The requirement
NYC Admin Code §28-320.3.7 requires the annual building emissions report to be prepared by a registered design professional, and DOB's rule carries the requirement into the filing mechanics (1 RCNY §103-14(b)). In New York that means a licensed professional engineer (PE) or registered architect (RA). The report is submitted through DOB's BEAM portal with the professional's attestation, alongside the filing fee — $210 simple, $615 complex (1 RCNY §101-03).
The same discipline extends to penalty mitigation: a Good Faith Efforts submission requires professional review, with the reviewer's license captured and an attestation form signed in the portal (DOB Penalty Mitigation User Guide v3).
The structure of the law is deliberate. The city is not auditing every utility bill in every filing; it is requiring a licensed professional to stand behind each one, with their license as the stake.
What the certifier actually reviews
A professional who signs an LL97 report is attesting to a chain of specific, checkable claims:
| Property types & floor area | The building's uses are mapped to the correct property-type factors and the gross floor area is right — the limit is factor × area, summed across uses (1 RCNY §103-14(d)(2), Equation 103-14.1), so an error here moves the cap directly. |
|---|---|
| Twelve months of energy data | The utility data is complete for the calendar year — every fuel, every meter, no gaps. A missing fuel understates emissions and produces a false verdict. |
| Coefficients | Energy converts to tCO2e with the adopted coefficients (1 RCNY §103-14(d)(3)) — not draft-rule values, not a spreadsheet inherited from last year. |
| Deductions & evidence | Any REC, EV-charging, or beneficial-electrification deduction (1 RCNY §103-14(d)(4)) is backed by its evidence requirements. |
| The arithmetic | The computation itself — limit, reported emissions, and any estimated maximum exposure under (§28-320.6) — is reproducible from the inputs. |
Why formula lineage matters
Here is the practical problem: a certifier handed a PDF of pasted numbers cannot verify any of the above without redoing the work. A static spreadsheet with hard-coded values is an assertion, not an argument. Professionals respond to that rationally — they either decline, re-derive everything at their hourly rate, or sign with less scrutiny than anyone should want on a document with six-figure estimated exposure attached.
The alternative is a package built for verification: every displayed figure traceable to its source. A workbook whose cells contain live formulas — utility quantities × cited coefficients → emissions; floor areas × cited factors → limit; the difference × $268 → estimated maximum exposure — lets the professional click any number and follow it back to the source data. A report that cites each constant to the rule text (1 RCNY §103-14(c)(3), (d)(3)) lets them check the inputs against the law in minutes instead of days.
Cross-checks close the loop: comparing the filing's underlying data against the building's public Local Law 84 benchmarking record catches transposed meters, missing fuels, and floor-area drift before a certifier — or an auditor — does.
What this means for owners
Choose your preparation process for the certifier's benefit, not just the deadline's. A package a PE or RA can verify quickly is one that gets certified quickly — and one that stands up if DOB ever looks twice. Ask of any filing package: can the professional trace every number? Are the constants cited to (1 RCNY §103-14) and (NYC Admin Code §28-320)? Is the estimated exposure labeled as an estimate, with the calculation shown?
If the answer is no, the certification step — the one step you cannot skip — becomes the bottleneck of the whole filing.