With the first Local Law 97 (LL97) compliance deadline approaching, building owners now have extra time to submit their reports, thanks to a recent NYC Department of Buildings (DOB) Service Notice.
- A 60-day grace period extends the deadline from May 1 to June 30, 2025, with no penalties.
- Owners must apply for an extension by June 30, 2025. If approved, the deadline is extended to August 29, 2025.
- Extensions require confirmation that a Registered Design Professional (RDP) has been hired to complete the report.
While this extension gives owners some breathing room, it’s important not to wait until the last minute. The best way to avoid penalties is to start preparing now.
Final Compliance Checklist for LL97
1. Hire a Registered Design Professional (RDP) to Confirm Compliance and File the Report
A Registered Design Professional (RDP), such as a Professional Engineer (PE) or Registered Architect (RA), must review emissions data, verify Gross Floor Area (GFA), and certify the Building Emissions Report before submission. If you haven’t hired an RDP yet, now is the time.
An RDP will:
- Confirm Local Law 84 (LL84) Benchmarking data to make sure energy usage records are accurate.
- Verify the building’s Gross Floor Area (GFA), which determines emissions limits.
- Check emissions calculations to determine whether the building is compliant.
- Certify and submit the report through the DOB’s online portal.
Buildings that exceed emissions caps will face additional fines at $268 per metric ton of CO₂ over the limit, so catching any discrepancies now is critical.
2. Take Advantage of the Grace Period or File Before the Deadline
The original Local Law 97 filing deadline is May 1, 2025, but a 60-day grace period allows building owners to submit their reports without penalties until June 30, 2025. Those who apply for an extension by this date may receive additional time until August 29, 2025, but only if they have hired a Registered Design Professional (RDP) to complete the report. Since RDP availability may become limited as the deadline approaches, starting the process early is critical for staying compliant and obtaining an extension if needed.
3. Avoid Common Mistakes That Could Lead to Penalties
Many reporting errors can result in fines or compliance issues. Taking proactive steps now can help prevent last-minute problems.
- Relying on incorrect square footage records – LL97 requires a GFA measurement based on the outer walls, which an RDP must confirm. Department of Finance (DOF) tax records may not be accurate for compliance purposes.
- Mismatched energy usage data – LL97 compliance relies on LL84 Benchmarking data, which needs to be checked carefully before filing. Inconsistent reporting could lead to unnecessary fines.
- Waiting too long to hire an RDP – The closer it gets to the deadline, the harder it may be to find an available RDP. Hiring early makes the process smoother.
- Having the wrong person submit the report – Only a Registered Design Professional or, in limited cases a Retro-Commissioning Agent, can certify and file the report on behalf of the building owner.
Act Now to Avoid LL97 Penalties
The extension gives building owners more time, but waiting too long can still result in penalties and added stress. Hiring an RDP now makes it easier to stay compliant, avoid last-minute problems, and keep the option open to apply for an extension if needed.
For expert assistance with your LL97 compliance report or extension, contact us today at info@nullrandpc.com or 212-675-8844. Visit www.randpc.com/LL97 for more information.
Andrew Briguet, PE, is RAND's MEP & Energy Team Leader.
