On July 26, 2023, CHPC Deputy Director Sarah Watson and President Mark Ginsberg testified before the City Planning Commission in support of the proposed City of Yes: Carbon Neutrality zoning text amendment, and to recommend technical changes.

Read the full testimony below.

Thank you for the opportunity to testify today. My name is Sarah Watson and I am the Deputy Director of Citizens Housing & Planning Council (CHPC).

On behalf of CHPC, I am delighted to share our strong support for the proposed city text amendment, City of Yes for Carbon Neutrality.

This proposal aligns the essential public policy goals of environmental sustainability and sustaining investment in our buildings, transportation, and energy systems.

CHPC has long advocated for zoning and regulatory reform to promote necessary investment in all segments of our housing stock, and to clear bureaucratic barriers to meeting the needs of New Yorkers. Zoning needs to make it easier to do the right thing for a carbon neutral future, and this proposal does just that.

There are four items that CHPC believes are especially critical for residential buildings:

First, the City of Yes for Carbon Neutrality would allow elevated solar trellises over 100% of roof area, a change CHPC has advocated for. The proposed allowance would nearly quadruple the solar wattage a typical rooftop can generate.

Second, this text amendment will make it easier for buildings to be retrofitted with exterior insulating panels, making heating, cooling, and powering our buildings more efficient. This is especially critical for our affordable and public housing stock.

Third, the changes will make it easier for building owners to place low-carbon HVAC equipment, on roofs and in yards; allowing sufficient flexibility for existing buildings as well as new ones to use clean energy systems, and supporting State and local goals for the electrification of building systems.

Fourth, we are in strong support of the changes that will remove administrative barriers to the use of permeable paving, an important surfacing option that helps reduce stormwater runoff.

We have some technical comments about specific adjustments needed to enable the text to accomplish its intended purpose, and these are included in the attachment with our written testimony. In particular, the standards for ultra-low energy buildings should be compatible with the gold standard of Passive House, today and into the future. Our board president, and Chair of our Zoning Committee, Mark Ginsberg, will testify on this point.

In summary, the City of Yes for Carbon Neutrality text amendment is exactly the type of zoning reform the city needs. We applaud the work of DCPs staff and the City team in developing this proposal, and are pleased to support these changes, with the technical refinements we have outlined.

I am Mark Ginsberg, President of the Citizens Housing & Planning Council (CHPC) and a practicing architect. CHPC is in strong support of this Proposal and compliments the Department on good work. Our Deputy Executive Director, Sarah Watson, is giving our testimony on the overall Proposal. I will concentrate on ultra-low-energy buildings.

One of the most important features of this proposal is the updating of standards that earn new buildings a floor area deduction for achieving leading-edge energy efficiency standards. There are two ways to qualify for this standard: (a) be a better than code building or (b) meet the current gold standard for energy efficiency.

CHPC convened a group of leading experts on building energy efficiency to evaluate this piece of the proposal. We all agreed on the importance of this proposal but identified areas for adjustment:

  • First, the better than code standard is unachievable with todays best practices, in large part because of how much more stringent codes have become.
    • IECC baseline performance is now over 33 percent better than it was 15 years ago when Zone Green was passed.
    • Beating code by 50% is effectively impossible. Beating it by 15% represents a building thats significantly better than the code and what was required in the past.
    • As codes continue to become more stringent, there may be a point when being better than code is no longer the right standard. This makes it more important for the gold standard option to reflect current best practices.
  • Second, the Passive House standard is the current gold standard for building energy efficiency. We understand the proposal intended include Passive House buildings. But we found that a Passive House building would not qualify under the originally proposed language.
    • The standards should be updated to reflect the most recent version of the Passive House standard and to enable DOB to administer them for several different modeling tools that are used in the industry.

As a group, we drafted recommended modifications for the definition of ultra-low-energy building that would reward Passive House buildings and other cutting-edge projects today and into the future. These recommendations are attached to CHPCs written testimony.

When the Commission votes on the proposed text amendment, we strongly recommend that your report acknowledge the purpose of these respective standards, to provide adequate guidance for future rulemaking.

I’ll be happy to answer any questions about our comments.

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CHPC's testimony, Sarah Watson and Mark Ginsberg, July 27, 2023