Don't Get Lost In Translation
By: Nancy Anderson, Ph.D.
January 01, 2009
If the science of climate change is on target, our policies and our actions will soon determine whether global warming becomes a calamity. The stakes couldn't be higher and this means the collective margin for error is slim while we're just beginning to learn how to do what needs to be done. At the same moment, New Yorkers are in the midst of a global economic crisis whose impact is already painfully clear although the solution to the crisis is far from obvious. What better time to examine the impact of New York City's sustainability headliner PlaNYC 2030 and the supporting role, played by Local Law 86!
With the publication of the first Local Law 86 of 2005 Annual Report, issued three years after the law was passed, readers can delve into this statute's progress-to-date on the construction and renovation of energy efficient buildings that are municipally owned or receive certain levels of taxpayer dollars. Although the law stipulates that the annual report cover only completed projects, the City's Office of Environmental Coordination wisely decided, since just one project has been completed that is subject to Local Law 86, to include "all projects that have started design since the law took effect" and it "documents projected reductions in energy cost and potable water use, as well as estimates of additional cost related to achieving the required LEED or the Green Schools standard." The report also instructs readers that, "the law supports the goals of PlaNYC to reduce greenhouse gas emissions 30% by 2030, as well as its goals to reduce energy costs".
The Local Law 86 Annual Report merits close reading because it contains energy-efficiency projections used in final project designs that can be tracked as the projects come on-line. The School Construction Authority, for instance, proposes to achieve the mandated minimum of 10% energy cost savings by installing more efficient boilers and replacing existing steam traps. With a total annual estimated cost saving of some $1.3 million, the lions' share should come from low-tech, low cost steam traps, which translates into a very attractive payback period of two years. If these design projections are regularly tracked and reported they will make an invaluable contribution to the learning curve to achieve high performance building and energy efficiency.
In all, the report offers information on eighty-three projects with total "project costs" about $4.8 billion of which nearly $4 billion "is related to fulfillment of Local Law 86. (Of these projects, thirteen are covered solely by Green School regulations.) These costs translate into almost 6.5 million square feet of space subject to the law. The report also offers the projected completion date for each project. And that's pretty much it. Want to know about project specific energy consumption reduction numbers and how they compare to baseline figures for energy consumption in buildings of comparable size and use category? You won't find the answers in the Annual Report.
Readers will find projected energy efficiencies and energy savings for two projects with completed designs. Here's some good news: the incremental cost of energy efficiency is projected at just over $400,000 out of total project costs of almost $83 million. Energy efficiency gains in these projects are anticipated to come from lower consumption of electricity, natural gas and purchased steam, which should mean an annual reduction of 330 metric tons of greenhouse gases. In turn, associated cost savings should translate into a seven-year payback period for the additional incurred compliance costs.
This is a real opportunity, but it must be compared to the overall 1.68 million metric ton cut in greenhouse gas emissions the City projects will be needed to meet its 30x2017 target for its own operations, as detailed in the Long-Term Plan to Reduce Energy Consumption and Greenhouse Gas Emissions of Municipal Buildings and Operations. Of this targeted reduction, increased energy efficiency in its structures will account for a hefty 953,606 tons. (More on this below.)
Yet, even with all the first Annual Report's facts and figures, something crucial gets lost in translation: the ability to measure and verify how Local Law 86 "supports" the 30x2017 goal of PlaNYC 2030. As of now, even the most careful readers can't compare and coordinate these bureaucratically distinct efforts and neither can anyone else. This is not a desiccated quibble about a definition, real money's at stake. The City, as part of a long-term energy plan that's an outgrowth of PlaNYC 2030, has launched an $80 million a year program to upgrade the energy efficiency and cut the energy costs of operating its building stock. Since the PlaNYC 2030 Progress Report doesn't provide data on the progress of Local Law 86, let's look next into the City's specific plan to boost its own energy performance.1
The Long-Term Plan to Reduce Energy Consumption and Greenhouse Gas Emissions of Municipal Buildings and Operations, issued in July 2008, provides the dominant narrative for how the City's municipal operations — which produce "approximately 3.8 million metric tons of greenhouse gas (GHG) emissions per year and consumes about 6.5% of New York City's total energy use" — will slash these emissions 30% by 2017 and save tax-payer dollars on its energy and fuel bills." The City proposes to meet these goals by "investing" 10% of the City's annual energy budget, and this could add up to more than $900 million. What's not made clear is how the energy-efficiency achievements of Local Law 86 will be factored in.2 For instance, the Long-Term Plan recommends building audits to identify energy-savings opportunities. It also recommends upgrading building management systems and enhancing staff operations and maintenance capacities. None of these are actions stipulated by Local Law 86.
As the Sallan Foundation routinely advocates, the Long-Term Plan calls on the City to institute performance measurement and verification programs and to develop a performance tracking and information management database. These are estimable aspirations, but who is thinking about how to deliver on them in the new and existing buildings designed to meet Local Law 86 requirements? The policy challenge that must be faced is how best to take verifiable credit for lower energy use and reduced greenhouse gas emissions in all City buildings regardless of the name of the policy, plan or statute. Even if we don't know what we're doing, Mother Nature does and the more greenhouse gases we pump into the atmosphere, the hotter and more turbulent our planet will become.
Furthermore, in these depressed economic times it's not yet clear what financial resources will be budgeted to boldly pursue the City's overall climate change campaign. Dollars could be scarce for the foreseeable future and it's a safe bet that there will be many continuous and compelling needs clamoring for support. Under these circumstances, the City must have a full and accurate grasp of its green building, energy-efficiency campaign so it can best compete for resources and thrive. That remains true even if the Obama administration commits major green funding to New York. If municipal momentum is lost or it turns out that "investments" and regulations don't produce significant results, it's easy to predict that the City's sustainability programs would be shelved and their funds redirected.
This is a bleak but hardly inevitable scenario. For starters, next year's crop of annual reports and progress prognoses could easily be made more systematically informative and provide the map for understanding the relationship between Local Law 86 and PlanNYC 2030. Then, as programs mature, reports should adopt evidence-based methods to assess outcomes. In these ways, supporters of sustainable development can acquire the information they need to defend and deepen these core green commitments. If the Mayor's Office of Long-Term Planning and Sustainability and his Office of Environmental Coordination learn to speak in common language, perhaps we all will be able to understand just what's happening.
- The Progress Report does outline ambitious projects for future development such as the "greening the code" work currently in development by the USGBC-NY and refers to the Energy Efficiency Partnership responsible for the City's Long Term Energy Plan that grapples with setting priorities for targeting incentives to reduce energy demand on the part of large consumers. Good stuff! ↩
- As the owner of many of the buildings in which municipal employees work, the City has an green advantage not available to private landlords; it controls the purchases of all the computers, lighting fixtures and other "plug loads" typical of commercial office occupants. In this regard, the City's purchasing decisions can help to lower a municipal building's energy demand more directly than a private landlord. ↩