Over the past decade, New York City has experienced a surge in construction, witnessing the addition of approximately 1,000 to 3,000 new buildings annually. A recent report from REBNY Quarterly New Building Construction Pipeline, analyzing Department of Buildings filings from 2008 to 2020, showcases an impressive yearly increase of 35 to 45 million square feet of new structures. While the majority of these constructions consist of one or two-family homes, a notable number of buildings exceeding seven stories are added to the cityscape each year. Recognizing the pivotal role buildings play in greenhouse gas emissions, New York City has embarked on an ambitious mission to reduce fossil fuel consumption.
Enter Local Law 154 (LL154), a groundbreaking initiative by the NYC City Council aimed at steering the city towards sustainability. LL154 tackles emissions by curbing the combustion of certain substances in new or substantially renovated buildings. In simpler terms, it seeks to revolutionize the way buildings obtain their heat, cooling, and hot water. Let’s delve into the key points of LL154, exploring its implications, implementation timeline, and the transformative changes it brings to building systems.
What is LL154?
Commencing in 2024, LL154 prohibits the burning of substances that emit 50 kilograms or more of carbon dioxide per million BTUs of energy in new or substantially renovated buildings. This includes fossil fuels such as natural gas, fuel oil, and coal. Instead, these buildings are mandated to rely exclusively on electricity for heating, hot water, and cooking. While this transition is impactful, it raises legitimate concerns about the city’s power grid capacity and the practicality of such a comprehensive switch.
Currently, a staggering 85% of New York City’s power is derived from fossil fuels, underscoring the city’s heavy dependence on them. Nevertheless, NYC has committed to transforming its electricity grid into a zero-emissions powerhouse by 2040, involving plans for offshore wind farms, solar arrays, increased transmission capacity, and robust energy storage facilities.
LL154 also mandates changes to heating and cooling systems, advocating for a shift to air-source heat pumps for larger buildings. Despite higher installation costs, the long-term benefits include enhanced energy efficiency and compliance with LL154 standards. The law also accommodates alternative systems for smaller buildings. Concerning domestic hot water systems, LL154 envisions a transition from traditional electric hot water heaters to air-sourced heat pumps and water-to-water heat exchangers for larger buildings. While LL154 does provide a technical option for buildings to use gas if permitted through a filed permit before the deadline, there’s a potential risk of future renovations necessitating a conversion to electric systems, aligning with the city’s evolving sustainability goals.
Important Dates to Know:
Applications for New Buildings or Alterations with Existing Elements to Remain (alterations that must be filed as New Buildings) must be submitted on or after the following dates:
- January 1, 2024: for Group R-3 (1,2 family homes) and all occupancies less than 7 stories (excluding Service HW)
- December 31, 2024: for NYC School Construction Authority projects
- December 31, 2025: for Affordable Housing less than 7 stories (excluding Service HW)
- July 2, 2027: for all occupancies (includes Service HW)
- December 31, 2027: for Affordable Housing 7 stories or taller (includes Service HW)
LL154 will be implemented gradually to facilitate a seamless transition, allowing the market to develop the necessary products, training, and design strategies. The law stipulates specific dates for submitting applications based on building types.
Is Your Building Exempt?
Certain buildings are exempt from LL154, such as those used by regulated utilities for energy generation, buildings operated by the Department of Environmental Protection for treating sewage or food waste, and specific spaces within buildings where fossil fuels are indispensable for manufacturing purposes. Some examples also include the following building space use types:
- Hospitals and Crematoria
- Commercial Kitchens
- For Emergency or Standby Power
Need assistance complying with Local Law 154?
Local Law 154 represents a significant stride in New York City’s commitment to environmental sustainability. The law paves the way for a more eco-friendly urban landscape by challenging the conventional use of fossil fuels in buildings. With its phased approach, attention to technology, and emphasis on electrification, LL154 is a transformative force, necessitating a thoughtful and strategic transition toward a greener future.