The Good Faith Trap
If you filed a Decarbonization Plan in 2025, you might think you're protected until 2030. You're partially correct. And that partial correctness is dangerous.
2025
Decarbonization plans filed
Good Faith claims submitted
2026
DOB audits begin
Good Faith claims reviewed
2030
Final compliance deadline
Caps tighten 50%
The "Good Faith" extension allows you to avoid penalties for exceeding 2024-2029 emissions caps IF you submitted a plan showing how you will comply by 2030.
However:
- The extension does NOT protect you from LL87 audit violations
- It does NOT protect you from failing to maintain existing equipment
- It does NOT protect you from tenant lawsuits about energy waste
"Owners can significantly reduce or defer penalties by documenting 'Good Faith Efforts,' including signed retrofit contracts, permits, financing commitments, and a clear implementation schedule."
The New Question
The DOB is now asking: "You said you would install heat pumps by 2028. That's fine. But why did you let your existing boiler deteriorate so badly that it's emitting 30% more carbon today than it did in 2023?"
What the DOB Wants to Know
In 2026, DOB auditors are asking specific questions about your existing equipment:
Maintenance Records
"Show us what you did to maintain the boiler you're still using. Where are your service logs?"
Efficiency Measurements
"What's your current boiler efficiency? How does it compare to five years ago?"
Capital Investment
"What have you invested in maintaining current equipment while you plan for 2028?"
Efficiency Improvements
"Have you done anything to improve the efficiency of existing systems?"
The bottom line: Negligence is not "Good Faith." If you ignored the equipment you currently own, the DOB can revoke your extension and impose retroactive penalties.
What Actually Counts as Good Faith
- ASHRAE-level energy audit
- Board-approved capital plan
- Financing in place or committed
- Permits filed with DOB
- Signed contracts for retrofit work
Notice what is NOT on the required list:
- Evidence that existing equipment was maintained
- Documentation of current operating efficiency
- Proof that the building isn't wasting energy TODAY
This is the gap the DOB is now auditing.
Value-Added Documentation
Smart building owners are adding these to their Good Faith files:
- Vulcan installation date (capital invested in existing equipment)
- Pre-installation efficiency measurements (delta-T, stack temp)
- Post-installation efficiency improvement (12-18% verified gain)
- Maintenance records showing proactive care
Real Proof: 13 Years of Maintenance-Free Protection
Location: Arch, Switzerland
Property Type: Residential home
Installation: Over 13 years ago
Homeowner's Testimonial
"Vulcan has now been in service for more than 13 years and still requires no maintenance. In addition, we no longer have any scale problems with our water pipes. That is why we recommend the purchase of this unit and would be prepared to buy it again if necessary."
The Good Faith Documentation
- Installation date: 13+ years of documented history
- Maintenance record: Zero maintenance required
- Performance proof: "No more scale problems with water pipes"
- Owner satisfaction: "Would buy again"
Why This Matters for Your Good Faith File: When the DOB asks "What did you do to maintain your existing equipment?", a 13-year track record of documented, maintenance-free scale prevention is powerful evidence. It shows proactive ownership, not neglect.
Residential House in Arch — 13 years of maintenance-free protection
Building Your Good Faith File with Vulcan
Installation Date
Proof of capital invested in equipment preservation, not just promises.
Pre-Installation Measurements
Documented baseline showing existing efficiency (or lack thereof).
Post-Installation Improvement
Verifiable 12-18% efficiency gain = proof of proactive maintenance.
Long-Term Records
Like the homeowner in Arch, you can document years of maintained efficiency.
Your Exhibit A
When the DOB asks "What did you do to maintain your existing equipment?", Vulcan documentation is your answer.
The ROI of Good Faith
| Annual fine exposure (typical building, 200 MT excess) | $53,600 |
| 10-year exposure | $536,000 |
| Good Faith extension (with documentation) | Penalties reduced/deferred |
| Good Faith extension (without documentation) | At risk of revocation |
| Vulcan model (typical installation) | Login for pricing |
| Value of documented Good Faith | $500,000+ preserved |
Get Exact Pricing for Your Building
For precise pricing tailored to your building's specifications:
- Existing customers: Log in to your account to view model-specific pricing
- New users: Create a free account to access detailed pricing and configuration options
- Need assistance? Contact our team for a Good Faith file consultation
Account registration takes less than 2 minutes.
* Savings vary based on building size, fine exposure, and documentation quality.
Selecting the Right Model for Your Good Faith File
Different building sizes require different Vulcan models. Create an account to view detailed specifications and pricing.
| Building Size | Recommended Model | Pipe Diameter | Flow Rate | Typical Application |
|---|---|---|---|---|
| Small residential / small commercial | Vulcan V5000 | Up to 2" | 35 GPM | Water heaters, small boilers |
| Mid-size commercial / multifamily | Vulcan S10 or S25 | 3-4" | 65-130 GPM | Boilers, heat exchangers |
| Large commercial / institutional | Vulcan S50 or S100 | 5-6" | 300-530 GPM | Central plants, cooling towers |
The 2026 Audit Timeline
March 31
LL87 audit deadline. Physical inspection of mechanical systems.
May 1
LL84 + LL97 filings. Penalties for 2024 exceedances collected.
June 1
NYSDEC GHG reports due for facilities >10,000 MT
Ongoing
Good Faith audits. DOB reviewing documentation.
The time to build your Good Faith file is now, before the auditor asks.
Building Your Good Faith File
- ASHRAE-level energy audit – Completed within last 5 years
- Decarbonization plan – Board-approved, with timeline to 2030
- Financing documentation – Commitments, grants, or budget allocations
- Permit filings – DOB permits for planned work
- Signed contracts – For heat pumps, retrofits, or other improvements
- Maintenance records – Vulcan installation, efficiency measurements, service logs
- Pre/post efficiency data – Delta-T improvements, stack temperature reductions
- Long-term documentation – Like the 13-year homeowner in Arch
Build Your Good Faith File Today
Don't wait for the auditor to ask. Document your proactive maintenance now.
About the Author
Waslix provides non-chemical, maintenance-free scale prevention using Vulcan technology. We help building owners document proactive equipment maintenance for LL97 Good Faith audits. Create an account for detailed model specifications and pricing.
