The Real Estate Board of New York to The New York City Department of Buildings re: Calculation of Emissions Limit for Buildings

Download the Comments

The Real Estate Board of New York (REBNY) is the City's leading real estate trade association. Founded in 1896, REBNY represents commercial, residential, and institutional property owners, builders, managers, investors, brokers, salespeople and other organizations and individuals active in New York City real estate. REBNY appreciates the opportunity to comment on proposed rules that impact the calculation of a building's emissions limit.

REBNY applauds the Department for its collaboration with industry experts and other key stakeholders in the determination of coefficient for certain co-generation systems. When properly managed, co-generation facilities can help to efficiently power buildings. The proposed rule appropriately recognizes this role.

In addition, REBNY commends the Department's efforts to create an offset fund that will support investment in affordable housing in New York City. This is a promising model that will require evaluation in advance of the 2030 compliance period to determine whether it can be scaled up over time to reach even more buildings.

Lastly, the proposed rule establishes a coefficient for biofuels that is higher than the coefficient for gasoline. Given that the U.S. Department of Energy states that "biofuels burn cleaner than gasoline, resulting in fewer greenhouse gas emissions," the Department should revisit this proposed coefficient.

Thank you.