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NYC Solar Compliance: Local Laws 92 & 94- A Comprehensive Guide to Commercial Solar and Sustainable Roofing Solutions

Updated: Jun 2

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Introduction to NYC's Sustainable Roofing Legislation-NYC Solar Compliance: Local Laws 92 & 94

In a groundbreaking step towards sustainability, New York City introduced Local Laws 92 and 94 in 2019, marking a pivotal shift in the city's architectural and environmental landscape. These laws, as detailed in Buildings Bulletin 2019-010, mandate incorporating sustainable roofing zones in all new construction, significant roof renovations, and expansions, effective November 15, 2019. This initiative underscores NYC's commitment to combatting climate change, enhancing urban green spaces, and promoting renewable energy sources.

Scope and Application

The scope of these laws is comprehensive, covering new buildings, complete roof replacements, and vertical and horizontal enlargements. Projects that fall under these criteria are required to implement one or a combination of the following sustainable roofing solutions:

  • Solar photovoltaic (PV) systems with a minimum generation capacity of 4kW.

  • Green roof systems designed to support vegetation and provide insulation.

  • A hybrid approach that combines both solar and green roofing elements.

Compliance and Documentation

Specific Requirements:

  • Roofs >200 sq ft (or >100 sq ft for Group R buildings up to five stories) with a slope <2:12:

  • Must install a solar system, green roof, or both.

  • If solar capacity cannot reach 4 kW due to shading, a green roof is required.

  • Solar panels must have a minimum efficiency of 15%.

  • Roofs <200 sq ft (or <100 sq ft for Group R buildings up to five stories) with a slope <2:12:

  • Must install a solar system covering the entire area.

  • If solar capacity cannot be reached, a green roof must cover the area.

  • Roofs with a slope >2:12:

  • Only solar PV systems are allowed.

  • If 4 kW capacity cannot be reached, the roof section is exempt.


To ensure adherence to Local Laws 92 and 94, the following compliance and filing protocols have been established:

  • Calculate the compliant roof area by excluding FDNY-required access paths, HVAC equipment, and existing structures.

  • Assess suitability for solar panels, green roofs, or both based on roof space and shading.

  • Hire professionals to perform structural analysis and ensure compliance with building codes.

  • Submit the Local Laws 92/94 Solar and Green Roof Systems form with building permits.

Thinking about solar panels for your new roof? Find out how we can guide you through complying with LL 92 and 94

For projects initiated on or after November 15, 2019: All new building (NB) applications, alterations involving enlargements, and post-approval amendments (PAA) that include new roofing must demonstrate compliance. This is facilitated by submitting a dedicated "Local Law 92/94 of 2019 Solar and Green Roof Systems" form, which certifies adherence or claims exemption.

For projects submitted before November 15, 2019: Any application not approved by 3:00 p.m. on November 14, 2019, is also mandated to submit the compliance form before plan approval can be granted.


Roofs may be exempt from these requirements if they:

  • Have a slope >2:12 and insufficient solar capacity.

  • Are occupied by other structures like water towers or HVAC systems.

  • Are used for recreational spaces or are undergoing simple repairs.

  • Are covered by stormwater management systems.

  • Cannot handle a 4 kW solar plant.

  • Are deemed unsuitable for sustainable roofing by the NYC Department of Buildings.

  • Must meet specific NYC building codes and zoning regulations.

  • Compliance with Affordable Housing

Buildings in the affordable housing sector must comply with these laws by November 15, 2024, following reduced requirements as determined by the NYC Department of Housing Preservation and Development (HPD).

Curious About the Benefits of Rooftop Solar Installation for Your NYC Building's Compliance Needs?

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Empowering Urban Spaces: Leveraging Local Laws 92-94 for Commercial Solar Sustainability

Benefits and Environmental Impact

The enactment of Local Laws 92 and 94 promises significant environmental, economic, and social benefits:

  • An expected increase in solar energy production by 20–35 MW annually.

  • Management of approximately 1 million gallons of stormwater each year.

  • Reduction of greenhouse gas emissions by 1 million tons by 2030.

  • Numerous jobs in the green economy have been created, reinforcing NYC's sustainability objectives and positioning it among global leaders in urban sustainability.

Detailed Requirements and Exceptions

  • Project Triggers: The requirement for sustainable roofing is activated by any project involving new construction, the complete replacement of the roof assembly, or decking. This encompasses entirely new structures, as well as both vertical and horizontal extensions and complete roof deck replacements.

  • Shaded Roofs: In cases where roofs are heavily shaded and unsuitable for solar panels, green roofs are an alternative, leveraging even minimal sunlight to sustain vegetation.

  • Cool Roof Standards: Updated standards from Local Law 21 of 2011 are incorporated, stipulating stricter emittance and reflectance criteria, including pitched roofs and areas beneath solar panels. Consequently, all new roofing projects must comply with cool roof requirements.

  • Pitched Roof Compliance: For pitched roofs, a variety of materials meeting specific Solar Reflectance Index (SRI), reflectance, and emittance standards are deemed compliant. This includes specially designed shingles and tiles with cooling properties.

Synergistic Green Roof and Solar PV Integration: Compliance with Local Laws 92-94 for Commercial Solar Sustainability
Take a Look At This Urban Green Roof and Solar PV Combo Concept

Integration with Other Local Laws

Local Laws 92 and 94 also interact with other city regulations to enhance environmental sustainability. Local Law 94 mandates sustainable roofing zones for all new construction and major roof renovations, while Local Law 92 adjusts these requirements for smaller buildings. These laws, part of NYC’s Climate Mobilization Act (Local Law 97), aim to enhance the city's sustainability by leveraging its extensive rooftop space for environmental benefits:

  • Local Law 97 (buildings over 25,000 Sq. Ft): Solar installations offer energy credits and contribute to meeting the carbon emission limits set by Local Law 97. Additionally, green roofs provide insulation and cooling benefits, aiding in the efficiency of rooftop equipment and furthering carbon reduction goals.

  • Roof Use and Accessibility: While sustainable roofing is prioritized, provisions are made for recreational spaces such as roof decks and playgrounds, provided they are essential to the building's use and documented on the Certificate of Occupancy.

  • Affordable Housing Consideration: The city offers a distinct compliance pathway through the Department of Housing Preservation and Development for specific affordable housing projects, reflecting its commitment to sustainability and accessibility. Buildings with City or State subsidies (e.g., HPD/DHCR loans, HDFCs, Mitchell Lamas, and 420-c tax incentive recipients), buildings in HPD’s AEP program, and those under HPD’s jurisdiction are mostly exempt. They must comply with the New York City Overlay of the Enterprise Green Communities Criteria, which may include solar installation. Affordable housing properties receiving 421-a or J-51 incentives must fully comply with the sustainable roofing requirements. No exemptions exist for cool roofs.

  • Local Law 94 Enhancements: Stricter emittance and reflectance standards for flat roofs. Pitched roofs and areas under solar panels must also meet cool roof standards. All new roofs in NYC must now be cool roofs.

Choosing Between Solar Panels vs. Green Roofs

Solar panels are an essential component for transitioning buildings to renewable energy sources. By harnessing solar energy, they provide a clean, inexhaustible electricity supply that is immune to the fluctuations in fossil fuel prices. Solar PV installations not only reduce reliance on finite resources but also significantly enhance overall energy efficiency, particularly when paired with electric appliances like water heaters and air source heat pumps.

On the other hand, green rooftops offer a plethora of ecological benefits. They create leisure spaces, support agriculture and biodiversity, enhance air quality, and mitigate the urban heat island effect. From an energy efficiency standpoint, green roofs excel in providing excellent insulation. This insulation lowers the energy needed for heating and cooling, effectively reducing energy expenses while also extending the life of HVAC systems.

For buildings with suitable rooftops, integrating a green roof with a solar PV system can be transformative. Take our innovative Brooklyn Solar Canopy, for example. Designed to stand nine feet above the rooftop, it circumvents potential obstructions while offering shaded, usable space below. This integration not only maximizes energy efficiency but also enhances the building's functionality in a sustainable manner.

Conclusion: A Step Towards a Greener Future

New York City's Local Laws 92 and 94 represent a significant leap forward in urban sustainability, environmental responsibility, and the promotion of green spaces within the city's dense architectural landscape. By mandating the inclusion of green and solar roofs, NYC aims to enhance its environmental footprint and improve its residents' quality of life through cleaner air, reduced urban heat island effect, and increased biodiversity. These laws set a precedent for cities worldwide, demonstrating the integral role of urban policy in the global fight against climate change and the transition toward a more sustainable future.

Transform your property with the power of clean energy! Although NYC's Local Law 92 and 94 mandate sustainable roofing solutions for only new constructions and roof replacements, there's no better time for all property owners to embrace energy efficiency. Make a smart decision for your building or home by opting for solar energy. Brooklyn SolarWorks is at the forefront of this revolution, having empowered over 1,500 property owners throughout the city to make the switch. Join the movement and let Renewapower help you navigate the path to a greener, more sustainable future. We Hope you enjoyed our guide: NYC Solar Compliance: Local Laws 92 & 94.

Ready to ensure compliance with Local Laws 92 and 94 with solar panels? Let's get started!

Useful Links and Resources:

NYC Mayors office LL92&94 FAQ
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