Local Law 97 (LL97) Covered Buildings List (CBL) FAQs

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My building should not be subject to LL97 - how do I remove it from the CBL?

  1. If you believe your building is erroneously listed on the LL97 CBL due to the square footage of your building, contact the NYC Department of Finance at sustainablebuildings@finance.nyc.gov. Please include the following in the email:
    • borough, block, and lot number of the building
    • contact information: name, email address and/or telephone number
    • explanation of your dispute and RDP certification if applicable
  2. If you believe your building is a “garden style apartment” as described in exception #2 of the definition “covered building” in § 28-320.1 of the NYC Administrative Code or exception #1 of the definition of “covered building” in § 28-321.1 of the NYC Administrative Code, email ghgemissions@buildings.nyc.gov with subject line: CBL Dispute. Please include the following in the email:

    • BBL and BIN for such building
    • contact information: name, email address and/or telephone number
    • Documentation signed and stamped by a registered design professional (RDP) including all of the following information:
      • Documentation demonstrating the covered building is three stories or less.
      • NYC Department of Finance (DOF) tax records classifying the covered building as residential Property Type.
      • Proof of the occupancy group on the Certificate of Occupancy (CO).
      • Provide a statement that no central HVAC or hot-water systems in the covered building serve more than 25,000 (2322.5 m2) gross square feet.
      • Provide a date stamped picture of the building, within the past year, with a geo-tag.
      • A single letter may cover multiple lots, blocks, or BBLs, as long as they are contiguous and under the same ownership in DOF records.

Why is my building’s BBL listed on multiple LL97 CBLs?

A BBL may be listed on multiple CBLs because:

  1. There are multiple buildings on the BBL.
    LL97 requires compliance at the level of an individual building (as designated by a Building Information Number, or BIN), even though the identifying information in the CBLs are tax lots (as designated by a Borough-Block-and-Lot number, or BBL).  If there are multiple buildings on a BBL, such buildings may be subject to different compliance paths. Each building must demonstrate compliance with the compliance path that is appropriate for that building, regardless of the appropriate compliance path for other buildings on the same lot.
  2. A building qualifies for multiple compliance paths.
    If one building qualifies for multiple compliance paths, such building is required to demonstrate compliance with the highest tiered compliance path, as identified by the CBL Matrix. The tiers are listed below from lowest to highest:
    • All Article 320 properties “CP0”
    • 2026 Rent Regulated “CP1”
    • 2035 Income Restricted “CP2”
    • Article 321 “CP3”
    • City Buildings/NYCHA “CP4”

For example, if a building is classified as BOTH CP0 and CP2, the higher tier is CP2 and the building should demonstrate compliance with CP2.

Where there is uncertainty regarding a building’s compliance pathway due to the affordability status of the dwelling units in such building, consult the CBL Matrix.

How do I dispute my building’s compliance pathway, as listed on one or more of the LL97 CBLs?

  1. If you believe your building is erroneously listed on one or more of the LL97 CBLs due to a characteristic of the building other than the square footage, email ghgemissions@buildings.nyc.gov with subject line: CBL Dispute. Please include the following in the email:
    • BBL and BIN for such building
    • contact information: name, email address and/or telephone number
    • explanation of your dispute and any documentation requirements listed on the CBL Matrix for the compliance pathway that you believe your building is subject to

Houses of Worship

LL97 defines “house of worship” as a building whose main use or dominant occupancy is classified as occupancy group A-3 religious house of worship. Such buildings are subject to Article 321 “CP3.” DOB asks these building owners to self-identify as follows:

If you believe your building meets the definition of “house of worship,” email ghgemissions@buildings.nyc.gov with subject line: CBL Dispute. Please include the following in the email:

  • BBL and BIN for such building
  • contact information: name, email address and/or telephone number
  • RDP certification confirming greater than 50% of the building is used as assembly space for religious purposes

My building received the 421-a Tax Incentive and I believe that I should be subject to Article 321 “CP3”, what should I do?

The 421-a Tax Incentive alone is not enough to determine a building’s compliance path under LL97. A building must participate in one of the programs listed on the CBL Matrix to qualify for an alternative compliance path under the law.

If you believe your building is erroneously listed on a CBL due to a characteristic of the building other than the square footage, email ghgemissions@buildings.nyc.gov with subject line: CBL Dispute. Please include the following in the email:

  • BBL and BIN for such building
  • contact information: name, email address and/or telephone number
  • explanation of your dispute and any documentation requirements listed on the CBL Matrix for the compliance pathway that you believe your building is subject to

What do I do if there are multiple BBLs associated with my building listed on the CBL?

If there are multiple BBLs associated with a building, DOB will need the building owner to confirm the preferred BBL to be used going forward. Such building owner should submit their LL97 report under the BBL that best represents the building (the primary BBL), and then submit documentation under any additional BBLs (secondary BBLs) identifying the building’s primary BBL.

Note:

  • LL97 compliance, including the submission of reports and assessment of any penalties, is at the level of an individual building (as designated by a Building Information Number, or BIN). Individual buildings are nested under tax lots (as designated by a Borough-Block-and-Lot number, or BBL).
  • The LL97 reporting process in DOB Now will be available in 2025, the first reporting year for LL97

How do I update the owner information on my building?

If you need to update the owner information on your building – for example, where a co-op shareholder is receiving communications as if that individual is the owner of entire co-op – such ownership information can be entered into DOB Now upon submission of the first LL97 report. Note the LL97 reporting process in DOB Now will be available in 2025, the first reporting year for LL97.