Local Law 97 Compliance Checklist: What You Need by May 1, 2025

Key 2024 Updates for LL97 Compliance 

1. New Reporting Platform: BEAM

• Building Energy Analysis Manager (BEAM) is now the main reporting portal for all LL97 submissions.BEAM will handle both annual (Article 320) and one-time (Article 321) compliance submissions.

2. Filing Fees and Data Submission 

• Applicants will pay filing fees through DOB NOW, NYC’s online portal for Department of Buildings filings. 
• Energy data must be submitted using EPA’s ENERGY STAR Portfolio Manager (ESPM). 

3. BEAM for Compliance Communication 

• All report reviews and follow-up communications between the Department of Buildings (DOB) and applicants will occur through BEAM. 

4. Combined Reporting Option (2024–2029) 

• During the first compliance period, owners can file a single report for multiple buildings if they: 
  • Have the same owner, 
  • Are on the same or adjacent lots, and 
  • Follow the same compliance pathway. 
• Combined reports must include separate emissions calculations for each building unless the buildings share an energy service, in which case emissions can be aggregated. 

Understanding Basics:  

Local Law 97 (LL97), first passed in 2019, is designed to reduce greenhouse gas (GHG) emissions from New York City’s largest buildings. The law aims to cut emissions 40% by 2030, targeting net-zero by 2050.  

The size threshold for LL97 is over 25,000 gross square feet (“GSF”) for a single building, or over 50,000 GSF for multiple buildings that are either on a single lot or governed by the same board of managers. 

Essentially, LL97 is structured into several articles – Articles 320 and 321 – which provide definitions and guidelines for “covered buildings”. 

Article 320 covers most private buildings, and Article 321 applies to specific categories, including affordable housing and houses of worship. Under Article 320, most private buildings must submit an annual GHG emissions report to the NYC Department of Buildings by May 1, 2025, and every May 1 afterward. Each report must be certified by a registered design professional. 

Steps to Prepare for LL97 Compliance 

1. Use WatchWire to Understand Compliance Risk and Reporting Requirements

First and foremost, you need to understand if your building (or if any buildings in your portfolio) are subject to LL97 compliance. You can do so by downloading a compliance report on WatchWire. This report identifies which buildings are subject to regulations like Local Law 97, outlines key reporting requirements, and specifies penalties for non-compliance.

With WatchWire’s partnership with the Institute for Market Transformation (IMT), this compliance support extends beyond Local Law 97, assisting clients with regulatory compliance across the U.S. and Canada.

2. Create a Property Profile for Buildings

To start LL97 reporting, the Applicant (such as the building owner or an authorized agent) must register in DOB NOW and complete the LL97 fee payment. This activates the building’s reporting functionality in BEAM. For Article 320 or 321 buildings meeting specific emissions limits, the Applicant must also create or update an ENERGY STAR Portfolio Manager (ESPM) profile with the building’s details, including Gross Floor Area (GFA) and primary property type, as required for Local Law 84 (LL84) benchmarking. 

3. Understand Your Building’s Emissions Limits

Once registration steps are complete in DOB NOW, ESPM, and BEAM, applicants can proceed with submitting LL97 compliance reports for their buildings in BEAM. For buildings following the Article 321 Prescriptive Pathway, this involves uploading the Prescriptive Energy Conservation Measure (PECM) templates and any required documentation; no ESPM data is needed. 

For all other compliance reports, applicants must define their building’s greenhouse gas (GHG) emissions limits. While BEAM pulls general building information from ESPM, LL97 may require more detailed data, including the subdivision of property types within the building along with specific floor plans and stacking diagrams. BEAM will automatically calculate the emissions limit using the current compliance period’s emissions factors. For buildings that have received adjustments under LL97 sections (such as 320.7, 320.8, or 320.9), the adjusted limits and relevant application numbers should be entered for DOB review. 

Once limits are set, the applicant can determine their building’s GHG emissions by selecting either a simple or complex reporting pathway. In the simple pathway, BEAM calculates emissions using annual energy data directly from ESPM, and applicants only need to upload additional documentation for specific fuel types or credits. For the complex pathway, more specific situations—such as multiple buildings on one lot, shared energy services, or use of Distributed Energy Resources (DERs)—require additional documentation, such as site plans or energy system specifications. In both cases, if the building has purchased offsets or Renewable Energy Credits (RECs), relevant proof must be uploaded in BEAM. 

Finally, if an unexpected event impacts the building’s emissions, applicants should submit proof, including DOB filings or permits, to support their report. This structured process ensures accurate reporting and adherence to LL97 compliance guidelines through BEAM. 

 4. Obtain Certification from a Registered Design Professional (RDP)

Following the emissions calculation, BEAM will assess whether the building meets its calculated emissions limit. Once this assessment is complete, the applicant must review it and then upload a signed attestation from the associated Registered Design Professional (RDP) or Retro-Commissioning Agent (RCxA), as applicable. This attestation confirms that the submitted information is accurate to the best of their knowledge and ability, finalizing the compliance submission in BEAM. 

5. Departmental Review

Once the LL97 Compliance Report is submitted, the Department of Buildings (DOB) will review all documentation in BEAM for clarity, completeness, and compliance using standardized templates. They will provide feedback to the applicant’s designated team as needed. For adjustment applications under §28-320.7, the DOB will determine if the adjustment request is accepted. After this review, there are three possible outcomes: the building may be deemed compliant, non-compliant with a penalty, or non-compliant with an opportunity for mediated resolution, where the owner can demonstrate Good Faith Efforts (GFE) toward compliance according to specified guidelines. 

6. Develop a Decarbonization Plan

Building owners can get a two-year break on Local Law 97 penalties if they demonstrate ‘good faith’ effort to decarbonize. Therefore, establishing a comprehensive decarbonization plan is essential to maintain long-term compliance with Local Law 97. This plan may include conducting energy audits and implementing energy efficiency upgrades, such as the installation of energy efficient electric-based heating, cooling, and domestic hot water systems to displace fossil fuel sources.

An Energy and Sustainability Software like WatchWire by Tango can support your decarbonization efforts by helping you: 

• Reduce energy during peak load times, 
• Track and manage progress on your decarbonization goals, and  
• Monitor cost-savings and energy reductions achieved from energy efficiency projects. 

In summary, Local Law 97 updates now introduce the Building Energy Analysis Manager (BEAM) as the central reporting portal, streamlining both annual and one-time compliance submissions under Articles 320 and 321. As regulatory requirements continue to evolve, it’s essential for portfolio companies to invest in technology solutions that support accurate emissions measurement, management, and decarbonization efforts. 

More About WatchWire

WatchWire by Tango is a market-leading, energy and sustainability data management platform that uses cloud-based software to collect, automize, and analyze utility, energy, and sustainability data metrics. WatchWire streamlines, automates, and standardizes your sustainability reporting process by integrating directly and/or providing reporting exports to ENERGY STAR Portfolio Manager, LEED Arc, GRESB, CDP, SASB, GRI, and more. The platform provides customizable dashboards, which allow asset managers, sustainability managers, engineers, and more to monitor individual key performance indicators (KPIs) and create custom views for specific use cases.

To learn more about WatchWire and its capabilities, you can visit our website, blog, or resource library, request a demo, or follow us on LinkedIn, Instagram, or Twitter to keep up-to-date on the latest energy and sustainability insights, news, and resources.