Meeting LL97 requirements is a milestone, not the finish line. Decarbonization is the key to long-term compliance, cost savings, and a more sustainable future.
As New York City pushes forward with its carbon reduction goals, building owners need to start planning now to meet Local Law 97 (LL97) requirements and reduce emissions. A decarbonization plan outlines a long-term strategy for transitioning away from fossil fuels, improving energy efficiency, and aligning with future emissions limits.
By implementing key upgrades, including electrification of heating and hot water, insulation improvements, and energy-efficient lighting, building owners can lower operating costs, increase asset value, and stay ahead of tightening regulations. Reducing carbon emissions and complying with LL97 requires a structured approach, including calculating emissions, evaluating compliance with LL97 limits, developing a retrofit master plan, and adopting energy conservation measures.
Roadmap for Decarbonization
1. Calculate Carbon Emissions
The first step in decarbonization is establishing a baseline emissions profile by calculating the building’s current greenhouse gas (GHG) emissions using Local Law 84 Benchmarking reports and utility records.
A Registered Design Professional (RDP), such as a Professional Engineer (PE) or Registered Architect (RA), is required to verify these calculations and certify Local Law 97 compliance reports. The RDP also plays a key role in:
- Confirming Gross Floor Area (GFA) accuracy, as LL97 emissions limits are based on GFA.
- Reviewing benchmarking data to catch errors that could affect compliance.
- Assessing emissions sources, including heating, cooling, domestic hot water, lighting, and plug loads, to identify the best reduction strategies.
Incorporating Local Law 87 Energy Audits
A Local Law 87 (LL87) energy audit provides a deeper analysis of building system performance and inefficiencies. These audits must comply with the American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE) Standards for a Level 2 energy audit. LL87 audits help decarbonization efforts by:
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Identifying mechanical and operational inefficiencies that increase energy use.
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Highlighting high-impact energy conservation measures (ECMs) that support electrification and emissions reduction goals.
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Pinpointing low-cost operational improvements that can reduce carbon emissions before major capital upgrades are undertaken.
Integrated Physical Needs Assessments (IPNAs) for Affordable Housing
For affordable housing properties, an Integrated Physical Needs Assessment (IPNA) helps owners evaluate capital needs alongside energy conservation opportunities. By combining emissions calculations with long-term capital planning, an IPNA allows owners to:
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Identify necessary repairs while incorporating energy efficiency upgrades.
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Access funding and incentives through programs like NYSERDA, Con Edison rebates, and sustainability grants.
2. Compare to Local Law 97 Emissions Limits
Once emissions are calculated, they must be compared to LL97 limits based on the building’s occupancy type and size. This step determines whether the building is already in compliance or requires emissions reductions to avoid penalties.
3. Develop a Retrofit Master Plan
A successful decarbonization strategy requires a phased approach, integrating energy conservation measures (ECMs) with building operations, capital improvement plans, and financing opportunities.
An RDP plays a key role in this phase, developing an integrated retrofit plan that prioritizes high-impact upgrades while maintaining building functionality. Because LL97 compliance is based on total carbon emissions, building owners should focus first on measures that achieve the greatest emissions reductions.
The highest-impact decarbonization pathways, in order of emissions reduction potential, include:
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Space Heating Electrification – Replacing fossil fuel-based heating systems with electric alternatives, such as Variable Refrigerant Flow (VRF) systems, Mini-Split/Multi-Split Air Source Heat Pumps (ASHP), and packaged terminal heat pumps (PTHP), has the biggest impact on emissions reduction.
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Domestic Hot Water Electrification – Gas-fired domestic hot water systems can be replaced with heat pump water heaters, point-of-use electric water heaters, or hybrid systems to further reduce carbon emissions.
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Building Envelope Insulation – Proper wall and roof insulation minimizes heat loss, reducing heating and cooling demand. Adding high-R-value insulation during roof replacements and installing reflective or cool roof coatings lowers energy demand and supports space heating electrification. If Facade Inspection Safety Program (FISP) facade repairs or capital projects like roof replacements are planned, integrating envelope upgrades at the same time improves efficiency without extra disruption.
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Common Area Lighting Upgrades – Replacing outdated lighting with LED fixtures, occupancy sensors, and smart lighting controls is a relatively low-cost way to reduce electricity consumption while improving efficiency.
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Solar Photovoltaic (PV) Arrays – On-site solar power generation can offset a building’s electricity consumption, though its impact on emissions is lower than direct electrification measures.
Incorporating Local Law 88 Lighting and Sub-Metering Upgrades
Local Law 88 (LL88) requires covered buildings to upgrade lighting systems and install sub-metering for tenant spaces. These improvements also support decarbonization by:
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Lowering electricity demand, which helps balance higher loads from electrification projects.
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Improving energy efficiency in common areas through LED retrofits, occupancy sensors, daylight sensors, and automated lighting controls.
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Providing better energy tracking through sub-metering, helping owners identify waste and optimize operations.
Since LL88 compliance is mandatory, integrating these upgrades into a decarbonization plan maximizes both energy and emissions reductions.
4. Implement Building Decarbonization Measures
With a phased approach, building owners can start making upgrades at a manageable pace, aligning projects with their budget, capital improvement plans, and available incentives.
Prioritizing high-impact upgrades, such as heating and hot water electrification, energy-efficient lighting, and system optimizations, can significantly reduce emissions while improving operational efficiency.
Financing & Incentives for LL97 Compliance
To offset upfront costs, building owners can work with an approved NYC Accelerator or NYSERDA Multifamily Building Solutions Network (MFBSN) provider to access grants, rebates, and financing for LL97-related upgrades.
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NYC Accelerator offers free technical assistance to help owners identify energy-saving measures and navigate incentive programs.
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NYSERDA’s MFBSN program provides grants, rebates, and financing for heat pumps, insulation, high-efficiency lighting, and other upgrades.
Taking advantage of these funding opportunities makes compliance more financially viable while reducing long-term energy costs.
Tracking Progress & Maintaining Compliance
Building owners should implement ongoing performance tracking to confirm that emissions reductions stay on target and LL97 compliance is met.
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Advanced metering and building management systems (BMS) provide real-time data on energy use, helping owners verify compliance and optimize building operations.
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Regular monitoring identifies inefficiencies, allowing for adjustments that improve energy savings and control costs over time.
Investing in continuous tracking and system improvements helps buildings stay compliant and operate more efficiently in the long run.
Contact RAND
A well-planned decarbonization roadmap not only helps building owners comply with LL97 and reduce operating costs but also keeps their properties efficient, resilient, and financially sustainable in the years ahead.
Contact us today to get started on your decarbonization strategy: 212-675-8844 or info@randpc.com.
