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NYC Local Law 97 (LL97) in Scaler

How Scaler identifies, maps, and evaluates compliance with New York City Local Law 97 (LL97), a Building Performance Standard.

Purpose of this article

This article explains how Local Law 97 (LL97) is represented in Scaler, including which buildings are considered in scope, how emissions performance is evaluated, and how LL97 analytics can be used to support compliance monitoring and decision-making.


Overview

Building Performance Standards (BPS) are regulations that require large buildings to meet progressively stricter energy or carbon emissions limits over time.

Local Law 97 (LL97) is New York City's Building Performance Standard. It mandates greenhouse gas (GHG) emissions reductions for large buildings and penalizes owners that exceed defined emissions thresholds.

Scaler supports LL97 by calculating emissions intensity, assigning applicable thresholds based on property type, and visualizing compliance status for eligible assets.

Tip: The easiest way to view LL97 compliance for your portfolio is the Local Regulations page in Analytics Portal. This article explains the methodology behind what you see there. See Using the Local Regulations page.


How LL97 relates to LL84

LL97 and LL84 both apply to large NYC buildings β€” it's easy to confuse them. They do different things and work together.

  • LL84 is the benchmarking layer β€” owners submit annual energy and water use data to the NYC Department of Buildings by May 1 each year. That data feeds LL97 compliance calculations.
  • LL97 is the performance layer β€” it sets emissions intensity caps by property type and penalizes buildings that exceed them.

LL84 came first (in effect since 2012). When disclosure alone wasn't moving the needle on NYC's climate goals, LL97 was added in 2019, with enforcement beginning in 2024.

In Scaler, LL97 compliance appears in the Building Performance Standards section of the Local Regulations page, and LL84 reporting obligations appear in the Benchmarking section.


Which buildings does LL97 apply to?

Local Law 97 applies to buildings that meet one of the following criteria:

  • A single building exceeding 25,000 gross square feet
  • Two or more buildings on the same tax lot that together exceed 50,000 gross square feet
  • Two or more buildings owned by a condominium association governed by the same board that together exceed 50,000 gross square feet

Applicability criteria, emissions intensity thresholds, and penalty rates are set by the NYC Department of Buildings and may be revised over time β€” for the authoritative current source, see the NYC Department of Buildings LL97 page.

Scaler's current scope

Scaler currently evaluates LL97 applicability only for single buildings exceeding 25,000 gross square feet. Tax lot aggregation and condominium ownership structures are not automatically evaluated at this time.


How Scaler determines LL97 applicability

Scaler evaluates whether an asset is subject to LL97 using location, size, and property type criteria.

Location requirements

An asset is considered subject to LL97 if:

  • Country = United States, and
  • Postal code corresponds to New York City:
    • Manhattan: 10001–10292
    • Staten Island: 10301–10314
    • Bronx: 10451–10475
    • Brooklyn: 11201–11256
    • Queens: 11354–11697

If Postal code is unavailable, Scaler attempts to infer location from the City field (e.g., "New York", "Brooklyn", "Bronx").

Size requirements

LL97 applies only if the asset's Gross floor area exceeds 25,000 square feet.

Building Unit requirements

Why Building Units are required

LL97 emissions intensity thresholds vary by property type. A single building can contain multiple property typesβ€”for example, retail on the ground floor and residential on upper floors. Each property type has a different LL97 threshold.

Building Units allow Scaler to:

  • Assign property-type-specific thresholds to different portions of a building
  • Calculate weighted thresholds for mixed-use buildings based on the floor area of each use

Coverage requirement

Building Units must collectively cover 100% of the asset's GFA – Tenant area. Without complete coverage, Scaler cannot calculate LL97 compliance.

Each Building Unit requires:

  • Property type that is ESPM-aligned (determines applicable LL97 threshold)
  • Unit floor area (used for weighted calculations in mixed-use buildings)

To verify which property types are ESPM-aligned, see Property-type mapping (GRESB, CRREM, ULI, ESPM).


How LL97 compliance is calculated

Single-use buildings

For assets with a single property type, Scaler applies the LL97 emissions intensity threshold corresponding to that property type.

Mixed-use buildings

For assets with multiple property types, Scaler calculates a weighted emissions intensity threshold based on each Building Unit's floor area and property type.

WEIGHTED_TARGET = Ξ£(UNIT_AREA Γ— LL97_THRESHOLD_FOR_UNIT_TYPE) Γ· Ξ£(UNIT_AREA)

This ensures mixed-use buildings are evaluated proportionally across their constituent uses.

Compliance determination

Scaler compares the asset's actual emissions intensity to its applicable LL97 threshold:

  • Actual performance: ghg_emissions_intensity_kgco2e_m2_yr
  • Target limit: LL97 emissions intensity threshold (single or weighted)

Result categories:

  • Compliant β€” Actual emissions are below the threshold
  • Non-compliant β€” Actual emissions exceed the threshold
  • Missing data β€” Required data is missing or incomplete

Civil penalty: Non-compliant assets accrue a civil penalty of $268 per metric ton of CO2e above the applicable threshold. Penalty rates are set by the NYC Department of Buildings and may be revised β€” for the authoritative current rate, see the NYC Department of Buildings LL97 page.


Setting up LL97 tracking

Required data

To calculate LL97 compliance, the following fields must be populated:

Asset-level fields:

  • Country
  • City
  • Postal code
  • Gross floor area

Building Unit fields:

  • Property type (must be ESPM-aligned)
  • Unit floor area

Recommended:

  • Clear Building Unit names for easier identification
  • Confirmation that Building Unit totals equal GFA – Tenant area

Configuring Building Units

Navigate to: Data Collection Portal β†’ Asset β†’ Building Units

For each Building Unit:

  1. Enter Property type (must be ESPM-aligned to determine LL97 threshold)
  1. Enter Unit floor area (used for weighted threshold calculations)
  1. Ensure all Building Units collectively cover 100% of GFA – Tenant area

To verify which property types are ESPM-aligned, see Property-type mapping (GRESB, CRREM, ULI, ESPM).

For more detail on filling in Building Unit fields, see Building units: Setting up & entering data.

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Viewing LL97 compliance status

Local Regulations page (recommended)

Navigate to: Analytics Portal β†’ Portfolio β†’ Regulatory β†’ Local Regulations

The Building Performance Standards section shows portfolio-level LL97 compliance status, estimated penalty exposure, and year-by-year detail for each in-scope asset. For a full walkthrough, see Using the Local Regulations page.

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Asset List view

Navigate to: Analytics Portal β†’ Portfolio β†’ Asset List

The BPS: LL97 column displays compliance status for all applicable assets in your portfolio.

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Custom pathway analysis

Separate from the LL97 compliance status above, you can configure custom pathways in the Roadmap Tool (for example, a custom LL97 trajectory) and view asset performance against them.

Navigate to: Analytics Portal β†’ Portfolio/Asset β†’ Roadmap Analysis β†’ GHG Emissions

Important: Custom pathways and planned Roadmap measures are independent from the LL97 compliance check shown on the Local Regulations page. The BPS compliance status reflects an asset's actual emissions vs. its statutory LL97 limit only β€” it does not yet factor in planned measures from the Roadmap Tool. To compare a planned-retrofit pathway against the LL97 limit, use the Roadmap Analysis GHG chart visually.

To learn how to set up custom pathways, see Setting and viewing targets, pathways & benchmarks.

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Troubleshooting & common issues

If LL97 compliance does not appear for an asset, it is typically due to one or more of the following:

Incomplete Building Unit coverage

Building Units do not collectively cover 100% of GFA – Tenant area. LL97 thresholds cannot be assigned without full coverage.

Missing or invalid location data

One or more of the following fields is missing or inconsistent: Country, City, or Postal code. If Postal code is unavailable, verify the City field includes recognizable NYC borough names.

Asset does not meet size threshold

The asset's Gross floor area is less than 25,000 square feet, or qualifies only under tax-lot aggregation or condominium ownership criteria (not currently evaluated by Scaler).

Building Unit property types not ESPM-aligned

Building Units must use property types that are ESPM-aligned and can be mapped to LL97 thresholds. To verify which property types are ESPM-aligned, see Property-type mapping (GRESB, CRREM, ULI, ESPM).

Missing emissions intensity data

ghg_emissions_intensity_kgco2e_m2_yr cannot be calculated due to incomplete energy or emissions data. Verify that consumption and emissions data have been entered for the asset.

Asset marked inactive for analytics

Assets marked as inactive in analytics are excluded from LL97 calculations and visualizations. Verify the asset's active status in the Data Collection Portal.


Known limitations

  • Tax-lot aggregation (multiple buildings on the same tax lot totaling β‰₯50,000 sqft) and condominium ownership structures (β‰₯50,000 sqft total) are not currently evaluated. Only single buildings β‰₯25,000 sqft are detected.
  • BPS compliance projections currently reflect business-as-usual emissions only. Planned measures from the Roadmap Tool are not yet factored into projected compliance status or penalty estimates.
  • LL97-specific emission factors are not yet applied; calculations currently use location-based (CRREM) emission factors. For electricity-heavy or steam-heated NYC buildings this can overstate emissions vs. LL97's published methodology, so penalty estimates are directionally accurate but may vary.
  • Some Scaler energy subcategories don't have an LL97-published factor and use fallback values for those meters.

Additional resources

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