What are the Local Law 97 2030 limits?
Local Law 97 gives every covered building an annual emissions limit for each compliance period, and 2030–2034 is the second one. For those years the limit is the building's gross floor area multiplied by the emissions factor for its ENERGY STAR Portfolio Manager (ESPM) property type in the 2030–2034 table of DOB's rule (1 RCNY §103-14(c)(3)(iii); 1 RCNY §103-14(d)(2)(i)–(ii)). A mixed-use building adds up factor × floor area for each property type it contains (1 RCNY §103-14(d)(2)(i)–(ii)).
The buildings covered do not change: one that exceeds 25,000 gross square feet, or two or more on the same tax lot that together exceed 50,000 gross square feet (NYC Admin Code §28-320.1 (LL97 of 2019)). The covered-buildings guide walks through the exceptions and deferrals.
What changes is the number. DOB's own statement of basis for the rule says that many buildings estimated to comply with the 2024–2029 limits will fall out of compliance with the more stringent limits in 2030 (1 RCNY §103-14 Statement of Basis and Purpose (eff. 1/20/2024)), and the rule already carries the trajectory to a factor of 0.00 for every property type from calendar year 2050 (1 RCNY §103-14(c)(3)(iv)–(vi)). LL97 is one of several laws that touch the same building; the other NYC energy laws are covered separately.
LL97 limits by property type: 2024–2029 vs 2030–2034
The table pairs the rule's 2024–2029 factors with its 2030–2034 factors for common ESPM property types, in metric tons of CO2e per square foot of gross floor area per year (1 RCNY §103-14(c)(3)(i); 1 RCNY §103-14(c)(3)(iii)). The percentage reductions are our arithmetic from those two tables (1 RCNY §103-14(c)(3)(i), (c)(3)(iii) — arithmetic by ecosum).
| Office | 0.00758 → 0.002690852 (−64.5%) |
|---|---|
| Multifamily Housing | 0.00675 → 0.003346640 (−50.4%) |
| Hotel | 0.00987 → 0.003850668 (−61.0%) |
| Retail Store | 0.00758 → 0.002104490 (−72.2%) |
| K-12 School | 0.00675 → 0.002230588 (−67.0%) |
| Financial Office | 0.00846 → 0.003697004 (−56.3%) |
| Medical Office | 0.01074 → 0.002912778 (−72.9%) |
| Non-Refrigerated Warehouse | 0.00426 → 0.000883187 (−79.3%) |
The cuts are not uniform. Multifamily Housing keeps roughly half of its current allowance; Retail Store and Medical Office keep a little over a quarter; a Non-Refrigerated Warehouse keeps about a fifth. And the rule does not stop at 2034: it already sets Office at 0.001652340 and Multifamily Housing at 0.002692183 for 2035–2039, Office at 0.000581893 and Multifamily Housing at 0.002052731 for 2040–2049, and 0.00 for every property type from 2050 (1 RCNY §103-14(c)(3)(iv)–(vi)). A retrofit sized only to clear 2030 buys one five-year period.
Where the 2030 limits come from: §28-320.3.2 vs 1 RCNY §103-14
The statute itself contains a 2030–2034 table written in Building Code occupancy groups: group B (office) 0.00453, group M (retail) 0.00403, group R-1 (hotel) 0.00526 and group R-2 (residential) 0.00407 tCO2e per square foot (NYC Admin Code §28-320.3.2, items 2, 7, 8, 9 (LL97 of 2019)), with group A at 0.00420, E and I-4 at 0.00344, I-1 at 0.00598, F at 0.00167, S and U at 0.00110, and the hospital, laboratory and emergency-response categories at 0.01193 (NYC Admin Code §28-320.3.2, items 1, 3–6, 10 (LL97 of 2019)). Those figures are read from the enacted Local Law 97 of 2019 text that DOB publishes, not from the consolidated code.
The same section lets DOB “establish different limits, set forth in the rules of the department,” where it determines they are feasible and in the public interest (NYC Admin Code §28-320.3.2 (LL97 of 2019)). DOB used that authority: 1 RCNY §103-14 took effect January 19, 2023 and set property-type factors for 2024–2029, 2030–2034, 2035–2039 and 2040–2049 in one rule (1 RCNY §103-14 Promulgation Details (eff. 1/19/2023)).
The transition ran in two steps. For the CY2024 and CY2025 reports only, an owner could elect the statutory occupancy-group limit (§28-320.3.1, e.g. Group B 0.00846) where it exceeded the ESPM property-type factor (e.g. Office 0.00758), without mixing methods in one report; from the CY2026 report onward the ESPM factors in 1 RCNY §103-14(c)(3) govern (1 RCNY §103-14(c)(3)(ii); DOB Service Notice 2/7/2023). DOB states that limits for years beyond 2029 were established by 1 RCNY §103-14 using ESPM property types (DOB Service Notice 2/7/2023; DOB 'Buildings Emissions Limits Under LL97' page). For 2030, then, the statutory occupancy-group table is background; the rule's ESPM table is the operative limit.
LL97 emissions coefficients for electricity, gas and steam in 2030
Reported emissions are energy use multiplied by a greenhouse-gas coefficient for each fuel, and those coefficients also move in 2030. The 2024–2029 values are in the statute (NYC Admin Code §28-320.3.1.1 (LL97 of 2019)); the 2030–2034 values are set by rule (1 RCNY §103-14(d)(3)(ii); 1 RCNY §103-14(d)(3)(i)(b)).
| Grid electricity | 0.000288962 → 0.000145 tCO2e per kWh; an owner may instead elect a time-of-use coefficient (1 RCNY §103-14(d)(3)(ii), (d)(3)(iii)) |
|---|---|
| Natural gas | 0.00005311 tCO2e per kBtu — unchanged (1 RCNY §103-14(d)(3)(ii)(b) (2030–2034 value); NYC Admin Code §28-320.3.1.1 item 2 (2024–2029 value)) |
| District steam | 0.00004493 → 0.0000432 tCO2e per kBtu (1 RCNY §103-14(d)(3)(ii)(c) (2030–2034 value); NYC Admin Code §28-320.3.1.1 item 5 (2024–2029 value)) |
| #2 fuel oil | 0.00007421 tCO2e per kBtu — unchanged (1 RCNY §103-14(d)(3)(i)(b)) |
| #4 fuel oil | 0.00007529 tCO2e per kBtu — unchanged (1 RCNY §103-14(d)(3)(i)(b)) |
DOB's summary of the trajectory continues past 2034: grid electricity 0.0000866886 for 2035–2039 and 0 for 2040–2050, and district steam 0.000032 then 0.000025 tCO2e per kBtu, with gas and fuel oil unchanged (DOB 'Calculating Building Emissions & Emission Limits' deck, 6/26/2024, slide 29).
The electricity coefficient falls 49.8% between the two periods while the Office factor falls 64.5%: an all-electric office's reported emissions roughly halve on their own in 2030, but its limit falls by almost two-thirds, so a building sitting exactly at its limit today is still over it (1 RCNY §103-14(c)(3)(i), (c)(3)(iii), (d)(3)(ii) — arithmetic by ecosum). A gas-heated building gets none of that automatic help, because the gas coefficient does not move.
Worked example: a 100,000 sq ft office under the 2030 limits
Take a single-use ESPM Office of 100,000 gross square feet whose reported emissions sit exactly at its 2024–2029 limit and do not change. Every input is from the rule; the arithmetic is ours, and the result is an estimate of the maximum civil penalty, not an assessment (1 RCNY §103-14(c)(3)(i), (c)(3)(iii), (d)(2)(i), (h) — arithmetic by ecosum).
| 1. 2024–2029 limit | 100,000 sq ft × 0.00758 = 758.0 tCO2e (1 RCNY §103-14(c)(3)(i); (d)(2)(i)) |
|---|---|
| 2. 2030–2034 limit | 100,000 sq ft × 0.002690852 = 269.0852 tCO2e (1 RCNY §103-14(c)(3)(iii); (d)(2)(i)) |
| 3. Excess in 2030 | 758.0 − 269.0852 = 488.9148 tCO2e over the limit |
| 4. Estimated penalty | 488.9148 × $268 = $131,029.17 per year — the statutory maximum, before any mitigation (NYC Admin Code §28-320.6; 1 RCNY §103-14(h)) |
| If Group B was elected | An owner who used the 0.00846 Group B intensity for CY2024–2025 had an 846.0 t limit; flat at 846.0 t, the 2030 excess is 576.9148 t × $268 = about $154,613.17 per year (1 RCNY §103-14(c)(3)(ii) — arithmetic by ecosum) |
| Multifamily comparison | A 100,000 sq ft Multifamily Housing building goes from a 675.0 t limit to 334.664 t; flat at 675.0 t, the excess is 340.336 t × $268 = about $91,210.05 per year (1 RCNY §103-14(c)(3)(i), (c)(3)(iii) — arithmetic by ecosum) |
For scale, DOB's own enforcement illustration for a 2024 report shows 1,371.53 tCO2e reported against a 1,148.68 t limit — 222.85 t over, for a $59,723.80 penalty (DOB 'Enforcement of Article 320' deck, Feb. 2026, slide 33). The office above would owe more than double that, from a building that is fully compliant today. The calculator runs the same arithmetic for a specific address, and the penalties guide shows the mechanics step by step.
When do the 2030 limits take effect, and when is the first report due?
The rule's 2030–2034 factors apply “for the purposes of reporting for calendar years 2030 – 2034” (1 RCNY §103-14(c)(3)(iii)). Reports are due May 1 each year, certified by a registered design professional, cover the previous calendar year, and state either compliance or the amount by which the limit was exceeded (NYC Admin Code §28-320.3.7 (LL97 of 2019); 1 RCNY §103-14(b)).
Put together, the first report judged against the 2030 limits — covering calendar year 2030 — would be due May 1, 2031, and an owner would not be liable for the failure-to-file penalty if a report demonstrating compliance is filed within 60 days of that due date — June 30, 2031 (NYC Admin Code §28-320.3.7 and §28-320.6.2 (LL97 of 2019)). That date is an inference from the filing cycle; no DOB publication reviewed for this page states it. The practical point is that calendar year 2030 itself is the measured year: the energy a building uses in 2030 is what its first 2030-period report will reflect, so equipment and fuel decisions need to be in place before January 2030, not before May 2031.
The filing side does not soften. Failing to file carries a separate penalty of up to $0.50 per gross square foot for each month the violation is not corrected within the 12 months following the deadline, with no penalty if a compliant report is filed within 60 days (NYC Admin Code §28-320.6.2 (LL97 of 2019); 1 RCNY §103-14(g)(1)). As of DOB's April 22, 2026 release, about 93% of covered privately owned properties, representing 91% of covered buildings, had filed their CY2024 reports (DOB press release 4/22/2026) — the filing habit is largely formed; the 2030 problem is the number inside the report. The deadlines guide covers the annual cycle and extensions.
What can reduce a 2030 penalty, and what is not yet defined
For the 2024–2029 period the rule provides three routes to a smaller penalty: a mitigated penalty where the owner documents good faith efforts, a zero penalty where the excess was caused by an unforeseeable event, and a mediated resolution with DOB in which the penalty is waived in whole or in part, contingent on the owner meeting the agreement (1 RCNY §103-14(i); 1 RCNY §103-14(j)(3); DOB 'Enforcement of Article 320' deck, Feb. 2026). The good faith efforts guide covers what qualifies under 1 RCNY §103-14(i)(2).
None of that is yet written for 2030. DOB's statement of basis says the rule's good faith efforts definition applies to 2024–2029 and that “future rulemaking will lay out a definition of ‘good faith efforts’ for subsequent periods” (1 RCNY §103-14 Statement of Basis and Purpose (eff. 1/20/2024)), and the mitigation routes DOB describes are the 2024–2029 ones (1 RCNY §103-14(i); DOB 'Enforcement of Article 320' deck, Feb. 2026). The rule does not yet say what good faith efforts will mean for 2030–2034, so an owner counting on that relief in 2031 is counting on a rule that does not exist. Offsets are on firmer ground: the statute wrote the purchased-offset deduction for calendar years 2024 through 2029 but lets DOB extend date-limited deductions to future compliance periods by rule (NYC Admin Code §28-320.3.6.2; §28-320.3.6 (as amended by LL77/2023 §35)), and DOB's rule, as amended effective January 19, 2025, provides the Affordable Housing Reinvestment Fund offset deduction “for each compliance period” — the adoption notice says the change was made to “clarify that deductions for offsets are available in each compliance period” — still capped at 10% of the limit (1 RCNY §103-14(e)(3), (e)(3)(vii); DOB Statement of Basis and Purpose, 1 RCNY §103-14 amendment eff. 1/19/2025), so under the current rule AHRF offsets remain available for 2030–2034; the REC deduction (§28-320.6.1 in the enacted text of LL97 of 2019; 1 RCNY §103-14(e)(1)) has no year limit but remains capped at emissions from utility-supplied electricity. The RECs and offsets guide sets out what the rule says today.
The lever that does not depend on future rulemaking is the one in the formula: reported emissions minus the limit, times $268 (NYC Admin Code §28-320.6; 1 RCNY §103-14(h)). Closing that gap before calendar year 2030 begins is the plan that survives whatever the next rule says.