NYC Ll97: There’s still time
ICYMI – 2025 NYC Local Law 97 Deadline is Here!
2025 is the first filing year for New York City’s Local Law 97 emissions law. Local Law 88 Lighting and Submetering and LL84 Benchmarking are also due this year. The deadline for all three laws was pushed from May 1 to June 30, and an extension to August 29th is available for a fee.
These laws apply to buildings over 25,000sf across the 5 boroughs (almost 60,000 buildings in total). It seems many building owners are still not ready, so we prepared a very concise to do-list below.
CodeGreen is NYC’s leader in energy compliance filings and experts in the systems and processes required to comply on time and avoid fines. Contact us to get started!
If you don’t have a compliance plan for these laws, you must get started right away. There is still time to comply by Aug 29th, but you MUST file an extension before June 30th.
Step 1 – Confirm if your building needs to comply with each law
These laws generally apply to all types of buildings in the 5 boroughs that are 25,000 square feet and over. The City has published a Covered Building List for each law. Compliance is based on your Borough, Block and Lot (BBL). Each law has a different CBL so your building may be on one list and not another.
Step 2 – Engage an experienced Registered Design Professional (RDP) to support all three filings
LL88 and LL97 require an RDP (Registered Architect or Professional Engineer) to sign the filings. The filing processes for LL84, 88 and 97 are so intertwined, we highly recommend selecting a SINGLE vendor to prepare and file all three. The filing fee covers all three laws and links the submissions together. The filing process is very complex and requires experience with DOB NOW and knowledge of all the LL97 filing guidance. If a vendor offers to charge you $500 for the entire process, steer clear.
Step 3 – Have your RDP file for an extension
If you haven’t started yet, you will not be able to hit the June 30th deadline. Building owners and RDPs can apply for a $60 extension for all three laws that pushes the deadline back to August 29, 2025. This must be done through DOB NOW and completed before June 30, 2025. Payments can take a few days to clear, so to be safe, this should be completed by June 25th.
Step 4 – Identify which LL97 compliance path your building needs to follow
Buildings are assigned to one of three compliance pathways based on the presence of rent regulated apartment units:
“Article 321” Buildings - Buildings with >35% rent-regulated units: must perform a set of prescriptive measures by 2025 compliance deadline (or meet Article 320 limits by 2025 deadline)
“2026 Pathway” - Buildings with 1-35% rent-regulated units: must meet Article 320 emissions limits, but starting in 2026 with first filing due in 2027
“Article 320” Buildings - All other buildings not included above: must meet emissions limits based on ESPM spaces in 2024 with first filing due in 2025
LL97 sets emissions limits based on types of spaces in your building (ie office, retail, residential, etc), so you will need to confirm the square footage of each type of space in your building which can be time-consuming.
Even if your building is below the 2024 LL97 emissions limits you STILL need a PE/RA to stamp and submit for compliance which involves multiple steps across multiple city web portals.
Step 5 – Identify if your building is eligible for any adjustments or exemptions
Certain types of buildings and systems may be eligible for limit adjustments that can dramatically reduce annual fines:
Onsite Solar
Onsite Cogen
Recently Electrified Heating/Hot Water Systems
Hospitals
Manufacturing
Data Centers/Communication
Step 6 – Make sure to complete the online payments and filings by the deadline
The fine for missing the LL97 deadline is $0.50/sf per month, which is astronomical.
Step 7 – Develop a retrofit plan to reduce your building emissions to meet current and future LL97 emissions limits
Local Law 97 emissions limits continue to get more stringent every 5 years and building owners must develop long-term equipment upgrade and replacement cycles to lower energy and emissions over time.
CodeGreen is NYC’s leading expert in local energy filings. We have submitted over 1.6 billion square feet of local energy filings since 2009. Our in-house data management, engineering and code teams work together to streamline the collection, preparation and filing of Local Law 84, 88 and 97.
Once the 2025 filings are complete, our engineers will help you develop your long-term retrofit capital plan to avoid future LL97 fines. Call CodeGreen to get started ASAP and avoid 2025 and future violations.
Phone: (212) 695-5980 Email: info@codegreen.com