Local Law 154

NYC All-Electric New Buildings Law: What It Entails And How To Comply

Local Law 154 (“LL154”) was passed on December 15, 2021, by the New York City Council. The law sets strict CO2 limits on new construction, effectively requiring new buildings to be completely electric and free from fossil fuels by 2024 (for buildings less than 7 stories tall) and 2027 (for buildings more than 7 stories tall). With the passage of this law, New York City became the largest city in the world to phase out fossil fuels from newly constructed buildings.

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Local Law 154 Compliance Strategy And Solutions

Local Law 154 Essentials

This new law makes New York City the largest city in the world to phase out fossil fuels from newly constructed buildings. Environmental groups, who campaigned for a “gas-free NYC,” supported LL154 for several reasons, one being that removing gas stoves in residential units could improve indoor air quality. The bill outlines building electrification measures necessary to meet the new guidelines.

What Buildings Must Comply With LL154?

Rather than banning the use of fossil fuels directly, LL154 prohibits the combustion of any substance emitting ≥25 kg CO2e/mmBtu (propane, diesel & home heating fuel, kerosene, natural gas, gasoline, residual heating fuel, etc.) in new buildings and gut renovations.

Work that increases the floor service area of an existing building by more than 110% counts as a gut renovation, meaning the building will be considered new and is thus subject to LL154.

What are the LL154 Deadlines?

By January 1st, 2024:
all new buildings less than 7 stories can no longer be using the prohibited fossil fuels, except for their hot water systems. (except for on-site fossil fuel combustion for service hot water.)

By July 1st, 2027:
fossil fuels are prohibited in hot water systems for all new buildings less than 7 stories. Buildings with 7 stories or more will also have to be free from fossil fuels for all energy uses.

What are the LL154 Exceptions?

The following building types and uses are exempt from the fossil fuel restrictions established under Local Law 154. Compliance is not required to the extent described in each item below.

1: Appliances that are not connected to a gas line or fuel oil piping, are not used for space heating or hot water, and are used only on an occasional basis — for example, a propane grill.

2: Buildings used primarily for the treatment of sewage or food waste.

3: Buildings used by utilities for the generation of electricity or steam.

4: Spaces within a building where combustion is operationally required for manufacturing processes, laboratory functions, laundromat equipment, hospital operations, crematoriums, or commercial kitchen equipment but only within the specific spaces where such use occurs, and only to the minimum extent necessary for that purpose.

In mixed-use buildings, this exception applies solely to the qualifying spaces and does not extend to any other areas of the building. The building owner or operator is responsible for demonstrating that combustion use is operationally necessary.

What are the Permitted Delays

Certain buildings may qualify for a time-limited extension of the compliance deadline established under Local Law 154. All other applicable requirements remain in effect during the delay period.

2-year delay.
 
Buildings in which at least 50% of residential units qualify as affordable housing are eligible for a two-year delay from the otherwise applicable compliance deadline. This delay applies automatically upon written notice to the relevant enforcement authority, provided the building meets the affordability threshold at the time notice is submitted and continues to do so throughout the delay period.
 
If the affordability threshold is no longer met at any point during the delay period, the extension is void and the original compliance deadline applies. The building owner or operator bears the burden of demonstrating ongoing eligibility upon request.

How to Heat and Cool New Buildings Without Fossil Fuels

Heat Pumps are the solution for heating and cooling new buildings in compliance with LL154. Heat pumps are electrically powered, emissions-free, and work in a variety of exterior temperatures. MPN has air-to-liquid and liquid-to-liquid heat pumps available that provide a zero-emissions way to heat, cool, and make domestic hot water for your buildings.

Local Law 154 Carbon Compliance

Not sure where your building stands?
Contact Hudson Clean Heat for a Local Law 154 Carbon Compliance Assessment.

Meet the Team at Hudson Clean Heat

Jaime Tetrault

President & CEO

Julia Cyr

Sustainability Business Development

Ian Motley

Program Manager, Electrification Solutions

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