In 2025, carbon emissions reporting went well. But 2030? “It’s going to be a real scramble”

2025 was a big year for big build­ings in New York City. 

That’s because it was the first time that they had to report their carbon emis­sions to the city, as per Local Law 97 (LL97), the land­mark climate legis­la­tion that requires build­ings over 25,000 square feet to keep their emis­sions under grad­u­ated limits. Last year, roughly 50,000 such build­ings across the city had to measure their emis­sions and file reports with the city docu­menting whether they were in compli­ance — and about 900 of those build­ings’ filings were over­seen by Mariel Hoffman, the Director of Energy Engineering at EN-POWER GROUP. In this role, she serves as a Registered Design Professional (RDP), a state-licensed authority who works with building owners to prepare and certify their LL97 filings, reporting their emis­sions to the city. 

In many ways, according to Hoffman, 2025 was about estab­lishing a base­line and helping building owners learn the system, which has no real prece­dent in New York’s building industry. Early results were encour­aging: The vast majority of build­ings reported emis­sions within the city’s initial limits, and only a small percentage faced penal­ties. But Hoffman warns that the real chal­lenge is still ahead. In 2030, emis­sions caps will tighten sharply — and without signif­i­cant changes, she said, many of the build­ings she works with will get slammed with consid­er­able fines.

The reporting system that made this first year possible may be compli­cated and tech­nical, but it’s central to the city’s climate strategy. Without accu­rate data on how build­ings use energy, the law’s emis­sions limits can’t be enforced — or improved.

Skylight sat down with Hoffman at her office to talk about what the first year of LL97 compli­ance looked like, and what to expect down the line. 

This inter­view has been edited and condensed for clarity. 

You submitted over nine hundred LL97 filings. What percentage of the build­ings you filed for were compliant for 2025?

Well, it depends what you mean by compliant. There were some build­ings that had penal­ties [based on their total calcu­lated emis­sions], obvi­ously, as was the goal [of the city]. But there were often [compli­ance] path­ways for those build­ings. It doesn’t mean that just because it was calcu­lated a certain way, they have to pay [those penal­ties]. There are carve-outs that the Department of Buildings set in place from the begin­ning for adjust­ments, what they call ​“good faith” efforts, and options for medi­ated resolution. 

Our number was really around three percent that had calcu­lated penal­ties — and that number prob­ably came down to one percent, after different adjust­ments and pathways.

What did you learn overall from this process? What trends did you see in submis­sions for 2025?

Owners who started earlier had smoother filings, though, as you can imagine, last minute was the majority, because dead­lines got extended. But for those who engaged early, it was smoother, it was easier, they were more prepared.

Was there a scramble of people at the end of the year asking, ​“Can I possibly file LL97 with EN-POWER right now?”

I was doing [appli­ca­tion] proposals in mid-December! I don’t really think that we turned much away, to be honest. 

May 1st was the initial dead­line. There was always an exten­sion built into the law that would take it through August 29th, and a grace period through June 30th. So there was a push to get some files done without an exten­sion, and then there was also a push to get the exten­sions in by August 29th. 

Some manage­ment compa­nies were big advo­cates early on and helped commu­ni­cate to their build­ings early. So that made up for those that couldn’t, or tried and build­ings were resis­tant until some of the reality hit as time went on.

It was doable because of the DOB’s flex­i­bility. They pushed the filing dead­lines, they pushed the exten­sion dead­line; they were being really under­standing, and wanted to maxi­mize submis­sions by the 31st, even if some­thing had to be adjusted after. They just wanted people engaged with RDPs. If it weren’t for that senti­ment, we would not have been able to do that.

Let’s get into some of the details of how you submitted filings. Talk to me about your expe­ri­ence of the Building Energy Analysis Manager, or BEAM, the digital plat­form where building owners and their Registered Design Professionals (RDPs) submit LL97 filings.

It was a journey throughout the year. BEAM existed before for other purposes, but in terms of New York City compli­ance for various laws, this was the first appli­ca­tion of BEAM. 

There are three main plat­forms [we had to juggle]: Energy Star Portfolio Manager (ESPM), DOB Now, and BEAM. We saw some tech­nical diffi­cul­ties of connec­tivity of the different plat­forms, and popu­lating issues. 

To give access in BEAM, the DOB Now plat­form is where payments are made. Even if a building is fee-exempt, you would still have to go onto DOB Now and popu­late the building infor­ma­tion. If there’s a fee, you pay the fee, you put in the owner infor­ma­tion, and you put the owner repre­sen­ta­tive’s infor­ma­tion there. In most cases, we were doing that on the client’s behalf. 

In BEAM, the energy data would come from Energy Star Portfolio Manager. That’s where LL84 [reporting] is typi­cally done — the energy data that then gets pushed into BEAM should come from the LL84 profile. (Editor’s note: LL84 refers to the 2009 bench­marking law that requires build­ings to annu­ally assess and report energy and water consump­tion in their buildings.)

There are different defi­n­i­tions of space use types and how to report for LL84 than there are for LL97, so once that energy data popu­lates in BEAM, you can make adjust­ments; if there’s some­thing that didn’t popu­late correctly, you can change it on the filing ticket.

The other require­ment for successful filing is having a Registered Design Professional (RDP) in the first place. RDPs have specific tech­nical skills, and can be archi­tects, engi­neers, etc.; EN-POWER is an RDP. Let’s talk about this new busi­ness; what makes for a trust­worthy RDP?

I want a building in the best hands because I want them to have an accu­rate, long-term rela­tion­ship. So, I would say [build­ings need to make] sure to engage with energy engi­neers like ourselves, who have a real under­standing of building energy, building carbon emis­sions, and solutions.

There are a lot of providers out there that pop up for compli­ance purposes, but they’re not going to equip build­ings with plans or solu­tions, and I just think that’s a disser­vice. It’s not just about compli­ance filing, and you’re done. This really is a set of long-term goals that we’re all working towards for carbon emissions. 

So, don’t always go with the quickest and cheapest; go with RDPs that have expe­ri­ence in this space. I think that puts a building at a real advan­tage, having a partner that they can have that long-term rela­tion­ship with, [instead of] hopping around from year to year with different providers. 

Talk to me about differ­ences in compli­ance and penal­ties between building types. I’m curious about distinc­tions between co-ops, condos, rentals, pre-war, post-war, large port­folio, single asset, things like that.

There’s not a huge differ­ence in co-ops versus condos. The rentals that were different are the ones that ended up being rent-regu­lated or income-restricted, so they weren’t part of this first batch of filings; they’re deferred.

We also did a lot of Article 321, which covers build­ings [with] more than thirty-five percent regu­lated [units]. That’s a one-time filing in the first year. That was a whole animal unto itself. It’s good that there was an alter­na­tive pathway for these build­ings, because they just don’t have the resources to do much. A lot of the rentals that might have really strug­gled for compli­ance fell into that bucket.

Some clear differ­ences that stood out to me were build­ings on the smaller building side. LL87 [applies to] build­ings over 50,000 square feet. But LL97 applies to build­ings over 25,000. So there’s a lot of build­ings in that 25 – 50,000 [range] that haven’t had the same infor­ma­tion at their finger­tips, or haven’t had to comply with some­thing in this space; they might still be on [fuel] oil, more than a larger building. So that was defi­nitely a driver for the penalties. 

How many build­ings took on more inten­sive retro­fits versus low-hanging fruit improve­ments for efficiency?

I would say in 2025, that number is prob­ably very small, because I think build­ings were just navi­gating the reality of the law. I antic­i­pate that that’s going to change a lot in 2026. They’re going to have to do the work and start engaging now in order to make any impact towards 2030.

But there was defi­nitely a group of build­ings where we’ve been plan­ning ahead for several years that started doing analyses and assess­ments several years ago, trying to best posi­tion themselves.

In terms of low-hanging fruit, some of that is often achieved with LL87 compli­ance, because of the retro-commis­sioning require­ments. And LL88, the lighting and subme­tering law — for early compli­ance folks, there’s lighting upgrades that you have to make. (Editor’s note: Local Law 87 and Local Law 88 both set require­ments for certain build­ings to eval­uate and improve energy use. The former requires manda­tory energy audits and effi­ciency tune-ups for large build­ings to be completed every ten years, and the latter focuses on lighting improve­ments and submetering.) 

Did you see any addi­tional actions that people were opting into, without legis­la­tion forcing their hand to do so?

I mean, a lot of the projects that are going to save carbon are also going to save energy and save money. So, in some cases, espe­cially on the lower-hanging fruit end, a lot of that work is going to help towards carbon emis­sions anyway, and a lot of build­ings were thinking about it all tied together — the energy, the dollars, and then the carbon.

We have seen, and we’ve been trying to push, that when you are doing some façade work, maybe a window replace­ment, [you should be] taking it to a level further and doing more aggres­sive air sealing and insu­la­tion. That’s defi­nitely a piece of the puzzle that is not mandated. I think we’re going to see more of that, because that’s going to be the limiting factor. The enve­lope of the building, they’re going to have to spend more time in that space.

If I’m in a building that has a C or a D rating, and maybe we were compliant in 2025, but prob­ably we won’t be in 2030, are there first steps that you would recom­mend build­ings of that type should think about and start looking at?

You kind of unin­ten­tion­ally brought up a good point there — that the letter grade does not always corre­spond to penal­ties. [The letter grade is about] energy use, versus [penal­ties corre­lating to] carbon emis­sions. That’s one piece of the equa­tion that makes it a little bit complicated. 

But I think what build­ings should be doing is be engaging with energy engi­neers now, having studies done now, if they can, or refer­ring back and refreshing old LL87 reports, then assessing projects, from low-hanging fruit to huge capital invest­ments, and creating a capital plan for the near future and the long-term future, in order to best equip them to get there. 

Based on what you saw in year one, what did poli­cy­makers underestimate?

The intri­ca­cies of the process. It’s a law, it’s a policy; all those steps are obvi­ously not thought out [at the writing stage]. It’s not meant to be.

But I think some of the things that they under­es­ti­mated were just adop­tion and under­standing. It’s just so compli­cated, and there’s been nothing like it. It’s so novel! Yes, it’s a nice piggy­back on top of LL84 and other regu­la­tions, but the reality of penal­ties for exceeding [limits] is so different from anything we’ve seen before.

I think they really tried to do a lot of commu­ni­ca­tion and outreach, and they did a good job, but there was some push­back from building owners of, ​“Is this actu­ally going to happen?” Some early adopters before last year planned ahead, but I think there were many people that were waiting to see what would happen.

In terms of logis­tics, I think the compli­ca­tions of connecting three plat­forms that had not been used for anything like this before was a big piece of it. 

Was there anything that you were surprised by in the process?

This is not some­thing that I usually get to say, but the flex­i­bility and collab­o­ra­tion of the DOB was a very pleasant surprise. They were very collab­o­ra­tive and looking for feed­back and input from a lot of the providers. I mean, we were speaking to the DOB on December 31st, and they were helping us with indi­vidual filings. If it weren’t for that, the first year of compli­ance would not have gone the way it did.

Let’s talk about the future. Do you know what 2030 will look like, if the build­ings don’t take action? How many build­ings will be out of compliance?

Those numbers are way different — from a quick look at our inven­tory from BEAM, it’s more than fifty percent, with a lot of penalties. 

We haven’t dived into this yet, because the differ­ence between past years and now is that now we have accu­rate [area] measure­ments for a lot more build­ings, which changes things. So, our port­folio was more than fifty percent, and for the ones that don’t have penal­ties — I don’t know why they don’t have penal­ties, but they prob­ably should. [The penal­ties] might be small, [but] prob­ably a good chunk have high penal­ties. It’s going to be a real scramble.

In your opinion, are the penal­ties strong enough to inspire further action? 

I think the penal­ties seem high enough and appro­priate enough, because I think it is going to touch a lot of build­ings. In that regard, it’s doing what it’s meant to do.

Will the build­ings get out there and do the work? I don’t know, but I’m really opti­mistic, because this has been on the table for a while. We just got past our first year, which I’m hoping will be a reality check and will open the eyes of people that were maybe a bit resis­tant before.

There’s just enough time. We’re cutting it kind of close, but there are options for plans to compli­ance; there’s different paths to get there, but I do think that, gener­ally speaking, there’s going to be a shift this year. And we’re preparing for it.