MANAGEMENT BASICS
DOB Gives Extra Time for Emissions and Lighting Reports
Even with the initial grace periods, many owners have found the reporting process challenging.
Three overlapping laws make up the climate compliance calendar for New York City apartment building owners:
Local Law 97, passed in 2019 as part of the city’s Climate Mobilization Act, sets greenhouse gas (GHG) emissions limits on most buildings over 25,000 square feet. However, applicable rent-regulated buildings with more than 35 percent rent-regulated units follow a different path. Rather than meet emissions caps, they’re required to complete a defined set of energy conservation measures.
Local Law 88, in effect since 2009, targets energy-efficient lighting and submetering. Owners of buildings over 25,000 square feet had to complete lighting upgrades in common areas in residential buildings and all interior spaces in non-residential or mixed-use properties. The compliance attestation, signed by a licensed professional, had to be filed to avoid penalty.
Last, Local Law 84, the city’s benchmarking law adopted in 2016, requires owners of buildings over 25,000 square feet to submit energy and water usage data through ENERGY STAR Portfolio Manager annually.
The Department of Buildings (DOB) originally gave owners until May 1, 2025, to file LL97 emissions reports, then added a 60-day grace period that moved the functional deadline to June 30. A similar June 30 due date applied to LL88 lighting and submetering attestations, while LL84 benchmarking remained fixed on May 1, or June 30 with a grace period, each year.
Even with the initial grace periods, many owners found the reporting process challenging. Gathering utility data, submitting DOB NOW payments, syncing accounts in ENERGY STAR, and navigating the newly launched BEAM portal was time-consuming. And while only about 8 percent of buildings are projected to exceed their 2024 emissions caps, Urban Green Council warns that more than half of all covered properties could fall short of the much stricter 2030 standards. These reasons have driven the city’s recent extension of key compliance deadlines.
Deadline Changes
The DOB’s June 16 Service Notice gives owners more breathing room, but only if owners request it. If a Local Law 97 extension request is filed through the BEAM portal any time up to Aug. 29, 2025, the emissions reporting deadline is pushed to Dec. 31, 2025.
If your building must file for both LL97 and LL88 this year, the LL88 attestation can also be submitted by that same date. However, if your property needs to submit only an LL88 report, that deadline remains June 30, 2025. Local Law 84 benchmarking filings are due June 30 unless the building receives a Local Law 97 extension, in which case the LL84 deadline shifts to Aug. 29.
It’s important to note that missing these deadlines can trigger significant penalties. LL97 violations carry late-filing fines of $0.50 per square foot per month and emissions fines of $268 per ton of CO2 above the building’s limit. LL88 violations result in a $1,500 fine for not submitting the required documentation and $500 per unmetered commercial tenant space.
Getting the Extension
To qualify for the extended deadline, building owners must submit a ticket through the BEAM portal no later than Aug. 29. Start by logging into DOB NOW to pay the $60 Local Law 97 extension fee. The system will generate a payment confirmation number, which is needed to access the extension request in BEAM. Because BEAM and DOB NOW sync overnight, expect a short delay before the extension form becomes available.
Once in BEAM, choose the LL97 Extension Request option, enter the building’s address, BBL, and BIN, and upload an attestation from a Registered Design Professional or Qualified Retro-Commissioning Agent if you have one. Once submitted, the filing deadline for LL97 (and LL88, if applicable) will automatically extend to Dec. 31, 2025. If you have any issues submitting LL97 reports before the deadline, the DOB encourages you to reach out to BEAM_LL97@buildings.nyc.gov, with your building’s 10-digit identifier (Borough-Block-Lot) and “Pre-Compliance Engagement” in the email subject line.
