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JUNE 12, 2026 · REGULATORY COMMENTARY · Jeremy Riback, RA

What LL97 Actually Requires From Your Building's Architect

Most building owners are receiving compliance advice from energy consultants who cannot produce the DOB filings the law requires. The architect's role in LL97 compliance is underappreciated — and undersupplied.

Local Law 97 sets emissions limits for buildings over 25,000 square feet, with penalties for non-compliance starting in 2024 and tightening again in 2030. Energy consultants can model a building's performance and recommend upgrades, but many of the actual filings — energy audits tied to Chapter 8, retro-commissioning reports, and the technical narratives DOB expects — require a licensed architect or engineer to prepare and stamp.

We've seen owners bring in energy consultants early, get a strategy, and then discover late in the process that the paperwork DOB actually requires needs to come from a design professional. That gap costs time and, in a compliance deadline, time is the one thing you can't buy back.

Bringing an architect in from the start of the compliance process — not after the energy consultant's recommendations are already set — means the filing requirements shape the strategy instead of the other way around. For owners managing a portfolio against the 2030 deadline, that sequencing difference compounds fast.

The architect isn't a formality in LL97 compliance — for most buildings, we're the only party who can actually produce what DOB is asking for.
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