New York City’s Local Law 97 Year One Results: High Compliance Ahead of Tougher 2030 Limits

Buildings account for more than two-thirds of greenhouse gas emissions in New York City, which makes them the central target of Local Law 97 (LL97), one of the most ambitious building emissions policies in the United States. Under the law, most buildings larger than 25,000 square feet must stay within annual emissions limits that began in 2024 and become stricter in 2030. Calendar year 2024 was the first compliance year, and reports were due by December 31, 2025. The NYC Department of Buildings (DOB) has now released its first compliance report, and the results show strong participation. Of 19,963 properties required to report, representing 29,031 buildings, about 95% filed, and 95% of Article 320 filers with emissions data met their limits. The first year gives owners a useful baseline, but the larger test arrives when limits tighten at the end of the decade.

First-Year Filing and Compliance Rates

When LL97 was enacted in 2019, it was designed so that roughly 80% of covered properties would already fall below the first-period limits, leaving the highest-emitting 20% to make reductions. Actual results came in higher. The law has two main compliance paths. Article 320 generally applies to market-rate buildings of all use types and requires annual emissions reports. Article 321 covers many affordable housing properties and houses of worship through a one-time obligation, which owners can meet either through emissions performance or by completing prescribed energy conservation measures (PECMs).

Key results from the first compliance year include:

• Article 320: Of 10,437 properties that filed, 9,951 met their limits and 470 exceeded them. Among those over the limit, 32% exceeded it by less than 10%, 42% by 10 to 50%, and 26% by more than 50%.
• Article 321: Of 8,501 filers, 83% chose the prescriptive PECM pathway. Of those, 73% reported completing the required work and 27% requested more time. Among the 12% using the performance pathway, 90% already meet the stricter 2030 limits.
• Borough and property type: Article 320 filing rates ranged from 98% in Manhattan to 84% on Staten Island. Emissions compliance was 95% for multifamily and office properties, 91% for hotels, and 86% for distribution centers.

Results varied more at the neighborhood level. Most council districts had compliance rates of 93% or higher, while several districts in Queens and the Bronx fell between 79% and 86%.

How Buildings Met Their Emissions Limits

According to DOB officials speaking at an Urban Green Council webinar, most properties that needed to cut emissions did so through conventional upgrades and efficiency measures. These included lighting retrofits, building envelope improvements, heat pump installations, and building or energy management systems. The DOB report also highlights the role of fuel choice. Comparing the energy mix of properties above and below their limits, it finds that reducing fossil fuel use plays an important role in achieving compliance.

LL97 also offers alternative compliance tools, including offsets, limit adjustments, deductions, and alternative calculation methods. Each mechanism was used by fewer than 1% of filers in the first year:

• 79 properties used Affordable Housing Reinvestment Fund (AHRF) offsets
• 31 used solar deductions
• 10 used the combined heat and power methodology
• 6 used the beneficial electrification deduction
• No property used offsite or onsite storage, fuel cell, alternative fuel, or cell tower deductions

AHRF offsets are the only offsets eligible under LL97, and their proceeds fund efficiency and electrification upgrades in affordable housing across the five boroughs. DOB officials said the fund has raised $1.7 million so far, with money allocated to two deep electrification projects.

Enforcement, Penalties and Good-Faith Mitigation

DOB paired enforcement with outreach during the first year. Ahead of the reporting deadline, the department held 56 webinars and presentations and ran more than 40 mail and email campaigns reaching over 244,000 recipients, working alongside NYC Accelerator. Owners who fell short received Notices of Deficiency (NODs), which give them an opportunity to come into compliance before penalties are pursued. Figures shared at the webinar show how that process is playing out:

• Failure to file (Article 320): DOB issued 1,014 NODs. Afterward, 239 properties filed and 111 were resolved through exemptions or exceptions, while the remaining 664 were referred to the Office of Administrative Trials and Hearings (OATH).
• Emissions exceedances: DOB issued 164 NODs. About 15 properties have paid or are paying penalties totaling roughly $270,000. Penalties can reach $268 per ton of CO2e above a building’s limit.
• Article 321: DOB issued 476 NODs and has begun issuing $10,000 violations to properties that still have not filed.

Owners over their limits can also request penalty mitigation by demonstrating good-faith efforts. Of the 470 Article 320 properties above their limits, 149 made such requests, and DOB officials said 102 of those chose to submit decarbonization plans through 2050. Where owners show a credible path to compliance, DOB may resolve cases through mediated resolutions. Owners who do not engage face penalties.

What the Results Mean for 2030 Compliance

The first-year results suggest most covered buildings are currently within their limits, but the requirements change significantly in 2030. The law’s tighter limits are designed to cut emissions from the city’s largest buildings by 40% by 2030 and reach net zero by 2050. DOB officials noted at the webinar that data refinement, differences between how square footage was modeled and measured, and alternative compliance pathways all contributed to compliance exceeding the original 80% projection. They added that data refinement will not help owners in the next period. Some options will expand. Beginning with reports filed in 2027, eligible renewable energy credits can be applied against emissions from grid electricity. The 470 properties currently over their limits, many only slightly, and the minimal use of storage and electrification deductions suggest there is still room for action. Because deeper retrofits such as heat pump conversions require long lead times, planning ahead of 2030 appears to be the next priority for much of the city’s building stock.

Reference

• NYC Department of Buildings: Local Law 97: 2024 Compliance and Reporting Rates
• Urban Green Council: Local Law 97: Year One Results with NYC DOB