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October 28, 2022
The Chamber supports efforts by the City of Boston to transition to a resilient and sustainable built environment that addresses the reality of climate change. We also recognize that such a transition will have a significant impact on development and building construction in the city. As the Agency explores requiring a net-zero emissions standard for new buildings during planning, construction, and operation, the Chamber urges the Agency to factor in the technical and practical challenges to achieving some of the Initiative’s recommendations, particularly in the near term and for the growing number of buildings subject to the new proposed requirements.
Compliance and Access to Onsite and Offsite Renewable Energy The ZNC Building Zoning Initiative envisions the use of onsite and offsite renewable energy as a key component of compliance with proposed emissions intensity targets and comparative emissions reductions. Building owners must optimize buildings for onsite solar facilities, procure renewable energy through ownership of offsite facilities, power purchase agreements, or submit alternative compliance payments to offset operational emissions. Yet each of these methods often present significant challenges:
We appreciate the ZNC Building Zoning Initiative builds in flexibility for particular projects when confronting some of these challenges, but we urge the Agency also to factor in practical concerns when considering these recommendations and to maximize compliance flexibility. Our utility infrastructure must undergo a dramatic transformation to provide the clean, reliable power our long-term goals require. Moving forward with unreasonable requirements before widespread solutions are available will only add costs and discourage development without reducing emissions.
Interaction between ZNC Building Zoning and BERDO requirements While the Agency contemplates net-zero building requirements, new regulations for the Building Energy Emissions Reductions Disclosure Ordinance (BERDO) move forward. The Initiative attempts to align these two regulatory efforts, and we encourage the Agency to avoid conflicts or confusion between these significant new requirements on property owners in Boston. For instance, ZNC Carbon Emissions Intensity target categories should be consistent under BERDO and Portfolio Manager. New buildings approved under any new ZNC Building Zoning requirements should also be included in any organization’s building portfolio for compliance purposes. Consistency among these new mandates will make it easier for developers to navigate the city’s different emissions rules as projects move forward.
ZNC Carbon Emissions Comparative Emissions Reductions and Intensity Targets We are concerned with the general feasibility of the aggressive comparative emissions reduction of 40% for most buildings envisioned under the ZNC Building Zoning Initiative and the 30% reduction target for hospitals. These targets will be difficult to achieve in many buildings, but they may be impossible in more energy intensive buildings like wet labs. At a minimum, wet labs should be held to the same 30% comparative reduction target as hospitals and other health care facilities. Given the importance of these facilities to the greater Boston region and the unique characteristics of their use, this is a small but reasonable adjustment to ensure new facilities continue to become available in the city. Proposed projects are also required to be planned, developed, and managed to attain Best Practice Predictive Carbon Emission Intensity Performance Targets (pCEI). We encourage BPDA to adopt the same pCEI for both commercial and college or university office space at 1.8 kg CO2e/sf-yr as there is no operational difference between these types of facilities. Wet labs again should also at least be consistent with the requirements for hospitals at 7.4 kg CO2e/sf-yr.
Major Renovations ZNC building zoning recommendations apply to new construction of buildings greater than 20,000 sq ft or those that contain 15 or more residential units. The requirements may also apply to major renovations depending on the specific circumstances. The Agency should clearly define the thresholds when renovations will trigger new ZNC requirements and consider making allowances for major renovations that promote the goal of reducing emissions while confronting the practical limitations to achieve the same types of reductions as new construction. ZNC building zoning requirements should not discourage needed building renovation, particularly those that may achieve other public policy goals, like promoting safety, creating affordable housing, or advancing practical emissions reduction progress.
Conclusion The Chamber supports the ambitious goals of achieving net-zero emissions in Massachusetts by 2050. However, we must balance the need to make progress towards that end with the practical and technical limitations of our build environment and the importance of a thriving economy in Boston. As we make the necessary transition to significant emissions reductions and clean energy resources, the Chamber encourages the Agency to focus on achievable solutions that we can build on over time.
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