Proposed NYC LL97 Rule Change
Summary of New Rules Proposed for NYC LL97
Based on our review of the new proposed rules, major takeaways are as follows:
- Carbon emission limits have been reduced significantly for the period 2030-2034.
- New rules suggest that the electric grid will emit much less CO2e in 2030-2034 than assumed under the current rules. This will add additional pressure for electrification.
- Efficiency improvements, waste heat recovery, and carbon capture technologies from existing building fossil fuel use should be reviewed as penalty reduction methods.
- More buildings - especially offices, universities, medical offices, and hotels - will likely be exposed to greater penalties in 2030-2034.
- Building Type emissions factors align better with Energy Star Portfolio Manager reporting types.
- Zero emissions allowed for 2050 and beyond.
- Renewable Energy Credits will only offset emissions from utility electricity delivery; no deductions are available for emissions from other fuel sources.
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Next Steps & What You Can Do
Attend the Urban Green hosted information session with NYC Department of Buildings: LL97: Unpacking the Proposed Rules | Urban Green Council
DOB will hold a public hearing on the proposed rule online. The public hearing will take place at 11am on 11/14/22
Anyone can comment on the proposed rules by:
- You can submit comments to the DOB through the NYC rules website at http://rules.cityofnewyork.us.
- You can email comments to email@example.com
- You can mail comments to the New York City Department of Buildings, Office of the General Counsel, 280 Broadway, 7th floor, New York, NY 10007.
- You can fax comments to the New York City Department of Buildings, Office of the General Counsel, at 212-566-3843.
Anyone who wants to comment on the proposed rule at the public hearing must sign up to speak. You can sign up by emailing firstname.lastname@example.org by 11/7/22 and including your name and affiliation.
While you will be given the opportunity during the hearing to indicate that you would like to provide comments, we prefer that you sign up in advance. You can speak for up to three minutes.
Download our complete guide to navigate the proposed LL97 changes
In late September, NYC Mayor Adams issued Executive Order 23 titled “Clean Construction”. The EO contains provisions that all City agency projects, new construction, renovations, and additions, must use low-carbon concrete (aligning with NYS requirements), provide Environmental Product Declarations for concrete and steel products, and utilize low-emission vehicles and equipment. Additionally, all projects that are subject to LL32 (green building certification) must prepare life-cycle-analysis (LCA) calculations which estimate the embodied carbon impacts of the project.
Operational and embodied carbon emission reductions are central to the proposed LL97 rule changes and the recent executive order from NYC and SOCOTEC is proud to be able to assist our Clients and municipal projects to meet these measures.