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Benchmarking: the Incredible Shrinking Law

New York City

Water and energy usage, Local Law 84, Climate Mobilization Act, building carbon emissions.
Dec. 16, 2022

The required annual reporting of buildings’ energy and water usage — an exercise known as benchmarking — is a key driver in efforts to reduce carbon emissions from buildings, the city’s single biggest polluter. The size of the buildings that fall under the benchmarking law has shrunk once before. And it could soon shrink again.

Under current law, buildings larger than 25,000 square feet must file annual benchmarking data with the city. A bill before the New York City Council, Intro. 237, would require buildings larger than 10,000 square feet to file the data — a change that would add about 30,000 buildings to the 50,000 that must now comply.

The bill has won applause from the nonprofit Urban Green Council, which was a supporter of the original benchmarking law, Local Law 84, as well as the city’s ambitious Climate Mobilization Act, which will require many buildings, including large co-ops and condos, to meet carbon emission caps beginning in 2024 or face fines.

"Urban Green’s analysis shows that since benchmarking began, carbon emissions have dropped 23% among those properties,” the council’s website states. “But one-third of all citywide emissions in 2019 came from the 1 million buildings that are smaller than 25,000 square feet, and little is known about their energy use because they do not benchmark. (The city) now has a robust set of benchmarking data from larger buildings, and lowering the size threshold would expand our knowledge of energy use in a broader set of buildings.”

When it first passed In 2009, Local Law 84 applied to buildings larger than 50,000 square feet and to city-owned buildings larger than 10,000 square feet. In 2016, requirements expanded to non-city-owned buildings over 25,000 square feet.

“Smaller buildings must be a key component of (the city’s) long-term climate strategy” Urban Green adds. “While progress won’t come from benchmarking alone, it is the first step to energy management and we cannot measure success without it. Other cities like San Francisco and Washington D.C. have already taken the step to expand benchmarking requirements to private buildings over 10,000 square feet.”

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