Local Law 97 (LL97): New York City's Landmark Building Emissions Law

What is LL97?

New York City's Local Law 97 (LL97) is a landmark legislation aimed at reducing greenhouse gas emissions from large buildings, the city's largest source of emissions. The law sets strict emissions limits for buildings over 25,000 square feet to achieve an 80% reduction in emissions by 2050.

Under LL97, building owners will be penalized $268 for every ton of emissions over their limit. The penalties will become harsher in 2030 when properties must cut emissions by 40% from their 2006 levels. Failure to submit emissions reports on time will also result in fines of 50 cents per square foot per month.

While 88% of buildings subject to the law are on track to meet the 2024 benchmarks, only 35% align with the 2030 limits. By 2030, an estimated 13,500 of the 50,000 properties required to be compliant won't be, with cumulative fines adding up to $900 million yearly.

The deadline to submit this year’s LL97 compliance report is May 1, 2025, with a 60-day grace period through June 30, 2025.

Some strategies to help buildings comply with LL97 include conducting energy audits, implementing energy efficiency measures, installing renewable energy systems, and engaging with tenants to promote energy-saving behaviors. If fully implemented, LL97 has the potential to significantly reduce New York City's greenhouse gas emissions reduction, putting the city on track to meet its ambitious climate goals.

Updated Key Provisions of Local Law 97 (LL97)

Local Law 97 is a groundbreaking climate legislation designed to reduce greenhouse gas emissions from New York City's largest buildings, which account for approximately 70% of the city's carbon emissions. The following is an updated version of the key provisions based on current information.

Compliance Timeline and Reporting Requirements

• First Compliance Period: Emissions limits for covered buildings began in 2024, with increasingly stringent limits phased in over time
• Reporting Deadline: The first annual emissions compliance report is due by May 1, 2025, covering emissions from calendar year 2024
• Grace Period: A 60-day grace period extends the filing deadline to June 30, 2025, with no penalties
• Extension Option: Building owners may apply for an extension to submit reports by August 29, 2025

Building Coverage and Emissions Limits

• Covered Buildings: Most buildings exceeding 25,000 gross square feet, two or more buildings on the same tax lot totaling over 50,000 square feet, or condominium buildings under a single board exceeding 50,000 square feet
• Phased Compliance: Emissions limits become increasingly stringent over time:
• 2024-2029: Initial emissions limits (affecting approximately 5,300 buildings)
• 2030-2034: Stricter limits apply (potentially affecting up to 80% of covered buildings)
• 2035-2049: Further reductions required
• 2050: Net-zero emissions goal

Penalties and Enforcement

• Emissions Exceedance Penalties: Buildings exceeding their annual emissions limits face penalties, which can amount to millions of dollars for large buildings
• Reporting Non-Compliance: Failure to file by the deadline results in a monthly penalty of $0.50 per square foot of the building. For example, a 25,000-square-foot building would face a $12,500 monthly penalty starting July 1, 2025

Compliance Pathways

• Article 320: Applies to private sector, non-rent-regulated buildings, requiring annual emissions reporting and compliance with carbon caps
• Article 321: Applies to buildings with at least 35% rent-regulated units and houses of worship, offering alternative compliance through prescriptive energy conservation measures

Compliance Options

• Energy Efficiency Upgrades: Implementing energy-saving measures such as upgrading HVAC systems, improving insulation, and enhancing lighting efficiency
• Building Electrification: Converting fossil fuel systems to electric alternatives, with potential credits for beneficial electrification
• Renewable Energy Credits (RECs): Building owners can purchase local RECs (generated in or directly feeding NYC's electrical grid) to offset emissions from electricity usage, though these cannot offset emissions from on-site fossil fuel combustion
• Free Assistance: NYC Accelerator offers free assistance with energy efficiency and renewable energy upgrades to help buildings meet compliance requirements

Connection to Other Laws

• Local Law 87: Requires energy audits and retro-commissioning every ten years (not five), which can help identify energy conservation measures relevant to LL97 compliance
• Climate Mobilization Act: LL97 is part of NYC's broader Climate Mobilization Act, which aims to reduce building emissions by 40% by 2030 and 80% by 2050

Exemptions

Exempt buildings include industrial facilities generating electric power or steam, specific low-rise detached properties, NYCHA buildings, HDFC properties, and most city-owned buildings

This law represents one of the country's most ambitious building emissions regulations. It will significantly impact how buildings in New York City operate and invest in sustainability improvements over the coming decades.

Compliance Challenges and Strategies

While LL97 is necessary to reduce the city's carbon footprint, it poses significant challenges for building owners and managers. Retrofitting older buildings to meet emissions limits can be costly and disruptive. However, some strategies can help buildings comply with the law:

• Conducting energy audits to identify areas for improvement
• Implementing energy efficiency measures like LED lighting, HVAC upgrades, and insulation
• Installing renewable energy systems like solar panels or geothermal heating
• Engaging with tenants to promote energy-saving behaviors

The Impact of LL97

If fully implemented, LL97 has the potential to reduce New York City's greenhouse gas emissions significantly. According to estimates from the NYC Mayor's Office of Sustainability, the law could reduce emissions from covered buildings by 40% by 2030 and 80% by 2050. This would put the city on track to meet its ambitious climate goals and serve as a model for other cities worldwide.

Legislative Context and Goals

• Comprehensive Emissions Strategy: LL97 is part of a broader climate strategy that includes the city's first climate budgeting process, integrating climate considerations into financial decisions. This approach ensures that all city investments align with long-term sustainability goals, including achieving net-zero emissions by 2050.
• Alignment with Global Standards: New York City's adoption of climate budgeting places it among leading global cities like London and Oslo, emphasizing its commitment to innovative climate action and setting a precedent for other municipalities.

Financial Implications and Support

• Funding for Compliance: The city has allocated significant resources to support LL97 compliance, including $4 million to the Department of Buildings for enforcement and $1.27 million annually for the Property Assessed Clean Energy Financing program. These funds are designed to help building owners improve energy efficiency and meet emissions targets.
• Economic Opportunities: The implementation of LL97 and climate budgeting could create approximately 400,000 "green-collar" jobs by 2040, fostering economic growth while addressing environmental challenges.

Challenges and Solutions

• Building Retrofits: Retrofitting older buildings poses financial and logistical challenges. However, the city encourages building owners to explore energy audits and efficiency upgrades, which can mitigate costs in the long run by reducing energy consumption and associated emissions.
• Engagement and Education: Engaging tenants in energy-saving practices is critical. Building owners are encouraged to foster a culture of sustainability among occupants, which can lead to significant reductions in overall energy use and emissions.

Long-term Impact

• Projected Emission Reductions: If fully implemented, LL97 could lead to a 40% reduction in emissions from covered buildings by 2030 and an 80% reduction by 2050, significantly contributing to New York City's climate goals and serving as a model for other cities worldwide.
• Resilience Against Climate Threats: Integrating climate considerations into budgeting and building regulations not only addresses emissions but also enhances the city's resilience to extreme weather events, a crucial aspect given the increasing frequency of such occurrences due to climate change.

Conclusion

Local Law 97 is a transformative step in New York City's fight against climate change, targeting the city's largest source of emissions-its buildings. By setting ambitious emissions limits and enforcing them through significant penalties, LL97 compels building owners to prioritize energy efficiency, electrification, and renewable energy adoption. While compliance presents notable financial and logistical hurdles, especially for older properties, the law also unlocks opportunities for innovation, job creation, and long-term cost savings. With robust support systems, partnerships, and city-backed funding, building owners can access resources to ease the transition.

The law’s integration with broader climate budgeting further ensures that environmental priorities are embedded in all city investments, enhancing resilience against climate threats. Ultimately, LL97 is more than a regulatory mandate-it is a blueprint for cities worldwide seeking to balance economic growth, environmental responsibility, and community well-being in the face of a changing climate.

How Zero Circle Helps with LL97 Compliance

1. Building energy audits
2. Strategy development for emissions reduction
3. Connecting with NYC programs
4. Support for reporting and penalty mitigation

Zero Circle can help buildings comply with Local Law 97 in New York City, which aims for greenhouse gas emissions reduction from buildings, regarded as the principal source of such emissions. By focusing on buildings, Local Law 97 provides an opportunity for Zero Circle to assist in making a dent in the fight against climate change through its expertise and solutions tailored to buildings. 

New York City's Local Law 97 (LL97) represents a significant effort to combat climate change through stringent regulations on greenhouse gas emissions from large buildings.