Local Law 97 and Battery Storage: What DOB Bulletin 2025-014 Changed

What changed

On December 8, 2025 the NYC Department of Buildings issued Buildings Bulletin 2025-014. It covers energy storage systems as a source of emissions deductions under Local Law 97, treated as a clean distributed energy resource. The bulletin does two things:

• It clarifies the Host deduction for off-site energy storage.
• It gives an alternate method for the Off-taker deduction, for both on-site and off-site storage.

Storage can contribute deductions. It does not by itself make a building compliant. Compliance depends on the building's reported emissions, its limits and every other deduction and pathway it uses.

Hosts and off-takers

The bulletin defines the roles:

• Host: the building where the battery is physically installed.
• Off-taker: a building where the battery's energy is used.
• On-site: the host is the only off-taker.
• Off-site: there are several off-takers, which may or may not include the host.

A building may take the Host deduction, the Off-taker deduction, or both. That opens a path for a building with no room for a battery: it can be an off-taker of a battery installed elsewhere, including one bought from an independent operator.

How the deduction is calculated, in plain English

Both methods multiply three things: an amount of storage, the total emissions spread (TES), and an efficiency factor.

• TES is a factor the Department of Buildings determines, under the methodology in 1 RCNY §103-14. The calculation uses the TES for the year before the reporting year.
• Efficiency is round-trip efficiency, set at 85% for calendar years 2024 to 2029.

Standard method, for hosts and for a building that takes the full output of its on-site battery: the battery's rated capacity in kWh × TES × 85%.

Adjusted TES method, for off-takers using part of a hosted battery or buying from an independent one: the kWh the building consumed from the battery in the prior year, divided by 365, × TES × 85%. The consumption must be metered within ±2.0%. Off-takers may use this method in place of the time-of-use (TOU) coefficient method in the rules.

The result is a deduction in metric tons of CO2e, taken off the building's emissions from electricity use.

Who is covered by Local Law 97

• A building that exceeds 25,000 gross square feet.
• Two or more buildings on the same tax lot that together exceed 50,000 gross square feet.
• Two or more condominium buildings governed by the same board of managers that together exceed 50,000 gross square feet.

Additional rules apply to some building classes. Confirm your building's status and filing obligations with DOB guidance and your adviser.

What to check before counting on a deduction

• Your gap. Model reported emissions against both the current limits and the 2030 limits first. The deduction is only useful against a real gap.
• Who claims it. If a battery serves several buildings, the agreements must say which building claims which deduction, so nothing is counted twice.
• Metering. Off-takers need consumption metered within ±2.0%. Plan the metering before the contract, not after.
• The rest of the case. A battery can also lower demand charges and may earn utility program payments. Each value is modeled separately, from the building's own data.

Where NOI fits

NOI finances and builds battery storage for commercial and multifamily owners and models it against the building's tariff and load. For Local Law 97, we work alongside the owner's compliance consultant: they own the filing, we model the storage. Send us twelve months of bills and the latest LL97 report to start.

Sources

• NYC Department of Buildings, Buildings Bulletin 2025-014, issued December 8, 2025: nyc.gov
• NYC Department of Buildings, Local Law 97: nyc.gov
• Hodgson Russ, client alert on the bulletin, December 19, 2025: hodgsonruss.com

Reviewed October 19, 2026. This is general guidance, not legal advice. Confirm your building's compliance position with DOB guidance and your compliance adviser.

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