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    Sometimes Compliance Isn't The Only Solution

    At Metropolis Group, we’re constantly interfacing with the DOB to understand the seemingly constant changes to the compliance process. So it’s particularly interesting to us, and possibly even surprising, when we learn that the DOB has issued new guidelines which outline the possibilities of legally not complying. DOB Building Bulletin 2011-015, issued in late June, presents such a case.

    BB 2011-015 clarifies the possible conditions under which an alteration, renovation or repair may not need to require compliance to the NYC Energy Conservation Code. As a Technical Bulletin, it references Section 101.4.3 of the NYCECC specifically.

    The Bulletin clarifies different conditions in detail. In addressing additions, alterations, renovations or repair to building thermal envelopes for example, it opens the door for the applicant to prove that NYCECC compliance would create hazardous or unsafe conditions, or would overload existing systems within the building.

    For jobs involving ceilings under unconditioned roof attics, the DOB again provides an out. If it’s a straightforward job to insulate properly when the floor of an attic is replaced, the work should be completed in compliance with NYCECC. If, however, there is practical difficulty in completing this install, the applicant can move forward without completing the work, so long as they provide an alternate way to control thermal loss and therefore limit energy consumption.

    There are more specific details throughout, relating to different possible scenarios. What’s interesting here is the DOB’s understanding of the complexity of different work place scenarios, and an attitude towards compromise.

    The bottom line here, and throughout this Bulletin, is the reality that the DOB does not want to insist on work under the umbrella of energy conservation that actually leads to greater energy consumption within the building. And they are willing to listen to thought-out alternatives that reach the same goal of lower energy use.

    This Bulletin is only about a month old, and it’s unclear how both the DOB and the Trade will handle the opportunity not to comply. Hopefully we take this initiative in good faith, and return the favor to the DOB by thinking of ways to improve our City-wide energy consumption.

    On a hot summer day, with air conditioners blazing across the five boroughs, it’s a great time to work together towards a common goal.

    Frank Fortino

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