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As we enter the second quarter of 2024, the New York City building industry is starting to feel the impacts of climate-focused legislation and regulations coming into effect this year. Much talked about carbon-saving policies, including building emissions limits (Local Law 97), natural gas bans (Local Law 154) and phase-out of high global warming refrigerants all start to take action in 2024. NYC has a unique opportunity to show the rest of the country and the world how these requirements can reduce emissions rather than driving fines and infractions.
The historic Local Law 97 (LL97), which regulates building emissions, takes effect this year. Energy that buildings are using right now will count towards the first round of LL97 carbon limits. Building owners are preparing to deal with the impact of exceeding the emissions limits. While for many owners, the first threshold period (from now through 2029) is not terribly onerous; the law, the associated carbon limits and the resulting fines are now tangible.
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In addition to the emission limits, 2024 marks the first year that some new buildings and major renovations in NYC will not be allowed to design systems with onsite combustion of fossil fuels. Local Law 154 (LL154), commonly referred to as the natural gas ban, went into effect for buildings less than 7-stories on January 1st, 2024. While this does not affect larger buildings yet, most other buildings will follow by January 2, 2027.
If that isn’t enough exciting Decarbonization momentum, NY State refrigerant phase-outs start this year. These regulations aim to limit the climate impact of the heating and cooling systems we use in buildings; they regulate the Global Warming Potential (GWP) of the refrigeration chemicals needed in most HVAC systems. NY State is one of the earliest adopters of the new refrigerant limits and many pieces of equipment are now under new requirements as of January 1, 2024. Most other HVAC equipment will follow next year.
All these industry leading regulations are critical to mitigate the effects of climate change. They present exciting opportunities for the buildings in which we live and work. They also create some confusion and challenges as owners plan to upgrade buildings to meet carbon limits and develop buildings that do not consume fossil fuels. To meet these challenges, manufacturers are developing equipment with new refrigerants, engineers are specifying new equipment technologies and filing projects with tight regulation timelines in mind, and contractors are trying to purchase new equipment while navigating long lead times and the timelines of these laws.
Perhaps the most common and clear long-term response to the LL97 and LL154 regulations is to consider a variant of heat pump technology as the primary source of space and domestic water heating, whether in new building designs or in renovating existing space. Enormous improvements have been made in this technology and its availability in the US over the last 5+ years and we are now able to confidently design and build systems that heat efficiently in our climate without the use of fossil fuels. However, there are also challenges associated with these systems, particularly in existing buildings where existing mechanical and electrical infrastructure can prove difficult and costly to convert to heat pump ready systems.
Additionally, for any heat pump design, product availability and costs have been a challenge, coming on the heels of the Covid-driven supply change issues, inflation and further complicated by the refrigerant regulations that are making it challenging to plan for equipment that will comply. Furthermore, the refrigerants required to meet the new GWP limits are often considered slightly flammable (referred to as A2L) refrigerants. There are still unknowns in how the city and local governments will regulate the installation of these A2L refrigerants, creating challenges for buildings looking to design and install these systems today.
To embrace the challenges and achieve the desired outcome of dramatic reduction in carbon emissions, owners and their team members should consider the following:
- Owners should plan for a full or hybrid heat pump future even if it is not implemented today.
- Designers should inform and educate owners on available technologies.
- Project teams should include contractors in discussing construction timelines and consider lead times and refrigerant types when designing for installation dates.
- Explore available incentives—including local, state and federal—some of which are quite beneficial, particularly for existing building retrofits.
Resources to estimate and track emissions and progress towards LL97
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, 2024-04-15 11:03:03
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