Nyc Local Law 88

A Brief Guide to NYC Local Law 88: Lighting Upgrades and Sub-Metering

The energy sector is closely observing the consequences of the historic NYC Local Law 88 (LL88) to see what effect it will have. The NYC LL88 requires all commercial structures greater than 50,000 sq. ft. to install submeters by the end of January 1, 2025.

The Greener, Greater Buildings Plan (GGBP) effort, which aims to improve energy efficiency in sizable existing buildings in New York City, includes LL88. One of the first American cities to mandate submetering was New York City.

The New York Public Service Commission (NYPSC) has established stringent regulations to control domestic electrical submetering in the state on the residential side of the equation. The regulations impact how submeters (building owners, real estate management firms, or independent energy resellers) charge for electricity use and safeguard residents.

While certain requirements are specific to the submetering technology itself, others pertain to the procedure a submeter must take before distributing submetered electricity. We, The Cotocon Group, are a dependable energy advisor for NYC Commercial and Residential building owners and tenants and help them perform energy efficiency audits for compliance.

In this article, we help you understand NYC local law 88 and why it mandates lighting upgrades and sub-metering.

What is NYC Local Law 88?

As per NYC local law 88 and its expansions, all areas in residential buildings larger than 25,000 sq. ft. and all areas in non-residential buildings larger than 25,000 sq. ft. must upgrade their lighting to comply with the most recent NYC Energy Conservation Code standards by 2025.

All non-residential buildings bigger than 25,000 sq. ft. are also required by the original statute and its expansions to install electricity sub-meters for each big non-residential tenant area larger than 5,000 square feet and to give monthly energy statements. Both the lighting standards and the sub-metering regulations have a 2025 compliance date.

Meet The NYC Energy Efficiency Standard Code With Lighting Upgrade

Property owners must first ascertain which properties are governed by LL88 to comply with. LL88 generally applies to any property that satisfies one of the following conditions:

  • Two or more buildings that are falling under the same tax bracket. (Summing up to a minimum of 100,000 sq. ft.)
  • Single buildings possessing a minimum floor space of 50,000 sq. ft.
  • Two or more buildings summing up to a minimum of 100,000 sq. ft. (falling under the condominium ownership form)

Property types that fall under occupation groups R-2 and R-3 are exempt from both lighting upgrades and submetering. Still, they must present documentation to the NYC Department of Buildings proving they are exempt.

While exempt from lighting upgrades, houses of worship in occupancy group A-3 are subject to metering and reporting regulations. Small residential properties with 1 to 3 families residing there are completely exempt from LL88. Hence, no exemption report is necessary.

Although there is plenty of time until the 2025 requirement, updating lighting systems earlier has several advantages.
  • Future revisions of the NYC Energy Conservation Code will have stricter standards as it is continually evaluated and updated. As a result, waiting might lead to more expensive upgrades.
  • Upgrades are needed for both tenant spaces and communal areas in LL88.
  • Property owners can schedule lighting upgrades more effectively by starting earlier because upgrades are more expensive and disruptive while tenant areas are occupied.
  • Lighting upgrades can be expensive to complete. However, LL88 permits them to be stretched out over several smaller projects as long as they are finished by January 1, 2025.

It is significant to note that if lighting system components fulfill NYC Energy Code criteria that apply after July 1, 2010, they do not need to be upgraded. The same rule applies to spaces with lighting power densities that comply with the code.

However, this applies only when these spaces are totally segregated from the rest of the building by doors and floor-to-ceiling partitions. Lighting controls are required in several commercial applications under the 2016 NYC Energy Conservation Code revision, as described in section C405.

Moreover, it offers a list of the highest permitted lighting power densities, which vary depending on the kind of occupancy. The NYCECC mandates that at least 75% of lighting systems in residential spaces use high-efficiency lights and fixtures.

Sub-Meter: What Is It?

A sub-meter is an electrical distribution system component that measures power flow within a specific area and allocates electricity costs. Submetering became required with LL88 for all commercial tenant spaces that satisfied one of the following criteria:

  • Rental space with a floor area of over 10,000 sq. ft for two or more people.
  • Rental space with over 10,000 sq. ft of floor area for the same person.

Installing Sub-Meters: When To Do So?

A business tenant’s build-out is the perfect time to install sub-meters since they should be installed continuously, space by space. Usually, the building’s cost is lower with this strategy. If at all possible, meter the whole structure at once.

Installing meters in bulk is substantially less expensive in the long term than doing it space by space, even though it may cause some inconvenience for tenants and need more upfront money.

NYC LL88 Requirement Concerning Sub-Metering & Monthly Electrical Use Statements

According to the law, sub-meters must be put in mixed-use buildings before January 1, 2025. Each tenant must be given the following if the building contains one or more floors with several non-residential components:

⦁ A separate sub-meter
⦁ Shared sub-meter with the floor area comprising rooms for other tenants
⦁ A shared sub-meter covering the entire floor

Each non-residential tenant must get a monthly electrical statement from the boards and building owners detailing the electricity used during the month as determined by the submeter and the charges made.

By January 1, 2025, the Department of Buildings (DOB) must receive a report proving compliance created by a registered and certified authority.


It is significant to remember that LL88 demands a report proving that the work has been finished in addition to lighting enhancements and submetering. The general advice is to use a lighting specialist because the 2016 NYC Energy Conservation Code’s requirements are quite technical in nature.

Moreover, it is crucial to remember that all work must adhere to the NYC Electrical Code. To ensure seamless compliance with NYC local law 88 for energy efficiency, perform energy efficiency audits with The Cotocon Group. Contact the professionals today!