In its pursuit of ambitious sustainability goals, New York City has committed to cutting greenhouse gas emissions by 80% by 2050, compared to 2005 levels. Laws are already in effect and come with hefty fines that property owners and managers must be aware of and take immediate action to avoid.

Local Law 88 (LL88)

Local Law 88 (LL88) mandates that buildings upgrade all of their lighting and lighting controls with equipment that adheres to the New York City Energy Conservation Code (NYCECC). This applies to covered buildings” exceeding 25,000 square feet, compelling them to install tenant sub-metering and to upgrade their lighting systems to meet specified energy efficiency standards. LL88 filing is expected to be a part of the Local Law 97 (LL97) filings, and buildings have until January 1, 2025, to comply. Fines imposed start at $1,500 every year until compliance is met.

Local Law 97 (LL97)

Local Law 97 (LL97)  set carbon emission caps in 2024 for buildings over 25,000 gross square feet (impacting approximately 30,000 buildings). Those that exceed these limits will face annual fines beginning in 2025, which are designed to be costlier than the needed energy improvements.

  • Failure to file a report = $0.50 per building square foot, per month
  • Exceeding your emissions limit = $268 for each metric ton over the building’s established limit
  • Providing false statements = $500,000

For example, a 300,000 sq./ft office building emitting 2,711 metric tons of carbon would be 437 metric tons over its 2024-2029 targets and must pay an annual fine of $117,116. In 2030, the annual fine becomes $375,146.

Covered buildings must comply with building emission limits on and after January 1st, 2024. By May 1st, 2025, and by May 1st of every year after that, the compliance reporting must be submitted through a new DOB portal and must be certified by a Professional Engineer or Registered Architect.

The Complexity and Risks of LL97 Reporting – Are You Prepared?

LL97 filing is much more involved than other energy code reporting, such as LL84. LL97 requires a multi-disciplinary approach and involves much greater risk and potential exposure with fines of $0.50 per square foot per month for failing to file and $500,000 for providing false statements.

LL97 reporting is expected to be done via a new portal being developed by the City and will include aspects of and Registered Design Professional attestations of the following:

  • LL97 Carbon Emissions Limits and Potential Fines
    • Detailed engineering calculations and verification of your building’s GHG emissions and possible fines in relation to established GHG limits.
  • LL88 Lighting and Tenant Submetering
    • Lighting audits, lighting power density calculations, and tenant submetering and monthly reporting must be completed and be attested to as a part of the LL97 filing.
  • LL84 Benchmarking Validation
    • Comprehensive analysis and validation of the building’s annual LL84 benchmarking inputs and results must be done to ensure the accuracy of the building’s reported emissions.
  • LL87 Energy Audits + RCx
    • Buildings must be in compliance with LL87 and have completed the required energy audits and retro-commissioning studies (RCx) by the property’s due date.


Time is of the essence!

Accomplishing the above requirements takes considerable time and effort and requires expertise in multiple disciplines (i.e. engineering, HVAC, electrical, etc.).

Evolution Sustainability Group brings the experience and multi-discipline ability to cost-effectively provide white-glove service to turnkey all aspects of LL97 for your organization.

Contact our team at or fill out our contact form to get started!