NYC Local Law 92 & 94: What to Know

New York City’s Local Laws 92 and 94 were passed by the City Council in 2019 as part of the Climate Mobilization Act (CMA). The CMA, otherwise known as NYC’s Green New Deal, aims to guide our city towards carbon neutrality by 2050 through various initiatives towards developing energy efficiency in buildings. 

NYC Local Law 92 and 94 are a pair of legislation under the CMA requiring building owners to install sustainable roofing systems – solar photovoltaic systems or green roofs – on all new roofs. Here’s what you need to know about the requirements of these laws and how to comply.

What are Local Laws 92 and 94 in NYC?

NYC Local Law 92 and 94 are a pair of laws mandating the installation of sustainable roofing zones on all rooftops undergoing major construction, both for new and existing roofs. These two pieces of legislation are grouped together because they both set forth the requirements for this specific mandate.

• LL 94 requires sustainable roofing zones on all new construction and major roof renovations.
• LL 92 adjusts those requirements for smaller buildings.

Sustainable Roofing Zones

A “sustainable roofing zone” is defined by these laws as “areas of a roof assembly where a solar photovoltaic electricity generating system, a green roof system, or a combination thereof, is installed.”

Why were Local Laws 92 and 94 created?

Data collected by the City Council estimates that 70% of NYC’s carbon emissions come from buildings. Local Law 97, one of the main parts of the CMA, focuses on improving the all-around efficiency of buildings 25,000 square feet or larger. LL 92/94 were created to help this effort, by requiring solar panels or green roofs to be built on new rooftop installations of all sizes (with some exceptions). 

Benefits of Sustainable Roofing for NYC

Solar panels are an essential part of moving towards true energy efficiency. While upgrading to electric appliances – like air source heat pumps or induction cooktops – improve a building’s overall efficiency, running those appliances, and the rest of the building, off of clean solar energy is even better.

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Green roofs provide a number of benefits to urban environments, including:

• Improvements in air quality and biodiversity
• Creation of recreational space
• Increased energy efficiency by acting as an insulator, reducing the energy needed for heating and cooling

What are the building requirements of NYC Local Law 92 and 94?

LL 92 and 94 mandated that beginning November 15, 2019, all new buildings and roof replacements in NYC must install a solar photovoltaic system or green roof (or a combination of the two). There are some exceptions and different requirements based on the size, classification, and slope of the roof.

1. For continuous roof area greater than 200 square feet (100 square feet or more in Group R buildings up to five stories), and a slope below 2:12
   • A solar system, green roof, or a combination of both, must be installed. 
   • If the solar power capacity cannot reach 4 kW due to conditions like shading, a green roof is the only option. 
   • A minimum solar panel efficiency of 15% must be used for all calculations.
2. For continuous roof area of less than 200 square feet (less than 100 square feet in Group R buildings up to five stories), and a slope below 2:12
   • A solar system reaching 4 kW must cover the entire area
   • If solar capacity cannot be reached, the entire area must be covered by a green roof
   • A combination of a solar PV system and green roof is not allowed
3. Continuous roof area with a slope higher than 2:12
   • A solar PV system is the only option because the slope is too great for a green roof
   • However, if a solar capacity of 4 kW cannot be reached, that roof section is exempt from LL92/94

Exceptions to LL 92 and 94

The requirements of this law apply to all new roof installations in the city and are based on the square footage of “continuous” or available space on the roof. In some cases, a roof or sections of a roof may be exempt from the requirements of these laws. Here are some exceptions:

• If the slope of the roof is greater than 2:12 and a solar system would not reach a capacity of 4 kW
• Too much of the roof area is occupied by other structures such as water towers, mechanical equipment, or stormwater management systems
• The roof is already occupied by recreational spaces
• If you’re making simple repairs to your roof, rather than replacing it altogether

Solar Panels vs. Green Roofs

Solar systems and green roofs are both great tools for improving energy efficiency, but are not necessarily interchangeable in terms of their environmental benefits. 

With just a solar PV system, you’ll be improving your building’s energy use by changing the power supply. Rather than relying on nonrenewable fossil fuels to power the building, your solar panels would provide clean, renewable electricity. This is energy that doesn’t pollute, will always be available and won’t face supply price hikes. Solar PV systems are especially beneficial for energy efficiency when used in conjunction with electric appliances like hot water heaters and air source heat pumps.

Green roofs are versatile spaces with a variety of environmental benefits. They can provide recreational areas, house agriculture and biodiversity, and improve air quality and urban heat island effects. When it comes to energy efficiency, green roofs act as insulation for buildings, reducing energy consumption for heating and cooling. Decreasing the use of heating and cooling systems also means saving energy costs and extending the longevity of HVAC systems.

If your roof allows it, a combination of green roof and solar PV system can be a great upgrade for your building. Our patented Brooklyn Solar Canopy is elevated nine feet above the roof surface to avoid obstructions. As a result, it also provides shade and living space underneath. 

Check out this green roof-canopy combo that one of our customers created:

How to Calculate Your Roof Area Covered by LL 92 & 94

Because some areas of your roof, like FDNY fire paths and other structures, are exempt from LL 92 and 94 coverage, you’ll need to calculate the area of your roof that needs to comply. It’s best to work with a certified design professional or contractor on this, but you can expect to subtract the following areas from your total roof area:

• Required FDNY roof access: for every 100 square feet of rooftop, there should be a clear path of at least 6 feet in width stretching across the building.
• HVAC equipment and existing structures like stormwater management systems
• Recreational spaces

How to Be Compliant with NYC’s Sustainable Roof Policies

In order to comply with LL 92 and 94 (NYC green roof law), you should work with a contractor or design professional to determine if your roof is suitable for solar panels, a green roof, or both, or if it’s exempt from the requirements of the mandate. From there, you can choose a solar or green roof installer that best fits your building’s needs.

Interested in installing solar panels on your new roof? Learn about how we can help you comply with LL 92 and 94:

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Building permits filed with the DOB must submit a Local Laws 92/94 of 2019 Solar and Green Roof Systems form certifying their compliance with, or exemption from, the requirements of Local Laws 92 and 94 prior to approval.

New York City Sustainability and Energy Efficiency 

NYC has some of the most ambitious sustainability goals in the country, which is a great thing for our fight against climate change. A major part of achieving carbon neutrality is reducing the carbon emissions of our buildings by choosing renewable energy sources and increasing energy efficiency. 

While NYC Local Law 92 and 94 apply only to new buildings and roofs, energy efficient upgrades are a great idea for any building or home. If you’re making the switch to clean energy, choose an expert. Brooklyn SolarWorks has made solar energy appealing and accessible for over 1,500 property owners across the city.

Need solar panels to comply with LL 92 and 94? Get started:

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