New York City's Local Law 88 (LL88), enacted as part of the Greener, Greater Buildings Plan (GGBP), aims to enhance energy efficiency in commercial and industrial buildings across the city. This legislative package seeks to improve energy and water efficiency across the city's largest buildings. Compliance with LL88 is crucial to avoid penalties, reduce energy costs, and promote sustainability.
What is Local Law 88?
Local Law 88 mandates significant improvements in two key areas:
Lighting System Upgrades: Buildings are required to update lighting systems to comply with the latest New York City Energy Conservation Code (NYCECC). This involves installing energy-efficient lighting solutions, such as LED fixtures and automated lighting controls, designed to significantly reduce energy consumption. We believe much of this has been completed as fluorescent lighting continues to be phased out in availability as well as the continued reductions in the cost of LED lighting.
Electrical Sub-Metering: The law requires electrical sub-metering for non-residential tenant spaces larger than 5,000 gross square feet, and floors exceeding 5,000 gross square feet that are occupied by multiple tenants. This sub-metering enables precise monitoring of energy usage, empowering tenants to actively manage and lower their consumption. The tenants must also be given monthly energy usage statements so they can monitor and manage their own consumption.
We believe that the complexity of installing sub-meters in tenant spaces have introduced many challenges to landlords as it becomes increasing cost prohibitive to properly segregate energy in multi-tenant spaces. Depending on the type of submeters being installed at each location, additional complexities can arise from either manual (physical) meter reads vs. an automated integrated data collection system.
Building Sizes Affected by Local Law 88
Local Law 88 applies to the following building categories:
Buildings exceeding 25,000 gross square feet.
Two or more buildings on the same tax lot collectively exceeding 100,000 gross square feet.
Condominium buildings exceeding 100,000 gross square feet, managed collectively.
Local Law 88 (LL88) Compliance Checklist:
Lighting Upgrades:
- Conduct a lighting audit (interior and common areas)
- Identify any fixtures that might not be meeting the NYCECC guidelines
- Upgrade lighting based on available funding and document upgrades for DOB inspections
Tenant Sub-metering:
- Inventory all tenant spaces that are greater than the 5,000 SQFT threshold
- Develop a scope of work for the electrical sub-meters needed needed for each tenant
- Integration of data for simplified data collection and report development for the tenant(s). This process is crucial for our customers as they ultimately seek to reduce the engineering and labor effort to provide reports to their tenants. Our approach is to provide access directly to each tenant to the centralized dashboard, which will provide live metering metrics to each tenant.
- Deliver usage reports to each tenant and maintain records of compliance
Coordination with Local Law 97
Local Law 88 complements Local Law 97, which sets stringent greenhouse gas emission limits for buildings over 25,000 square feet. By implementing LL88's requirements, building owners directly support compliance with Local Law 97 through reduced energy consumption and improved operational efficiency. Effective lighting upgrades and accurate sub-metering under LL88 provide essential data and infrastructure for meeting Local Law 97's emissions targets, helping building owners avoid substantial fines related to exceeding emissions limits.
Implications for Commercial and Industrial Buildings
Cost and Energy Efficiency
Upgrading lighting systems under LL88 can drastically reduce electricity consumption, offering substantial financial benefits through reduced energy bills and available incentives.
Tenant Engagement
Electrical sub-metering fosters greater awareness among tenants about their individual energy use, encouraging proactive energy management and cost reduction. As LL88 and LL97 merge to become the city's targeted carbon reduction strategy, it will also benefit each landlord and tenant to continue to meter other resources such as chilled water, heating water, steam and natural gas supply to their tenants. Although this is not yet a requirement, large high rises with central plants might look to invest in these additional energy resource meters.
Penalties and Compliance
Non-compliance carries considerable penalties, including:
Annual fines of $1,500 for failure to submit required compliance documentation.
Additional penalties of $500 per tenant space lacking proper sub-meter installation.
Building owners must complete upgrades and installations by January 1, 2025, and submit compliance reports by May 1, 2025.
Steps Toward Compliance
Lighting Audits and Upgrades: Conduct comprehensive audits to identify outdated systems and implement necessary improvements.
Sub-meter Installation: Collaborate with certified professionals for efficient sub-meter installations.
Tenant Communication: Engage tenants with clear information on sub-metering benefits and energy-saving strategies.
Documentation and Reporting: Maintain accurate records of compliance activities for efficient reporting and documentation.
Conclusion
Local Law 88, in tandem with Local Law 97, provides building owners a strategic opportunity to significantly enhance energy efficiency, meet regulatory obligations, and optimize building performance. Timely compliance not only prevents costly penalties but also contributes to the long-term sustainability and competitiveness of commercial and industrial properties in New York City.
Link to Local Law 88 (LL88) through nyc.gov : https://www.nyc.gov/site/buildings/codes/ll88-lighting-system-upgrades-sub-meter-installation.page
To learn more about how Emergent Metering can support you with complying with LL88 and LL97, reach out to us at sales@emergentenergy.us