// NYC Local Law Compliance
Local Law 92 & 94 — solar & green roof requirements.
What are Local Laws 92 & 94?
Passed as part of the Climate Mobilization Act, Local Laws 92 and 94 require that covered roofs include a “sustainable roofing zone” — covered 100% by a solar photovoltaic (PV) system, a green (vegetated) roof, or a combination of the two.
Unlike the annual filings, this one is trigger-based: it applies when you build new or perform major roof work. Getting the feasibility and design right early keeps a re-roofing or renovation project from stalling at DOB plan approval.
100%
of the sustainable roofing zone must be covered by solar PV, a green roof, or a combination — whenever a covered roof is newly built or fully replaced.
Solar / green
PV, vegetated roof, or both
DOB
enforced at permit approval
// Who is covered
When does it apply — and what's exempt?
New construction, vertical or horizontal enlargements, and major roof work that requires a permit — replacing the entire roof deck or assembly. Routine re-roofing of the membrane does not trigger it.
Areas that can't host solar or green roof — required fire-access setbacks, rooftop mechanical equipment, stormwater structures, and integral recreation space — are excluded from the zone.
A small-roof exemption applies where a solar system can't reach 4 kW (or a green roof can't reach the minimum area), substantiated by calculations and a shading report from a registered design professional.
// What it requires
A sustainable roofing zone
Solar and / or green
Cover 100% of the sustainable roofing zone with a solar PV system, a vegetated green roof, or a combination — whichever is most cost-effective for your building.
Feasibility drives the choice
If solar isn't feasible a green roof is required, and vice versa. Remaining non-feasible areas must still meet cool-roof standards.
Filed before approval
A Sustainable Roof Zone form certifying compliance must be filed and approved before DOB grants plan approval.
// Enforcement
Enforced at the permit, not by an annual fine
Local Laws 92 and 94 are enforced through DOB's plan-approval and permit process rather than a periodic penalty schedule — unresolved non-compliance blocks approval and sign-off, which can hold up your whole project.
2024 update
As of November 15, 2024 the affordable-housing exemption ended — those buildings now meet the same sustainable-roof requirements as everyone else — and HPD folded its separate solar-feasibility review into DOB's standard LL92/94 process.
Stormwater coordination
Rooftop solar and green-roof design must be coordinated with DEP's Unified Stormwater Rule, so the disciplines have to be planned together.
// How we help
How Eastern Engineering handles your sustainable roof
- 01Run the solar and green-roof feasibility study — shading analysis, capacity calculations, and substantiation for any exemption.
- 02Design the solar PV system and coordinate the green-roof structural, waterproofing, and stormwater requirements.
- 03Prepare and file the DOB Sustainable Roof Zone form and secure plan approval so your project keeps moving.
- 04Stack NY-Sun, NYSERDA, and federal solar incentives — and tie the roof into your Local Law 97 carbon plan.
// The full slate