DER Performance Uncertain Under NYC Building Emissions Law
King of Hearts, CC BY-SA 4.0, via Wikimedia Commons
New York City set carbon coefficients for energy resources to help calculate building emissions, but officials haven't set a coefficient for DERs.

New York City officials are trying to work out how to account for distributed energy resources (DER) under a building emissions law the city passed two years ago.

Local Law 97, which is part of NYC’s 2019 Climate Mobilization Act, limits GHG emissions for buildings with more than 25,000 square feet and sets carbon coefficients for different energy resources to help calculate those emissions.

Coefficients are already set from 2024 to 2029 for certain resources, such as utility electricity and natural gas, but the city has yet to identify a coefficient for DERs, including energy storage. The coefficient for natural gas, for example, is 0.00005311 ton carbon dioxide equivalent/kilo Btus.

“If the New York State goal for 70% renewable electricity by 2030 is achieved, obviously this has a big impact on coefficients,” Gina Bocra, chief sustainability officer at the New York City Department of Buildings, said at the New York Battery and Energy Storage Technology Consortium’s Capture the Energy conference on Wednesday. “Likewise, if we’re moving towards 100% by 2040, that has a huge impact on compliance for Local Law 97.”

Building owners with properties covered by the law must start emissions reporting to NYC in 2025 based on 2024 performance.

“For most buildings, that means they’re going to have to make upgrades to become low-carbon operating buildings,” Bocra said.

The law’s success, she said, depends on how the grid changes in the coming decades, and the coefficients for different resources help reduce uncertainty in investment strategies for building owners.

“We have to make the law responsive to a changing energy infrastructure,” Bocra said. “We have to promote renewables and avoid stranded assets, and we also have to set guidance on how to account for distributed energy resources.”

Finalizing the DER coefficient is a “must” to make energy storage work in New York City at scale, Josh London, senior vice president at Glenwood Management, said during the conference.

Glenwood operates 1.5 MW/6 MWh of dispatchable behind-the-meter energy storage in the city.

“We use it for demand response, time-shifting and peak demand reduction,” he said, and the economics of that storage strategy have been positive for the company.

London sees the installation of behind-the-meter energy storage systems in buildings throughout the city as an important way to support the goals of Local Law 97. If, for example, 10,000 of the 50,000 buildings that the law covers install a 100-kW storage system, they would create a 1-GW virtual power plant, he said.

Some stakeholders in the city believe that a real-time carbon coefficient would be the best answer for valuing DERs under the law.

“[A real-time coefficient] helps the building understand how it can adjust its own behavior to maximize decarbonization based on how the grid is behaving,” Robyn Beavers, CEO of Blueprint Power, said during the conference.

A building that has solar, storage, and combined heat and power technologies, for example, can use real-time grid carbon performance to make optimal decisions about how it is consuming, storing and producing electricity behind the meter, she said.

For storage, focusing on using energy at the right time is important, according to Rebecca Craft, director of sustainability-electrification at Sidewalk Labs.

“When the carbon intensity of the grid is very high, it’s a good time not to use energy,” she said during the conference. “But when renewable supply exceeds demand and renewables are being curtailed, it’s a great time to use energy.”

The only way to have that level of insight is for the grid to be much more transparent about what types of resources are on it during any hour, she added.

“Knowing that allows you to plan a strategy that would create a more effective pathway to managing energy use,” she said.

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