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Reminder: Climate Mobilization Act Deadlines Draw Nearer

When New York City’s Climate Mobilization Act (CMA) was enacted in 2019, it was seen as some consolation that many of the more challenging deadlines were several years away. A year later is a year closer to those deadlines, and buildings are starting to have to take steps to comply.

One component of the CMA is a “letter grade” program, modeled on the letter grade system for restaurants, and is intended to bring visibility to buildings’ energy and water usage and incentivize building owners to improve their “ENERGY STAR” metrics. The letter grade program is derived from benchmarking data that most large buildings have been required to compile for the last several years. This year, the benchmarking data was due to be submitted to the Department of Buildings by May 1, 2020, which was extended to August 1, 2020 due to the coronavirus emergency. If your building is required to submit this data but has not yet done so, you should contact counsel immediately.
Like so many things, the rollout of the CMA has been disrupted by the ongoing pandemic. Not only has the letter grade deadline been extended, but with so many people working from home this year (and not working from Manhattan office buildings), this year’s energy usage data will be seriously skewed. As a result, a building’s letter grade next year may not accurately reflect its usual energy performance.

The CMA contemplated a specialized lending program for energy improvements, but the program guidelines that were to be unveiled this past spring have been delayed indefinitely. The CMA also requires the City to publish a study on a potential carbon trading program by January 1, 2021, but it is unclear whether that deadline will be met. This is of concern because a workable carbon trading program will be the only way for many large buildings to achieve compliance with the CMA’s emissions limits in future years.