Objective

To determine whether the Department of Citywide Administrative Services (DCAS) has taken steps to achieve compliance with the Local Law 97 Implementation Action Plan by the mandated and commitment time frames. We also determined whether DCAS adhered to the related mayoral Executive Orders to achieve compliance with Local Law 97. The audit covered the period from November 2019 through September 2025.

About the Program

According to the U.S. Environmental Protection Agency, greenhouse gases (e.g., carbon dioxide, methane, and nitrous oxide) trap heat and can alter climate and weather patterns, affecting surface air and ocean temperatures, precipitation, and sea levels.

In 2019, the New York City Council passed the Climate Mobilization Act to reduce greenhouse gas emissions, also known as carbon emissions, and improve energy efficiency for certain buildings in New York City (NYC or City). As a result, Local Law 97 (LL97), (later modified by LL147) required City government operations to reduce emissions by at least 40% by fiscal year 2025 and 50% by fiscal year 2030, relative to such emissions for fiscal year 2006. (The City’s fiscal year begins July 1 and ends June 30 of the following calendar year. For the purposes of this report, all years represent fiscal years, unless they are specifically stated to represent calendar years.)

Four mayoral Executive Orders were issued to facilitate the reduction of emissions in City government operations. These Executive Orders require the City to identify a City Chief Decarbonization Officer and Agency Chief Decarbonization Officers (Decarbonization Officers), establish specific emissions reduction targets, annually report on each agency’s emissions reduction progress on the City’s website beginning in 2022, and set requirements to make the New York City fleet more sustainable and efficient.

DCAS published its LL97 Implementation Action Plan (Action Plan) in December 2021, as required in Executive Order 89. The plan identified the 2006 emissions baseline for 19 City agencies and plans to collaborate with City agencies on multiple emissions reduction and energy efficiency commitments including:

• 100% of City government electricity from renewable sources by 2025
• 20% energy consumption reduction for City buildings by 2025
• 100 megawatts (MW) of solar energy production by 2025
• 50% fossil fuel consumption reduction by 2025 (80% by 2035)

The City acknowledged in March 2024 that it was 2 years behind schedule in achieving LL97 goals and that it planned to reach them in 2027 rather than 2025, having reduced emissions by only 26% by the end of 2023 (the most recent published data). Similarly, as codified in LL99 of 2024, the timeline for the City to reach 100 MW of solar energy production was extended to September 1, 2030 and 150 MW by December 31, 2035.

Key Findings

The City did not achieve the emissions reductions or energy efficiency improvements for 2025 outlined in LL97 or DCAS’ Action Plan. While the City has acknowledged that it is behind schedule due to “unforeseen and unprecedented challenges over the past years,” other factors such as missing documentation, missed reporting deadlines, inconsistent metrics, and unclear guidance and communication with affected agencies have also contributed to delays with achieving Climate Mobilization Act goals. Addressing these issues through targeted process improvements could improve accountability and transparency and help the City achieve its revised goals.

The audit found:

• DCAS did not ensure all required agencies identified Agency Chief Decarbonization Officers on a timely basis. As these officers were an important part of realizing the Action Plan designed to assist City agencies in achieving their emissions reduction and energy efficiency goals, delays in appointing or failure to install someone in these positions may have contributed to the City not upholding its LL97 and Action Plan commitments.
• DCAS did not establish emissions reduction goals for each entity covered by LL97 as required by EO 89. Of the City’s 158 agencies, offices, and entities, DCAS evaluated the assets of 24, and allocated LL97 emissions reduction targets to only 19 of those 24. While these 19 agencies accounted for a large percentage of the City’s emissions, DCAS was still required to establish targets for all entities covered by LL97, a step that could help the City achieve its emissions goals.
• DCAS did not meet its reporting requirements, publishing progress reports late and without all relevant data needed to ensure transparency with the public.
• DCAS could not provide documentation and data to support adequate oversight of assessments and reporting regarding overall LL97 progress and management of the City’s fleet and efficiency projects. DCAS did not provide source data to support the 2006 baseline emissions, as requested; leased properties were inconsistently factored into goals; and it was unclear between agencies and DCAS who was responsible for conducting certain evaluations and assessments such as projected emissions reductions and cost savings.

Key Recommendations

• Ensure Decarbonization Officers are identified in accordance with Executive Order 89 and that they carry out their duties as specified in the Action Plan. Provide guidance for reducing emissions to agencies without Decarbonization Officers.
• Identify agencies required to comply with Executive Order 89, comply with the provisions related to target setting and reporting on progress for those agencies, or provide a rationale for non-compliance.
• Retain City emissions data and documents to support the achievement of emissions reductions reported and provide such information when requested to support accountability.

Develop procedures and a review process to ensure the tracking of all projects, as well as the accuracy and completeness of the information.