NYC’s Local Law 97 Sets GHG Emissions Limits for Its Buildings’ Sustainable Future

Approximately 70 percent of New York City’s (NYC) greenhouse gas (GHG) emissions come from the fossil fuels that power the city’s buildings. NYC enacted the Climate Mobilization Act in 2019 to reduce its GHG emissions. As a part of the Climate Mobilization Act, Local Law 97 has established annual GHG emissions limits for the city’s largest buildings. With enforcement beginning in 2025, this mandate requires compliance from approximately 50,000 buildings in NYC. By enacting Local Law 97, NYC strives to integrate sustainability into the city’s largest buildings by promoting renewable energy, discouraging the use of fossil fuels, encouraging energy efficiency, and lowering operation expenses.

This article first examines the types of buildings covered by Local Law 97 and the anticipated benefits. It then examines Local Law 97’s reporting requirements, methods to reduce building emissions, and resources provided by NYC to ensure compliance. It concludes by analyzing the growing trends of sustainability in building emissions reduction.

Buildings That Are Covered under Local Law 97 and Anticipated Benefits

Covered buildings are:

• a building exceeding 25,000 square feet;
• two or more buildings on the same tax lot exceeding 50,000 square feet together; or
• two or more condominium buildings exceeding 50,000 square feet together, governed by the same board.

By assisting these buildings to increase energy efficiency or to upgrade with renewable energy, NYC seeks to reduce its emissions by 10 percent by 2030, which is equivalent to 6 million tons of GHG emissions. NYC will introduce stricter compliance requirements by raising compliance standards in five reporting periods: 2024–2029, 2030–2034, 2035–2039, 2040–2029, and 2050 to achieve carbon neutrality. By gradually lowering emissions limits, NYC provides time for covered buildings to transition. Furthermore, Local Law 97 provides alternative compliance pathways for certain covered buildings, such as affordable housing or house of worship. Those buildings can comply by showing that their emissions are under the emissions limit or that they have completed the thirteen Prescriptive Energy Conservation Measures.

Reporting Requirements under Local Law 97, Methods to Reduce Buildings Emissions, and Resources to Achieve Compliance

Local Law 97 requires covered buildings to report GHG emissions to NYC’s Department of Buildings by May 1, 2025, and every year onwards. These reports will also include information about the building’s energy usage and emissions from the prior year and identify whether the building exceeds the emissions limit. The reports must be certified by a professional, such as a licensed engineer or a registered architect. Building owners must implement work to achieve emissions reductions, as buildings that exceed emissions limits are subject to civil penalties of $268 per ton of CO₂ over the limit.

To achieve emissions reductions, building owners can make improvements to the buildings by increasing energy efficiency, making renewable energy upgrades, or introducing distributed energy resources (DER). Local Law 97 provides a beneficial electricity credit to reward buildings that replace fossil fuel systems with electric alternatives to lower emissions. Specifically, the installation of heat pump water heaters can result in the application of electrification credits that decrease the fines by 93 percent in 2030 to 2034. Building owners can claim lower emissions and achieve compliance or lower penalties using the credit. Local Law 97 will also allow building owners to use renewable energy credits (RECs) to claim emissions reduction.

Furthermore, Local Law 97 pushes for upgrades and retrofit solutions to reduce emissions, save energy, and transition to a climate-friendly, sustainable building for NYC’s carbon-neutral future. In its guidance, NYC highlights retrofits to save energy and reduce GHG emissions by modernizing controls and installing high-efficiency appliances and insulation measures. Combining these practices with installing renewables like solar can reduce GHG emissions significantly.

Such sustainable practices will allow the city to reduce building emissions effectively. Still, successful compliance is key for NYC to achieve its goal and for the building owners to avoid fines. NYC’s Department of Buildings provides resources like the Local Law 97 Service Provider Program and the NYC Accelerator to facilitate the transition with energy efficiency and renewable energy upgrades. These programs assist building owners by providing free guidance to accelerate the transition, such as a financing assistance program to explain financing options to building owners and to provide support in the financing process. Furthermore, the program creates a network to increase participation and identifies building upgrade projects to meet emissions limits.

The Growing Trends of Building Emissions Reduction and Sustainable Buildings

Local Law 97, enacted in 2019, demonstrates NYC’s commitment to addressing climate change by targeting buildings that contribute to 70 percent of GHG emissions in the city. In other states, numerous rules have also been promulgated to lower emissions caused by buildings. For example, Washington enacted the Clean Buildings Performance Standard in 2019. Boston’s Building Emissions Reduction and Disclosure Ordinance requires large buildings in Boston to reduce GHG emissions. The U.S. Department of Energy announced a final rule in 2024 to decrease emissions from new or renovated federal buildings. Alongside Local Law 97, these rules illustrate a growing trend to reduce buildings’ reliance on fossil fuels and facilitate the transition to renewable energy and sustainable energy-efficient practices.