New York City's Local Law 97, part of the Climate Mobilization Act of 2019, establishes strict carbon emission limits for buildings over 25,000 square feet. With 2024 limits in effect and annual compliance reports due, building owners and boards must start planning now for the significantly stricter 2030 limits.
Understanding the 2030 Requirements
Local Law 97 requires buildings to achieve at least a 40% reduction in carbon emissions by 2030 compared to baseline levels. Emission limits are set in kilograms of CO2 equivalent per square foot per year (kgCO2e/sq ft/yr). For 2024, examples of limits include: multifamily residential at 4.53 kgCO2e/sq ft/yr, office at 8.46, hospital at 23.81, and warehouse at 2.19. These caps become more stringent in 2030 and continue tightening through 2050, when buildings must reach an 80% emissions reduction.
Penalties for Non-Compliance
Buildings that exceed their emissions limits face fines of $268 per metric ton of CO2 equivalent over the limit per year. For a 100,000 sq ft building that exceeds its limit by 100 metric tons, that translates to $26,800 annually—and penalties apply every year the building remains non-compliant. Compliance began in 2024 for approximately 34,000 buildings, with penalties starting in 2025. An estimated 5,300 buildings were projected to be out of compliance initially, and that number will grow as limits tighten in 2030.
Key Strategies for Compliance
1. Energy Audits — Start with a comprehensive Local Law 87 energy audit if not already completed. This identifies your building's current emissions profile and highest-impact improvement opportunities.
2. Building Systems Upgrades — HVAC systems typically account for 40–60% of building energy use. Consider high-efficiency boilers, chillers, VFDs on pumps and fans, and building automation upgrades.
3. Electrification — Transitioning from fossil fuel heating to electric heat pumps is one of the most effective strategies. The NYS Clean Heat program and other state incentives can help offset costs.
4. Renewable Energy — On-site solar, renewable energy credits (RECs), or power purchase agreements (PPAs) can reduce grid electricity emissions.
5. Building Envelope — Insulation, window upgrades, and air sealing reduce heating and cooling loads and lower overall energy consumption.
Financial Considerations and Incentives
Multiple programs help offset improvement costs: NYSERDA FlexTech for energy studies, NYS Clean Heat for heat pumps, NY-Sun for solar, Con Edison rebates for equipment upgrades, and federal tax credits under the Inflation Reduction Act, including the 179D deduction for energy-efficient commercial buildings. Building owners should work with their property manager and a qualified energy consultant to identify which programs apply to their asset type and project scope. Combining incentives can significantly reduce net capital cost and payback periods.
Reporting and Deadlines
Local Law 97 requires annual benchmarking and reporting of greenhouse gas emissions. Buildings must submit reports by the deadline set by the Department of Buildings; late or inaccurate filings can result in additional penalties. Keeping accurate energy and fuel data throughout the year simplifies reporting and helps boards track progress toward 2030 and 2050 goals. Many property managers and third-party vendors offer LL97 reporting and tracking services.
Getting Started
With 2030 only a few years away, the time to start planning is now. Major capital improvements require board approval, financing, and construction timelines. Contact your property manager or a qualified sustainability consultant for a compliance assessment and strategy tailored to your building. Early action reduces the risk of costly penalties and spreads capital spending over multiple years.