Year-End Check-In Guide
If you are a regular reader of our newsletter, you will notice a common theme. We have your back. At Aurora Energy Advisors, our top concern is meeting our clients’ energy-related needs. That includes being aware of critical can’t miss deadlines, whether they are related to energy supply contracts, utility issues, or local laws. With year-end quickly approaching, below we aggregated upcoming “check in” reminders so you can stay informed.
Local Law 95 – Letter Grades
Most buildings that benchmark under New York City’s LL84 will earn a score through the Energy Star benchmarking platform. This score translates into a letter grade. Under LL95, each year, all required buildings must print and post their grade in a conspicuous location near each public entrance by October 31. Letter grades should be left in place until the next October. Each October 1, letter grades become accessible via the DOB NOW Public Portal, then by clicking on Building Energy Efficiency Rating Label and searching by Borough, Block, and Lot. Failure to post before the deadline will result in a DOB violation and an annual penalty of $1,250.
Interruptible Gas Account Affidavits
If you have an interruptible gas account in Con Edison or National Grid territory managed by Aurora, we already shared this with you in September, but here is another reminder. Both utility companies require interruptible gas account owners to submit an annual affidavit essentially affirming they are willing, able, and prepared to act during an “interruptible” cold weather event. The deadline for both utilities was October 1 with a grace period until October 31. Daily fines are assessed until submission. The Con Edison affidavit can be found here, and National Grid here.
Local Law 87 – Energy Audits
LL87 mandates that BBLs over 50,000 square feet must perform an energy audit and retro-commissioning measures every 10 years. Upon completion of the measures, the engineer who completed the audit must submit a report by December 31 of the compliance year, which is determined by the last digit of the property’s DOB-assigned block number. For example, if your BBL (borough-block-lot) is 1-01234-5678, compliance is due by December 31, 2024. Because of the vastness of the audit, the entire process takes at least a year. However, if you have not signed up an engineer for LL87 yet and your due date is in 2024, it is not too late. The DOB offers two one-year extensions. If you contract with an engineer as soon as possible, there is still time to apply for the extension and avoid the $3,000 penalty for first-time offenses and $5,000 per year thereafter. Aurora can assist with getting started on this process.
Local Law 88 – Lighting and Submetering
LL88, later amended by LL132 and LL134, requires buildings over 25,000 square feet to (i) be up to lighting code in commercial and common spaces, and (ii) separately meter commercial spaces over 5,000 square feet. Though the final compliance report is due to the DOB by May 1, 2025, work to bring a building into compliance must be completed by December 31, 2024. The first step is for an engineer or electrician familiar with the law to audit the building and provide a report of required upgrades, if any. Next, you complete the upgrades and have the auditor submit the final report. Aurora can assist with getting started on this process.
Local Law 97 Article 321 Compliance
If your building falls into the Article 321 bucket of LL97, the clock is running low on time. For a refresher on Article 321, qualifying criteria, required steps for compliance, and more, please refer back to our April newsletter here. In short, this set of buildings must complete 13 prescribed energy conservation measures by December 31, 2024, with the final compliance report submitted to the DOB by May 1, 2025. The first step is for an engineer to audit your building to determine which measures are not in compliance. If you have not signed up an engineer for this audit, Aurora can help start this process for you. If you do not expect to complete all measures by year-end, it is critical to take necessary steps to retain eligibility for a mediated resolution with the DOB that would grant an extension. The most important component of this is proving intention to do the work by contracting with vendors. Buildings will be fined $10,000 if they fail to submit the required report and another $10,000 if they cannot prove compliance by the applicable deadlines.
Local Law 157 – Natural Gas Detector Installation
Under this law, natural gas alarms must be installed in private dwellings, class A multiple dwellings (includes condos, co-ops, multifamily rental buildings, and one- and two-family houses), and class B multiple dwellings (transient housing properties such as hotels, lodging houses, and dormitories) with gas service. Compliance is due by May 1, 2025.
Market Analysis
Electricity
Still in the shoulder season, NYISO Zone J price movement stayed relatively still in the first half of October, as cooling and heating demand is at a minimum. Aside from temporary upward pressure on the day Hurricane Milton hit Florida, pricing hovered in the $0.03-0.04 per kWh range. The commodity is expected to remain at seasonally low levels until the onset of winter, when demand will once again increase and lift prices.
Natural Gas
Following Hurricane Helene, the NYMEX crept up to nearly $3 per MMBtu, as production in the Gulf Coast was impacted by the storm. Then just two weeks later, Hurricane Milton ravaged the same region and buoyed the commodity in the high $2 range. With these headwinds in the rear, the NYMEX gradually declined, now sitting at $2.60 as of October 14.
Crude Oil
The sub-$70 per barrel prices for crude oil were just a blip in the radar. Through the first two weeks of October, price rose nearly 10 percent amid escalating tensions in the Middle East and fears of the conflict spreading across the region.
💡 Mitchell’s Tip: Develop an LL97 carbon roadmap.
