"LL97 does not currently allow for the use of CCS…”, in the Era of, "Drill, baby, drill!"

"Drill, baby, drill!" — President-elect Donald Trump’s rallying cry underscores a commitment to domestic fossil fuel expansion. In stark contrast, New York City’s Local Law 97 (LL97) FAQ provides a cautionary note:

"LL97 does not currently allow for the use of CCS [carbon capture and storage] as a compliance pathway, absent further government action...DOB is engaging with stakeholders to better understand how CCS technology works."

The juxtaposition of Trump’s fossil-fuel-driven agenda and NYC’s emissions reduction goals highlights a broader tension. This tension reflects the divide between purist sustainability advocates and staunch fossil fuel proponents. However, bridging these perspectives requires pragmatic strategies that acknowledge the realities of energy security while advancing decarbonization. Our Carbon Bridge technology offers a pathway that balances these competing priorities, aligning local compliance efforts with broader energy considerations.

The traditional heat pump retrofit approach for achieving compliance with LL97 is increasingly viewed as unfeasible for many NYC properties. Heat pumps require significant in-unit renovations, extensive tenant cooperation, and substantial financial investment. These challenges render the strategy impractical, particularly for pre-war buildings with long-term tenants and limited infrastructure capacity.

Barriers to Heat Pump Retrofits

1. In-Unit Work Requirements: Retrofitting an entire building with heat pumps involves disruptive construction in every apartment. Walls must be opened, ductwork installed, and existing heating systems replaced. These renovations can lead to prolonged tenant displacement and resistance from residents unwilling to vacate their homes.
2. Tenant Resistance: Many tenants, especially in rent-regulated buildings, are unlikely to agree to intrusive renovations. The prospect of moving out during construction is a non-starter for many residents, leading to delays or outright project cancellation.
3. Infrastructure Limitations: Heat pumps necessitate a major upgrade to a building’s electrical system, including service lines, panelboards, and transformers. These upgrades are not only costly but also time-consuming and require coordination with utility providers. In older buildings, these challenges are magnified by outdated infrastructure.
4. Cost: The capital expenditure for heat pump installation is prohibitive for many property owners. The return on investment is often unclear, especially when factoring in tenant disruptions and extended project timelines.
5. Energy Demand Charges: Heat pumps operate on electricity, which can lead to significant demand charges during peak periods. This makes them less cost-effective, especially when compared to solutions leveraging off-peak renewable electricity.

Alternative Strategies

Given these challenges, property owners are seeking alternative pathways that minimize tenant disruption, avoid extensive infrastructure upgrades, and align with LL97’s emissions goals. Standard Carbon offers three distinct approaches to decarbonization:

1. Point-of-Source Carbon Capture: Captures CO2 directly from boilers and transports it off-site for processing.
2. Integrated Carbon Bridge with RNG Export: Converts CO2 into renewable natural gas (RNG) on-site and injects it into the existing natural gas grid.
3. Integrated Carbon Bridge with On-Site Storage: Produces and stores RNG within the building, eliminating reliance on external utility systems.

Each of these approaches avoids the pitfalls of heat pump retrofits. Work is confined to boiler rooms and rooftops, leaving apartments untouched. Electrical upgrades, where required, are limited to building-level systems, avoiding the need for in-unit modifications.

Three Approaches of the Carbon Bridge

1. Point-of-Source Carbon Capture

This approach captures CO2 emissions directly from a building’s boiler, liquefies the CO2 on-site, and transports it to a centralized facility for conversion into renewable natural gas (RNG). This model mirrors the CarbonQuest system, which has demonstrated its feasibility in urban settings.

Advantages:

• Requires no electrical upgrades to the building.
• Permitting and installation processes are straightforward.
• Small physical footprint with no disruption to property operations.

Regulatory Context: Despite its simplicity, the NYC Department of Buildings (DOB) has not yet approved point-source carbon capture for LL97 compliance. However, the DOB’s 2023 FAQ ("FAQs Related to 1 RCNY 103-14") signals an openness to evaluating this technology. The DOB is engaging stakeholders to assess carbon capture’s role in achieving emissions reductions, exploring methodologies for accounting captured carbon, and understanding the landscape of markets for captured CO2.

Implementation:

• Equipment captures CO2 emissions at the boiler.
• Liquefied CO2 is trucked to processing centers for RNG production.
• RNG is integrated back into the energy grid for use.

2. Integrated Carbon Bridge with RNG Export

This option captures CO2 on-site, transforms it into RNG, and exports it directly into the existing natural gas grid. By leveraging interconnection rules for renewable and landfill natural gas projects, the building’s gas network becomes a storage solution.

Advantages:

• All operations occur within the building, avoiding the need for storage infrastructure.
• Minimizes tenant disruption by confining work to boiler rooms and rooftops.
• Reduces reliance on fossil fuels while maintaining energy reliability.

Regulatory Considerations: While natural gas produced from CO2 is not yet recognized as equivalent to landfill or renewable natural gas, the high likelihood of future approval rests on the gas’s compliance with established quality standards. Documents like ConEd’s "Gas Sales & Transportation Operating Procedures" outline these standards, and the Carbon Bridge’s output meets or exceeds them, ensuring alignment with regulatory frameworks.

Implementation:

• CO2 is captured and converted into RNG on-site.
• RNG is injected into the natural gas grid under existing interconnection guidelines.

3. Integrated Carbon Bridge with On-Site Storage

This approach captures and converts CO2 into RNG within the building, storing the gas in compact 8-cubic-foot compressed natural gas (CNG) containers or in adsorbed natural gas (ANG) tanks at atmospheric pressure on the roof. These containers comply with NYC fire safety and fuel gas codes, ensuring safe storage.

Advantages:

• Legally deployable under existing NYC regulations.
• Eliminates reliance on utility-supplied natural gas.
• Operates during off-peak hours, avoiding demand charges while utilizing renewable electricity.

Regulatory Compliance: On-site storage aligns fully with NYC fire and fuel gas codes, meeting LL97’s emissions reduction targets. The system’s reliance on off-peak electricity for RNG production supports electrification without infrastructure upgrades required for electric boilers.

Implementation:

• RNG is stored in rooftop CNG containers, adhering to fire safety protocols.
• High-voltage off-peak electricity powers the system, ensuring cost-efficiency.

Comparative Analysis of the Three Approaches

Option 1: Point-of-Source Capture

• Strengths: Quick deployment, low cost, and minimal permitting.
• Limitations: Formal LL97 compliance approval is pending, and CO2 transport logistics must be managed.

Option 2: RNG Export

• Strengths: Seamless integration with existing infrastructure, no storage needs, and regulatory alignment potential.
• Limitations: Requires electrical upgrades and certification of RNG from CO2 for compliance.

Option 3: On-Site Storage

• Strengths: Deployable under current regulations, independence from utilities, and flexibility for building types.
• Limitations: Requires rooftop space and strict adherence to fire safety codes.

Financial and Environmental Benefits

Revenue Streams

1. 45V Green Hydrogen Tax Credits: Provides incentives for hydrogen production using renewable electricity. Offers $3 per kg of H2 produced.
2. 45Q Carbon Capture Tax Credits: Offers $60 per tonne of CO2 captured.
3. Avoided LL97 Penalties: Eliminates fines of $268 per tonne of CO2.
4. RNG Sales: RNG can be monetized by selling it to the grid or using it on-site, creating revenue in NYC’s constrained gas market.

Environmental Benefits

• Zero CO2 Emissions: The system’s water scrubbers and CO2 solvent spray towers eliminate pollutants alongside CO2.
• Air Quality Improvements: Pollutant reductions address asthma-related health impacts in populated areas.

Strategic Importance and Timing

LL97 Deadlines and Good Faith Effort Filings

The May 1, 2025, LL97 compliance deadline poses challenges for NYC properties. Market-rate properties, including condos and co-ops, face fines unless they submit a ‘Good Faith Effort’ master decarbonization plan. The Carbon Bridge system offers an alternative to retrofits like heat pumps.

Global Energy Market Considerations

Recent geopolitical events, including the Ukraine war and tensions in the Gulf, highlight the volatility of fossil fuel markets. Even with expanded domestic production, global demand pressures could elevate prices, as seen during Europe’s energy crisis. Renewable solutions like the Carbon Bridge provide resilience against such disruptions, offering a stable energy source.

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