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NYC Local Law 97: How to Reduce Your Building Emissions and Avoid Fines

Learn how to comply with one of the most ambitious energy efficiency laws in the world.


Tim Olson | Senior Environmental & Sustainability Regulatory Advisor
APTIM | Environment & Sustainability Solutions
Tim is a visionary public policy attorney and a hands-on project administrator and manager with over 10 years’ experience in developing and sharing solutions to energy and environmental crises. Among other projects, Tim currently supports the design and development of e-bike rebate, registration, application, and reimbursement systems for Denver and Boulder, Colorado.

Brian Thurston | Sustainability Solutions Sales Director
APTIM | Environment & Sustainability Solutions
Brian leads business development for APTIM’s Sustainability Solutions group and has spent the last 16 years focusing on strategy, innovation, and technology solutions to tackle big challenges at scale.


NYC Local Law 97: How to Reduce Your Building Emissions and Avoid Fines

New York City’s Local Law 97 (LL97) is recognized as one of the most ambitious energy efficiency laws in the world. Over one-third of the metropolitan area’s greenhouse gas (GHG) emissions are attributable to its built environment, so when NYC City Council passed the Climate Mobilization Act in 2019, they narrowed in on building emissions. LL97 was one of the earliest examples of building performance standards (BPS), and it continues to be one of the most comprehensive today.

As with many climate and energy policies, legislators offered a few years for building owners to prepare before enforcement on decarbonization efforts. That forgiveness period is now over. Starting this year, all buildings larger than 25,000 square feet must meet ambitious GHG reduction to avoid the risk of financial penalties. Building owners could be charged up to $268 for every ton of carbon dioxide equivalent (CO2e) they emit above their annual allowance. (For reference, one metric ton of CO2 emissions is equivalent to burning about 100 gallons of gasoline or driving about 2,500 miles in a passenger vehicle.) Even stricter limits will come into effect in 2030.

What is Local Law 97?

The specific requirements outlined in this municipal climate change mitigation law include:

  • Emission Reduction Targets: Specific, time-bound targets for GHG emissions reduction must be defined for covered buildings.
  • Building Emissions Limits: Covered buildings are required to meet certain emissions limits measured in carbon dioxide equivalent (CO2e) emissions per square foot of floor area based on their occupancy class and size.
  • Compliance Deadlines: Expectations for emissions reduction become progressively stricter over time.
  • Penalties for Non-Compliance: Building owners who fail to meet emissions limits are subject to penalties, which may include fines or other enforcement actions.
  • Reporting and Documentation: Building owners must report their energy usage and emissions data to the city annually—which will be used to assess compliance.
  • Regulatory Exemptions: For buildings unable to meet emissions limits through traditional means, alternative compliance pathways are to be explored including renewable energy generation, energy efficiency upgrades, and emissions trading programs.
  • Monitoring and Enforcement: The city monitors compliance through regular reporting and inspections and may take enforcement action against non-compliant building owners.

How to Comply with LL97

According to Urban Green Council, 20% of the more than 50,000 regulated buildings in NYC exceed emissions caps set for 2024 and upwards of 76% exceed the 2030 cap. Conservatively, tens of thousands of buildings are out of compliance. In addition to paying penalties, noncompliance with BPS can lead to negative perceptions among investors, tenants, and regulators. Thus, property owners or operators could face significant damage to their reputations through public disclosures of noncompliant buildings.

APTIM provides services to help close the BPS and LL97 compliance gap. To get started and swiftly comply, our team can provide the following:

  • Energy Benchmarking: Using tools like ENERGYSTAR™ Portfolio Manager and New York City Energy Efficiency Reports to benchmark the energy use of covered buildings
  • Emission Reduction Strategies: Offering roadmapping support to identify effective strategies to reduce building emissions
  • Financial Planning: Assessing the financial implications of compliance efforts, including upfront investment costs and potential long-term savings from energy efficiency improvements
  • Implementation: Executing identified emission reduction strategies, ensuring that all measures are implemented efficiently and effectively
  • Monitoring and Reporting: Continuously monitoring building energy performance to track progress towards emission reduction goals
  • Compliance Verification: Verifying compliance with LL97 through periodic inspections, audits, or certifications
  • Adaptation and Optimization: Regularly reviewing and refining emission reduction strategies to optimize building performance and maximize energy savings
  • Engagement and Education: Engaging building occupants, owners, and stakeholders in sustainability initiatives, raising awareness about the importance of reducing emissions, and promoting energy conservation behaviors

More and more commercial tenants are implementing corporate social responsibility and sustainability policies, and some have even shown a preference for leasing spaces in energy-efficient and low or zero-carbon buildings. Residential customer demand for efficient buildings is growing as well, and noncompliance could make it significantly more difficult for underperforming properties to attract and retain tenants, leading to higher vacancy rates and lower returns on investment.

If you are a building owner or operator seeking support on managing BPS, get in touch with our Sustainability Solutions team. Our experts can guide you top-to-bottom to achieve compliance and demonstrate leadership in environmental performance.

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