which many buildings have been submitting for nearly a decade is no longer going into a black hole. It is being used to make a judgement on your building, one which could potentially have an effect on its value.

No matter how you do your annual benchmarking filings(with us, with another company, or by yourself), it is worth taking the time to understand how your buildings annual benchmarking reporting informs your EnergyStar score which in turn informs your letter grade. Whoever does your benchmarking should understand and be able to articulate to you how the algorithm works, how your grade is determined, and what you can do about it.

Please don't hesitate to call me at 212-650-1591 x 112 to discuss further. We handle NYC energy and environmental compliance for nearly 3000 buildings.