Electrifying Our Buildings to Fight Climate Change

As global fossil fuel emissions are the leading cause of climate change, leaders all over the world have come up with solutions to lower their region’s carbon footprint. In New York, policies have been implemented to help reduce gas emissions through transportation, industrial, and power sectors. Since the primary source of the city’s emissions comes from buildings, it is evident that building decarbonization is necessary to achieve our climate goals. One of the most critical ways to fight climate change in New York City is to electrify buildings. NYLCV therefore supports Intro 2317, a bill that would place an emissions cap on all new and renovated buildings and encourage building electrification. However, we feel that there need to be some major amendments to the bill so that we approach the complexities of building electrification pragmatically.

Electrifying buildings is the next logical step in the building sector. The bill would lead to a more just system by reducing the burning of fossil fuels and decreasing overall pollution in the city. Through the mandate of Intro 2317, there can be an equitable energy transformation. Focusing on local, renewable energy rather than outsourcing fossil fuels would redirect money within the New York State economy. It would also create tens of thousands of new green jobs, stimulating the economy and revolutionizing the job market.

NYLCV, along with UGC, NRDC, and RPA have come up with a list of recommendations to ensure Intro 2317 is effective. With policies that scale efficacy and electrification, the benefits can be maximized. These recommendations would drive all-electric construction in new buildings and a full renovation in others. The first recommendation is to phase in requirements by building height to allow more time for taller buildings and market ramp-up. We recommend applying requirements in two phases: first, any building with seven or fewer stories permitted two years from the law’s effective date; second, any building with eight or more stories permitted five years from the law’s effective date.  This phased approach recognizes that all-electric new construction in lower-rise buildings is easier and can happen sooner, with design and technology ready for this transition. But it also allows more time for designers, builders and trades professionals to adapt to the greater technical challenges in taller buildings and for manufacturers to bring more products to market. Above seven stories, system design becomes more complex in part because of limitations in refrigerant line length and less roof and basement space compared to the size of the building. 

We must also clearly define a high threshold for major renovations to be covered. Electrification is much more challenging for existing buildings. If included, we recommend only  covering very major renovations that present electrification opportunities similar to new  construction, such as by reference to a clearly defined and high threshold like the Building Code defined term “Substantial Improvement.” We also recommend addressing any significant hardships unique to renovations, such as the inability to increase capacity for incoming electrical service, through exemptions or waivers. However, to keep exceptions limited and justified, they must be distinctly detailed. Exceptions to the emissions limits may be necessary for certain building types, space uses or circumstances, but the current phrasing is overbroad and risks exempting too many buildings. We recommend that the Department of Buildings define a waiver process for circumstances where sufficient utility electricity service is not possible, clearly define undue hardship, and provide criteria for when combustion is deemed required.

Another recommendation is to lower the permitted CO2 emissions limit. The proposed CO2 emissions limit is only marginally lower than emissions from natural gas combustion, which means a small amount of lower-CO2 fuel, such as hydrogen, blended with natural gas could enable the installation of new or replacement fossil fuel equipment in buildings. Finally, since this approach can take years, we suggest adding “electrification-ready” requirements for all new construction and major renovations in the interim. Every new building with fossil fuel equipment is adding to the future retrofit challenge, as these buildings will be harder and more costly to retrofit to all-electric down the line. We recommend requiring modest “electrification-ready” measures for all new construction and major renovations until these emissions limits kick in, so that future retrofits are less costly and easier. Potential measures include electrical distribution sizing, space for future electrical service upgrades, access requirements for mechanical spaces, roof layouts to consolidate equipment, and structural support for future equipment. 

With the adoption of these proposals, we can further progress towards our city’s climate goals.  The mayor is in support of building electrification, and we hope that our recommendations are adopted so that NYLCV can fully support the advancement of this legislation. 

By Mahirah Billah