Fine Tuning New York City’s Green Roof Tax Abatement Program
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New York City’s current Green Roof Tax Abatement (GRTA) Program is the result of an ongoing 13-year stakeholder advocacy effort. The Tax Abatement Program provides property owners with a reduction of taxes payable to the city so that these funds can help to offset the costs of implementing a green roof. Thanks to sustained advocacy of community stakeholders and collaboration with city and state elected officials, the GRTA has evolved and been renewed every five years since it was first adopted into law. This integrated, long term collaboration amongst a wide array of stakeholders is the cornerstone of meaningful policy-making. Most recently; stakeholders, municipal agencies, and elected officials worked together to identify priority community districts where a higher tax abatement should be made available because the need for green roofs is greatest. The criteria for the priority community district designations was finalized by the NYC Mayor’s Office of Long Term Planning and Sustainability (MOS) in 2020. One of the key criteria is heat vulnerability, which also coincides with marginalized communities.
The New York City Department of Health and Mental Hygiene (DOHMH) has amassed data that links health issues (like higher asthma rates, mortality from heart attacks and strokes, and hospital visits caused by poor air quality) to neighborhoods throughout the city. The DOHMH established a Heat Vulnerability Index that defines heat-related mortality based on neighborhood characteristics such as access to green space, poverty, daytime summer surface temperature, and households reporting air conditioning. Here is a link to an article that provides details on the priority areas and below are two maps from an article on the NYC Building Energy Exchange.
Image: Building Energy Exchange
Image: Building Energy Exchange
The green roof conversation got started in 2007, when members of the newly formed Stormwater Infrastructure Matters (SWIM) Coalition, convened a group of experts to develop a shared vision for a Green Roof Tax Abatement program that would help incentivize the use of green infrastructure on private property. Armed with significant research and extensive input from green roof professionals, researchers and policy makers, the Coalition was able to convince the Bloomberg administration and the NY State legislature (whose approval via legislation was needed) to launch the first iteration of the GRTA in 2008.
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When the GRTA was up for renewal in 2013, SWIM Coalition worked closely with a land use expert and city agencies to conduct an independent analysis and host a series of focus groups to compile professional input on and make recommendations for improvements to the program that would lessen the financial and administrative burdens that hindered the use of the program. SWIM presented the research findings at a Green Roofs for Healthy Cities conference in 2012 to obtain additional stakeholder input.
Kingsland Wildflowers Green Roof & Community Engagement Center in Greenpoint, Brooklyn. Photo: Shino Tanikawa
Many of the 2013 recommendations SWIM made were not incorporated into the renewed law and program participation remained low. The initial low tax abatement amount combined with additional bureaucracy involved in accessing the incentive created barriers to participation. And the value of the incentive was only raised from $4.50/sf of installed green roof to $5.23/sf, about half of the rate recommended by the SWIM’s analysis.
In 2018, when the program was set to expire for a second time, the New York City Council passed a resolution to renew the program and proposed that the State increase the abatement amount. SWIM Coalition immediately reached out to the sponsors of the NY State legislation to share and discuss the recommendations from 2013 in an effort to advance the inclusion of the improvements that were left out of the 2013 renewal. As it turned out, SWIM Coalition wasn’t the only stakeholder group reaching out to the legislators for the renewal and improvement of the program, the NYC Comptroller's office was campaigning for the renewal of the program as were researchers at NYU and a team at The Nature Conservancy. The legislators connected the various stakeholders with one another and a GRTA working group was formed in order to compile a unified set of recommendations for the renewal of the program. Once again, this cross collaboration amongst stakeholders was a vital factor in improving the policy and the program.
Photo: Brooklyn Green Roof, LLC
The GRTA working group, coordinated by The Nature Conservancy and comprised of a broad array of experts, including members of Green Roofs for Healthy Cities, convened throughout early 2019 to develop and deliver a set of recommendations for:
an increase in the program cap (from $1 million to $10 million),
the removal of a 4” soil depth requirement to make more roofs eligible for the program,
the establishment of priority zones in the city (based on a set of environmental, socioeconomic, and health criteria) where the abatement amount would be higher ($15 per square foot) because the need for green roof benefits is greater,
a doubling of the tax abatement rate in non-priority zones to $10.46 per square foot
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It was challenging for the working group to reach a consensus on the recommendations as there were differing views on the elements of the law. For instance, the concept of the priority zones with a higher abatement amount was tricky. How would the zones be determined? Which city entity would establish them? What criteria would they be based on? The group wanted to be sure that the program provided effective incentives for green roofs in communities that suffer from poor air quality, higher summertime temperatures and a lack of green space. The fact that the overall program participation rate was dismal for the ten years since the enactment of the program, incentivizing green roofs anywhere in the City was also an urgent need. Additionally, green roof professionals in the working group raised the fact that even $15 per square foot was not going to cover the full set of costs to install a green roof in NYC and many wanted to recommend a higher abatement amount overall. Ultimately, the group reached a consensus and agreed that the renewal of the program was the most important outcome and the recommendations had to represent an incremental increase.
Photo: Brooklyn Greenroof, LLC
The program was renewed (retroactively) in July 2019 with a mandate that the NYC Mayor’s office appoint a city agency to identify a set of priority areas in the city where green roofs were needed most and that properties in these areas would receive a higher tax abatement amount of $15 per square foot. The group’s recommendations that the program cap be increased (it remains at $1 million), and that the 4” growing media depth requirement be removed to make more roofs eligible for the abatement were not included. The abatement rate in non-priority zones remains at the 2013 level of $5.23 per square foot. (Stakeholders learned later that the depth requirement was planned to be removed, but due to an error, was not.) This is why it is important to have an array of stakeholders involved in monitoring and providing input throughout the policy-making process! As we understand it today, the 4” growing media depth requirement will be removed.
The working group continued to meet throughout late 2019 to develop recommendations on the criteria for the priority areas and discuss a next set of recommendations for the GRTA that they hoped could be made in the next legislative session rather than wait until the next renewal period. Perseverance and patience are required when working on policy matters.
The COVID-19 pandemic caused a cascade of legislative delays in early 2020 but the working group continued to convene remotely. In the summer of 2020, the Mayor’s Office of Long Term Planning and Sustainability (MOS) requested that the Mayor designate MOS as the agency responsible for identifying the GRTA priority zones through an Executive Order. The working group sent its priority zone criteria analysis to the MOS for their immediate review. But months later, when there had been no word about the priority zone designation, the stakeholder working group sent a letter to the Mayor encouraging him to sign the executive order on his desk authorizing the MOS rulemaking process to designate the priority zones.
GRTA Working Group Members
Green Roof Researchers Alliance/NYC Audubon Society
Guarini Center on Environmental, Energy & Land Use Law/NYU
NYC Soil and Water Conservation District
New York Cities Program, The Nature Conservancy
Brooklyn Greenroof, LLC
Alive Structures
NY League of Conservation Voters
Stormwater Infrastructure Matters
Gowanus Canal Conservancy
Newtown Creek Alliance
Hudson Riverkeeper
Guardians of Flushing Bay
Green Roofs for Healthy Cities
In the waning days of 2020, the MOS released the proposed rule and held a public hearing for a final round of public input on the criteria for the priority zones. In early 2021 the Mayor’s office issued the rulemaking documents without much fanfare and the first list of priority zones here is a link to their web page with the rule and the list of priority zones). As of this writing (September, 2021), the NYC Dept of Buildings (DOB) webpage for the GRTA says the program ended in March 2018. The GRTA working group has been in touch with the DOB who says they are updating their website to reflect the new GRTA. Members of the working group will continue to monitor this and call on the city to provide up to date information on the program. In fact, there is a NY City Council resolution that also calls for the updates to the DOB site. Data from the NYC Panel on Climate Change indicate that NYC and our region will experience and increase in extreme heat index conditions and frequent and intense rain and flooding events in the 2020’s through the 2080s. Green roofs can help relieve the impacts of both.
The GRTA working group is currently working together to build public awareness of the updated program and get the word out about the priority zones. A member of the working group, the Green Roof Researchers Association, is establishing a tool on their website ( in late 2021/early 2022) where people can insert their zip code to see if their property is in one of the priority zones, while other members of the working group are working on getting op eds published, and have been presenting at high profile online events to inform the local real estate communities. While there is more advocacy work to do, it is clear that without the influence and focus of a relatively small group of stakeholders and elected officials, the GRTA might have languished and faded away in the midst of budget negotiations and change of administration. Never underestimate the power of a small group of citizens!
Shino Tanikawa is Executive Director of the NYC Soil and Water Conservation District
Inger Yancey, a LEED Accredited Architect and a Green Roof Professional (GRP), is Founder and President of Brooklyn Greenroof, LLC
Anna Yie, MS, Sustainable Environmental Systems, LEED® Green Associate™ is a Pratt Fellow for SWIM Coalition
Julie Welch is Program Director at SWIM Coalition
More Information
A full historical timeline on the GRTA is available on the SWIM Coalition’s website
Attend the Green Roofs In New York: Research & Practice Virtual Symposium on Tuesday, October 19, 2021 to learn more about green roof policy, design, and research in New York City.
