A building owner in Queens plans a full roof replacement for next spring. The roofer prices the membrane. Nobody prices the solar. Then the DOB filing asks for the Local Law 92 and 94 form, and the job that was a re-roof becomes a re-roof with a sustainable roofing zone. NYC Local Law 94 solar requirements are older than most installers' current templates. They still catch people every season.
Local Laws 92 and 94 of 2019 went into effect in November 2019. They apply to new buildings and to existing buildings that replace the entire roof deck or the entire roof assembly. Vertical and horizontal enlargements are covered too. A patch is not. A full tear-off down to the deck usually is.
What NYC Local Law 94 solar rules require on the roof
The Department of Buildings describes the requirement this way. The sustainable roofing zone has to carry a solar photovoltaic system generating at least 4 kW, a green roof system, or a combination of the two. If the 4 kW solar minimum cannot be met, a green roof is required instead.
A few rules from DOB Buildings Bulletin 2019-010 shape the drawing:
- Roof areas are separate. Each contiguous roof area is evaluated on its own. A bulkhead that splits the roof can create two areas with two answers.
- Slope matters. Steeper roofs are not suited to green roofs, so solar is usually the practical option there.
- Exclusions exist. DOB can exclude areas where conditions are unfavorable, such as a structure that cannot support the added weight.
The point for a designer is that the roof plan is now the compliance document. It has to show where the zone is, what was excluded, and why.
The filing sequence that keeps plan approval moving
DOB asks for the LL 92/94 Solar and Green Roof Systems form before plan approval. A Registered Design Professional has to make the green roof and solar filings. Solar filings also need an electrical filing by a licensed electrician. Those are three different people on a typical re-roof, and they all need the same roof plan.
Athol Energy prepares the solar permit design drawings that the design professional and the electrician file. We are not the roofer or the RDP of record for the building. Our sheets are built so the zone, the array, and the electrical path agree before the filing starts.
What the roof plan should carry:
- Sustainable roofing zone outline. Drawn and dimensioned for each contiguous roof area.
- Excluded areas. Mechanical equipment, required access paths, and any structural exclusion, each labeled with the reason.
- Array layout and kW. Module count and the resulting system size, so the reviewer can check the 4 kW minimum without a calculator.
- Fire access. Pathways and setbacks under the New York City Fire Code, written as dimensions.
- Structural note. Ballast or attachment basis, tied to the roof assembly being installed, not the one being removed.
Do not draw the city like upstate
New York City enforces its own construction and electrical codes. A template built for an upstate town under the state Uniform Code will cite the wrong documents. Our post on NYC DOB solar permits vs upstate walks through the differences. The short version: separate templates, separate code notes, separate title blocks.
The utility side is Con Edison for most of the five boroughs. The Con Edison solar interconnection post covers the application. On a re-roof, the timing trap is that the roofer wants to close the roof before the interconnection paperwork is even started. Sequence the sleeves, curbs, or ballast trays into the roofing scope so the array does not mean cutting into a new membrane.
When the owner asks for the minimum
Many owners will ask for the smallest compliant system. That is a fair request. Draw the 4 kW minimum clearly, and show the remaining zone as green roof, open roof where excluded, or additional solar if the owner wants it. Then price the additional modules as an option. A bigger array on a brand-new roof is cheaper now than a second mobilization later. Most owners only need to see that number once.
Questions about NYC Local Law 94 solar
Does Local Law 94 apply to a roof replacement?
It applies when an existing building replaces the entire roof deck or the entire roof assembly, as well as to new buildings and to vertical and horizontal enlargements.
How big does the solar system have to be?
Where solar is used, the sustainable roofing zone has to include a system generating at least 4 kW. If that minimum cannot be met, a green roof is required instead, or a combination can be used.
Who files the Local Law 92/94 paperwork?
A Registered Design Professional files the solar and green roof filings, and the LL 92/94 form is due before plan approval. Solar filings also need an electrical filing by a licensed electrician.
If a New York City re-roof is on your schedule for spring, start the solar drawings now. New York solar design from Athol Energy builds the zone, the array, and the electrical path on one roof plan. Contact us with the address and roof survey.