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Construction & real estate due diligenceNational Reach. Local Insight.

NYC emissions compliance

Local Law 97 Planning & Compliance

Building-specific emissions analysis, compliance planning, measure evaluation, documentation, and capital-roadmap support for New York City owners.

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In plain terms

Determine the building’s emissions limit and the work needed to meet it.

Local Law 97 regulates greenhouse gas emissions from covered NYC buildings. A sound assessment starts with the building’s compliance pathway, property uses, and complete energy record—not a penalty estimate based only on floor area.

Scope, requirements & reporting

Requirements and reporting details.

Coverage includes some groups of smaller buildings

Coverage generally includes individual buildings over 25,000 gross square feet, multiple buildings on one tax lot totaling over 50,000 square feet, and qualifying condominium groups over 50,000 square feet. Article 320 and Article 321 have different requirements; certain affordable housing and other special circumstances affect the pathway. Confirm each building’s status and supporting records.

Compare the current period with 2030

Limits began in 2024 and become stricter in 2030. Article 320 generally requires an annual report certified by a registered design professional. A building within its current limit may still need capital work for a later period. KOW can coordinate the baseline, reduction options, and implementation schedule within the agreed scope.

Understand what the penalty calculation does—and does not—show

DOB states the annual excess-emissions penalty calculation as emissions above the limit multiplied by $268 per metric ton. That calculation alone is not a complete assessment: filing obligations, applicable adjustments, deductions, and penalty-mitigation provisions need separate review. Proposed reductions should be supported by documented assumptions and realistic project timing.

What the work should document

The analysis should show the property boundary, uses and floor areas, utility inputs, applicable coefficients, emissions limit, calculated emissions, and supported adjustments. A reduction plan should compare the current compliance period with later periods and identify the equipment, design, electrical service, financing, and phasing needed for proposed measures. Keep a preliminary exposure estimate separate from the certified filing.

Office project representative of KOW experience
KOW in the fieldData · Exposure · Reduction measures · Capital roadmap

Decisions supported

Questions the report addresses.

  1. 01

    What is the building’s current compliance position?

  2. 02

    Which data, corrections, or documentation issues must be addressed?

  3. 03

    What operational or capital measures merit development?

  4. 04

    How should the owner sequence actions around compliance periods and planned work?

Typical scope

What KOW reviews and documents.

The final scope follows the property, transaction, program, client requirements, and information available. Typical elements include:

Applicability and building-data review
Emissions-performance assessment
Documentation and filing roadmap
Reduction-opportunity screening
Capital-plan coordination
Compliance-action tracking

Process

How the assignment is carried out.

01

Set the assignment

Confirm the property or project, intended use, reliance parties, schedule, available information, and required deliverable.

02

Read the record

Review the documents, identify gaps, and coordinate the people and access needed to complete the scope.

03

Do the field and technical work

Perform the observations, analysis, interviews, and specialist coordination called for by the assignment.

04

Report what matters

Separate material findings from background information and state the basis, limitations, open items, and follow-up clearly.

Common assignments

Typical assignments.

Current-period compliance

Organization of building data, documentation, and required professional work.

Capital roadmap

Prioritization of potential emissions-reduction measures alongside planned system work.

Portfolio triage

A consistent framework for identifying higher-risk properties and next actions.

Frequently asked

Frequently asked questions.

Is every affordable building exempt?

No. Affordability and regulatory arrangements can change the applicable pathway or timing. Review the actual agreements and DOB criteria; do not infer exemption from the presence of affordable units.

If the building meets today’s limit, is the work finished?

Not necessarily. Future limits, equipment replacement, and changing building use may require planning well ahead of the next period. Annual reporting obligations can remain even when there are no excess emissions.

Can we calculate compliance using energy cost?

No. Utility dollars are not emissions. Use the applicable energy quantities, coefficients, property uses, and calculation rules. A cost-saving change can have a different emissions effect.

Will purchasing renewable energy automatically resolve a shortfall?

No. Eligibility, applicable emissions, documentation, and current DOB rules constrain deductions and alternatives. Review the specific instrument and building pathway before including it in a compliance strategy.

Who certifies the report?

The applicable pathway establishes the professional requirements. Article 320 reporting generally involves a registered design professional. Confirm the responsible professional and filing scope before engagement.

What should a Local Law 97 plan include?

A useful plan connects building and utility data, the applicable emissions framework, near-term compliance exposure, realistic reduction measures, implementation timing, and planned capital work.

Why is building-specific analysis important?

Two buildings of similar size can have very different systems, uses, operations, utility profiles, constraints, and capital plans. Those differences affect which measures are practical.

Start a conversation

Talk to us about local law 97.

Tell us what you’re working on. Our team will help define the right scope and get a proposal moving.

Request a proposal