Complying with LL84: Part Three – Issues to consider when complying on your own

April 26, 2011 at 5:01 pm

The Network has been looking into what it takes to comply with Local Law 84, a new NYC regulation requiring owners to benchmark their buildings that are over 50,000 square feet.  View our previous coverage of LL84 , or read on for some important tips that you should keep in mind if you decide to comply without the help of a consultant.

Part Three: Issues to consider when complying on your own

Benchmarking on your own will help you get to know your building better, but may also present some challenges. The rules are complicated and the software tool is not user-friendly, which can make complying difficult.

EPA’s Portfolio Manager (PM) tool was designed as a national voluntary energy assessment tool in concert with the Energy Star program. It was not designed for benchmarking New York City multi-family buildings. As a result, its correct use is not always an intuitive process. NYC has proposed rules for LL84 that must be read and followed in addition to the general instructions, but that are not included or prompted by the Portfolio Manager tool (though the rules are not finalized, building owners should comply as though they will be finalized as-is). Here are some of the major issues to keep in mind as you benchmark, but it is by no means a comprehensive list, and is no substitute for reading the proposed rule amendments.

Add your block and lot number

 When you “add a property” in PM, a Notes section will be created for your building. Though the PM tool says that adding notes here is optional, under LL84 you must enter your building block and lot number. You will be reminded to do this later when you submit your data. You can find you building’s block and lot number on NYC’s Building Information Search website or NYC’s Property Address Search website.

“Optional” data is mandatory

Many of the data entry fields in PM are labeled as “optional,” but under LL84 they must be completed. PM will not remind you. This includes questions about building characteristics, such as the number of bedrooms in your building.

Report your commercial spaces

If you have commercial space within a building, you will need to mark that area as a separate “space” within Portfolio Manager. If it is greater than 5,000 square feet, you will need to categorize it from a drop-down menu in the tool. If it’s smaller than that, you should categorize it as “Other.”

Calculating your oil consumption

If your building uses fuel oil, record your usage by reporting twelve consecutive months’ worth of deliveries. In other words, assume that your consumption over that time equaled the deliveries.

Reporting sub-metered electricity consumption

If your building’s units are separately metered for electricity, you should request aggregated data from Con-Ed on the electricity consumption in those units. Con Ed can send you a spreadsheet that contains this information – it will cost $102.50 per building and can take 15 days or longer. For the initial year or two of LL84, building owners have an alternative – they can use “default values” that assume the same level of electricity consumption for each unit, regardless of size or number of occupants. The default values can be found in a table on page 8 of the LL84 rules. The downside of using default values is that you will not learn about the actual electricity usage behavior of your tenants.

Water metering

Though LL84 requires benchmarking of water consumption along with electricity, natural gas and fuel oil, in fact building owners do not need to worry about it, at least for this year. Page 11 of the proposed rules states that “building owners are not required to enter [water consumption] data.” Buildings that have automatic water-meter-reading equipment will have their water use information sent directly from the Department of Environmental Protection to the Department of Buildings without taking any action. Other buildings will not be benchmarked for water use. This may change in future years.

Submission Delay

After completing a building profile, including the building characteristics, all of its “spaces” and all of its covered energy consumption, you will submit this report through Portfolio Manager. However, since Portfolio Manager updates its data overnight, you will need to wait a day after finishing the profile before you will be able to submit it. If the profile for a given building does not appear when you try to submit it on the same day as you have updated it, there is no cause for concern that the data has been lost – it will appear for submission the next day.

Keep an eye out for Part Four of our series, Benchmarking Compliance Services

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Complying with LL84: Part Two – Benchmarking on your own Upcoming Events – April 27, 2011


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