Summary
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Details
- New York
Local Law 97 (LL97) applies to any building in New York City that meets one of the following criteria:
- Over 25,000 ft² in gross floor area.
- Two or more buildings on the same tax lot (BBL) totaling over 50,000 ft².
- Condominium buildings governed by the same board totaling over 50,000 ft².
The New York Department of Buildings has provided a Covered Building List for the 2025 calendar year identifying over 60,000 buildings subject to LL97 emissions reporting requirements.
Deep dive
Background
Enacted in 2019 as part of New York City’s Climate Mobilization Act, Local Law 97 (LL97) is a landmark state-level carbon emissions reduction measure in the United States. LL97 is administered by the New York City Department of Buildings (DOB) oversees enforcement and compliance monitoring, and the Mayor’s Office of Sustainability which is responsible for policy guidance and implementation strategies. LL97 builds on earlier efforts to track building energy use in New York, notably the Local Law 84 (2009), which required annual assessments of energy and water consumption for large buildings. However, LL97 goes further by imposing strict carbon emissions limits rather than just reporting, aligning with NYC’s goal to reduce building emissions 80% by 2050. Buildings account for 70% of New York City’s GHG emissions and 40% of New York State's GHG emissions, making LL97 a pillar of its climate strategy.
Reporting Requirements and Process
Starting in 2025, LL97 requires owners of covered buildings in New York to submit annual GHG emissions reports through the DOB’s online portal - Building Energy Analysis Manager (BEAM). Reports with emissions data for the previous calendar year are due by 1 May of each year: emissions for the calendar year 2024 are due by 1 May 2025. Reports must detail emissions from direct sources (Scope 1), such as on-site fuel combustion, and indirect sources (Scope 2), including purchased electricity and steam. The DOB has provided a detailed technical guidance manual including emissions calculation methods, which are consistent with EPA GHG Protocol standards. The DOB urges building owners to consult legal advisors and Registered Design Professionals to ensure their properties meet LL97 compliance standards.
Penalties for Noncompliance
Buildings that exceed the annual emissions limits established by the law face fines of $268 per metric ton of carbon dioxide equivalent (CO2e) over the cap, with penalties escalating overtime. For example, a building emitting 500 tons over its limit could face a maximum annual penalty of $134,000. Moreover, failure to submit reports by the deadline incurs a flat fee of $.50 per square foot, while inaccurate submissions may lead to audits or enforcement actions. The DOB could publicly list non-compliant buildings, creating reputational risks in the housing market for commercial buildings.
Tools to help building owners manage LL97 compliance and avoid penalties include:
NYC Accelerator’s Building Energy Snapshot: Operated by the DOB, this free online tool allows users to input their building address and instantly receive a detailed report. It includes energy-use history, projected emissions under LL97, estimated fines (through 2034), and potential savings from energy upgrades.
Carbon Curve by Daisy: This independent, AI-powered calculator focuses specifically on the 2030 emissions threshold. After entering a building address, it generates an emissions timeline graph compared to 2030 LL97 limits and computes potential non-compliance fees, giving owners a clear sense of risk.
Both tools provide address-based inputs, visual dashboards, and penalty forecasts, enabling proactive retrofit planning. They equip owners with the insights needed to identify cost-saving improvements, avoid fines that can range from thousands to hundreds of thousands of dollars, and stay on track for timely LL97 compliance.
Current Status
As of mid‑2025, Local Law 97 remains fully in effect with no injunctions or pauses. The New York Court of Appeals ruled on May 22, 2025, that the statewide Climate Leadership and Community Protection Act (CLCPA) does not preempt LL97, clearing the final legal obstacle and affirming the City's authority to enforce greenhouse gas limits on large buildings. Meanwhile, the DOB’s online reporting portal, launched in March 2025, closed its first-round window on May 1, with a 60-day grace period until June 30, and extensions available through August 29. Enforcement capacity has also been strengthened with new staff devoted to LL97, signaling the DOB's commitment to NYC's building decarbonization drive. The city continues to support owners via different channels including detailed DOB guidance, events like the LL97 Compliance Service Provider Expo, and incentives like electrification credits to ease compliance ahead of 2030.
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