Portfolio Analysis and Strategic Planning for Local Law 97 Compliance

Phipps Housing Services

FSG Role

  • Consulting Engineer

Organization Type

  • Non-Profit Housing

Timing

  • Complete September 2025

Construction Cost

  • TBD

Target Energy Savings

  • Net-Zero buildings by 2050

Building Type

  • Mid- and High-Rise

  • Commercial

Size

  • 99 buildings

  • 10,000,000+ square feet

  • 7,800+ dwelling units

Existing Conditions

  • Hydronic boilers, baseboard

    fintube, PTAC, make-up air

  • Mixed lighting from T8 & CFL to LED

  • Insulation per Code

  • Standard aerators, showerheads

Overview

In alignment with New York City’s ambitious climate legislation under the Climate Mobilization Act, FSG is supporting Phipps Houses in a comprehensive effort to decarbonize its portfolio and achieve full compliance with Local Law 97 (LL97). Phipps Houses, a leading nonprofit provider of affordable housing, owns and operates a diverse portfolio of residential and commercial buildings across the city. Recognizing the scale and urgency of the city’s emissions reduction mandates, Phipps partnered with FSG in 2024 to conduct a full-spectrum energy and sustainability assessment designed to evaluate feasibility and develop actionable pathways to meeting their commitments to sustainability.

The analysis involves eight integral tasks which are as follows: determination of building compliance with LL97, conditions and risk assessments, development of a strategy and roadmap for compliance, synthesis of reports needed for Article 320 and 321 compliance under LL97, incentive and utility program identification, and technical assistance with energy and sustainability related work throughout the development pipeline.

Approach and Methodology

Each property within the Phipps portfolio was evaluated to determine current conditions and systems, utilizing information provided by Phipps, recent audit reports, as well as various site visits to gather equipment information. Care was taken to evaluate the practical viability of implementing major energy upgrades for each property, particularly those related to electrification and emissions reductions. The feasibility analysis considered a wide range of site-specific variables, including:

  • The capacity and condition of existing electrical infrastructure and the potential need for service upgrades

  • Physical constraints affecting the installation of mechanical and electrical systems

  • Structural constraints related to renewable energy systems and battery storage

For each building in the portfolio, the benchmarking analysis included reviewing the energy required to perform services for the buildings which involved reviewing utility bills to establish consumption baselines for space heating, DHW, cooking, air conditioning, and electric base loads. Carbon emissions analysis was also performed to determine the greenhouse gas emissions resulting from the existing consumption baselines, and the necessary energy consumption reductions needed for each property to comply with LL97.

To test the impact of various retrofit scenarios, FSG developed representative energy models for representative properties, selected to represent groups of similar buildings, for the portfolio using EnergyPlus. These models were calibrated to reflect current building energy consumption and used to create a range of energy efficiency measures.

FSG’s analysis incorporates both proven and emerging low-carbon technologies selected for the appropriateness to multifamily buildings and constrained urban environments. Technologies under consideration include:

  • Variable Refrigerant Flow (VRF) systems for multi-zone heating and cooling

  • Air-source package terminal heat pumps for efficient space conditioning

  • Geothermal domestic hot water systems

  • Photovoltaic (PV) and battery storage systems for onsite generation and load shifting

  • Advanced control systems for temperature controls and monitoring

Along with LL97 strategies, FSG is consulting on policies to lower operational costs and better residential quality of life through other sustainable programs such as water conservation technologies, ventilation, green infrastructure, cooling, building deficiencies, and training programs for operations and maintenance building staff on energy and water management. In addition, the system replacement costs, annual maintenance and repair costs, and other operating expenses were estimated to develop a complete life cycle assessment.

Deliverables

The final deliverables include building compliance categorizations, condition and risk assessments, energy and carbon modeling reports detailing projected performance under multiple retrofit scenarios, cost and lifecycle assessments to guide capital planning, LL97 compliance filing, and a phased, actionable decarbonization master plan for Phipps Houses to meet its emissions reduction targets through 2030, 2040, and 2050 by implementing a variety of sustainability strategies. The results of this analysis will aid PHSI with improvement of energy efficiency across the portfolio, reduce emissions, and align with LL97’s sustainability goals.

Together, these deliverables form a cohesive, data-driven roadmap for PHSI to achieve significant reductions in greenhouse gas emissions and lead the way in equitable climate action within the affordable housing sector.