Design-Build-Comply
Local Law 97 is a cornerstone of New York City’s plan to reach net-zero emissions by 2050, requiring owners of buildings over 25,000 square feet to stay below strict annual carbon caps based on their occupancy type. To comply, owners must submit a certified emissions report by May 1st each year—including the current 2026 cycle—detailing their energy usage and proving they have met their specific limits.
The financial risks of non-compliance are severe: buildings that exceed their carbon limit face an annual fine of $268 per metric ton of excess CO2, while failing to file a report triggers a monthly "Failure to File" penalty of $0.50 per square foot, which can quickly escalate into six-figure liabilities for larger properties
Phase 1: Diagnostic & Forensic Audit (The Consultant)
We begin with a deep-dive analysis of your building’s carbon footprint.
Emissions Penalty Projection: We calculate your exact financial exposure for 2024–2029 and the much steeper 2030 "carbon cliff."
The "Good Faith" Shield: If you are currently facing fines, we immediately file a Good Faith Effort (GFE) plan to pause penalties while we move into the planning phase.
Phase 2: Registered Design Engineering (The Engineer)
Compliance in NYC is a legal matter that requires licensed sign-offs.
Decarbonization Roadmap: Our NYC-licensed Professional Engineers (PEs) create a custom master plan that prioritizes high-ROI upgrades, such as nano-engineered thermal coatings and beneficial electrification.
Technical Report (TR-8) Filing: We prepare all engineering documents required for DOB NOW: BEAM, ensuring every watt of energy saved is legally accounted for.
Phase 3: High-Tech Execution (The Construction)
We manage the physical transformation of your asset with a focus on non-invasive technologies.
Envelope Retrofitting: Specialized application of nano-ceramic thermal barriers and vacuum insulation that increase R-value without losing rentable square footage.
Electrification & HVAC: Turnkey installation of air-source heat pumps and smart building controls.
Project Management: We act as the "Owner’s Representative," managing subcontractors and ensuring work meets the strict ASTM and UL standards required for NYC Building Code.
Phase 4: Verification & Rebate Recovery (Compliance & Finance)
We ensure the project pays for itself through aggressive incentive capture.
Federal & State Rebates: We secure Inflation Reduction Act (IRA) tax credits and NYSERDA subsidies that can cover up to 30–50% of project costs.
Utility Incentives: We navigate ConEd and National Grid "Clean Heat" programs to claw back every available dollar.
Final Certification: Once construction is complete, our RDPs perform the final verification, submitting the compliance reports to the DOB to permanently zero out your carbon penalties.
The Bottom Line for Developers
Instead of managing fragmented vendors, you get a guaranteed compliance outcome. We turn your mandatory LL97 "expense" into a capital improvement that increases your property's value, lowers operating costs, and eliminates city fines forever.
"We don't just tell you what's wrong; we build what's right and get the city to pay for part of it."
Good Faith Effort (GFE) is a legal "safety valve" that allows building owners who are over their carbon limits to mitigate or waive expensive penalties by proving they are actively working toward compliance.
As of April 2026, the GFE has shifted from a "planning" phase to a "verification" phase. Here is the brief on how it works and why it matters to your business.
1. The Core Purpose
The GFE pathway was created because the city prefers retrofits over revenue. Instead of just collecting a $268/ton fine, the Department of Buildings (DOB) will let an owner keep that money if they spend it on building improvements (like your nano-coatings or HVAC upgrades).
2. The 3 Prerequisites to Qualify
To even apply for a GFE mediated resolution, an owner must have:
Filed the Annual Report: You cannot claim "good faith" if you haven't filed your emissions report by May 1st.
Benchmarked (LL84): The building must have updated energy data in the Portfolio Manager.
Paid the Fee: There is a $950 filing fee for a GFE application.
3. The 2026 "Verification" Checkpoint
This is the most critical update for NYC developers. For buildings that filed a "Decarbonization Plan" in 2024 or 2025 to buy time:
Deadline:May 1, 2026.
The Requirement: The DOB is now checking to see if the work promised in those plans has actually started.
The Risk: If a building has made zero progress, the DOB can retroactively cancel their GFE status and charge them for the 2024 and 2025 fines they skipped.
4. Six Ways to Prove "Good Faith"
An owner can qualify for penalty mitigation if they meet one of these criteria:
Work is Underway: Show building permits and contracts for retrofits (e.g., a contract to apply nano-coatings).
Decarbonization Plan: Submit a professional roadmap to reach net-zero by 2050 (this must be signed by a PE or RA).
Financial Hardship: Prove the building is in arrears or under financial distress.
Electrification Credit: Show they have already begun switching from gas to high-efficiency electric systems.
Prior Compliance: Show the building was under its limit in a previous year.
Pending Adjustment: The owner has an active application for a unique building constraint.
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2. Hilton Times Square - 321 W 38th Street, New York, NY - 30 Stories Building
3. 16 East 30th Street, New York, NY - 19 Stories Building
4. 50 W 36th Street, New York, NY - 17 Stories Building
5. 3934 21st Street, Long Island City - 7 Stories Building
6. 38-71 13th Street, Long Island City - 17 Stories Building
7. 38-60 13th Street, Long Island City - 11 Stories Building
8. 30-03 40th Ave, Long Island City - 7 Stories Building
9. 38-04 11th St, Long Island City, NY - 17 Stories Building
10. 38-15 9th St, Long Island City, NY - 17 Stories Building
