NYC Local Law 97 (LL97): Your Complete Guide to Compliance and Carbon Limits

Generally, any building over 25,000 gross square feet (GFA) must comply. This also includes two or more buildings on the same tax lot that exceed 50,000 GFA combined. While most properties are covered, certain buildings have alternate requirements, such as houses of worship, city-owned buildings, and specific types of affordable housing (e.g., Mitchell-Lama, HDFCs).

The first set of carbon emissions limits took effect in 2024. Significantly more stringent caps begin in 2030, aimed at achieving a 40% carbon reduction citywide by that year.

Not necessarily. Approximately 75–80% of multifamily buildings are already in compliance with the initial 2024 limits. However, if your building exceeds its carbon limit, you will need to implement operational improvements, energy conservation measures, or retrofits to achieve compliance.

Fines are calculated annually based on how much a building exceeds its assigned carbon limit, charged at $268 per metric ton of CO2 over the limit.

Owners must file an annual emissions report for each covered building, detailing building information, gross floor area (GFA), and calculated emissions. The report must be certified by a Registered Design Professional (RDP) and submitted through the NYC DOB’s BEAM Portal, typically by June 30th of each year.

Buildings with one or more rent-regulated units that are exempt from strict emissions limits can instead submit evidence of having performed specific prescriptive energy conservation measures. These include pipe insulation, steam trap repairs, weatherization, boiler sensor installations, and adjusting temperature set points to reflect occupancy.

No. Local Law 84/133 requires you to report annual energy usage (benchmarking), while Local Law 97 requires reporting emissions and meeting specific carbon caps. Benchmarking is a strategic tool to help you understand your energy usage and prepare for LL97 compliance, but the reports are distinct.

Local Law 87 provides the necessary roadmap for LL97. An LL87 energy audit and retro-commissioning process can identify low-cost operational improvements that help you achieve the carbon reduction targets required by LL97. We re-tool our LL87 audits to specifically target LL97 compliance, ensuring your investment serves both laws.

Local Law 33/95 requires buildings over 25,000 square feet to post an energy efficiency letter grade (A–F) at public entrances annually. These grades are derived from your ENERGY STAR Portfolio Manager score, which is based on the energy usage you report for benchmarking. While related to energy usage, the grades are a transparency tool, whereas LL97 is a performance-based emissions mandate.

You must design with minimum carbon emissions in mind to meet future LL97 limits. Additionally, you must comply with Local Law 92 (LL92) and Local Law 94 (LL94), which require the installation of a green roof or solar photovoltaic (PV) system on new developments.