by Stephen Hughes
As we enter 2025, New York’s building owners find themselves in the by now somewhat familiar position of watching the Department of Buildings navigate the rollout of another major energy law. Local Law 97, the city’s ambitious emissions reduction program, is now officially in effect – though what that means in practice remains a work in progress at 280 Broadway.
The pattern should be familiar to anyone who remembers 2011, when Local Law 84 introduced citywide energy benchmarking. That year showed us what happens when sweeping regulations meet bureaucratic reality, as the DOB released crucial updates through an impressive variety of channels that rarely seemed aware of each other’s existence. Building owners found themselves piecing together requirements like detectives, comparing notes at industry meetings to figure out what was actually expected of them.
Now we find ourselves at the dawn of Local Law 97 compliance, and the department appears committed to tradition. This October, buried within a general filing outline document the DOB revealed that buildings must submit floor plans and stacking diagrams to support their gross floor area measurement figures. This rather significant requirement appeared with all the fanfare of a subway service change update – technically announced, but you’d better be paying attention.
What does this mean for your building in 2025? First, we should accept that whatever plans are made based on last month’s guidance may need revision based on next month’s clarifications. The core requirements of LL97 are clear enough – reduce emissions or face penalties – but the path to compliance will likely include several unexpected turns. The DOB’s handling of LL97 isn’t so much a departure from standard practice as it is a continuation of a proud tradition of regulatory improvisation.
The saving grace is that New York’s professional community has adapted to this regulatory style over years of similar rollouts. Energy consultants, building managers, and industry groups have developed informal networks to share and verify new information as it surfaces, which has proven remarkably effective at catching crucial updates that might otherwise slip through the cracks.