Local Law 88 Importance

The Importance of Lighting Upgrades and Sub-Metering Under Local Law 88

New York City is prioritizing sustainability and aiming to generate at least 50% renewable energy by 2030. The city is also looking forward to bringing down its emission levels by 80% by 2050. Since it is home to multiple buildings, authorities have introduced strict laws to initiate targeted efforts toward achieving these goals. One such regulation is NYC Local Law 88, which attempts to improve lighting efficiency in non-residential buildings. Delve deeper into this article to discover the important aspects of this particular law dedicated toward fostering a greener and more sustainable future in NYC.

An Overview of Local Law 88

LL88 concerns mixed-use residential buildings with an area of more than 25,000 square feet. The requirements under this specific law include:

  • Upgrading common area lighting according to the latest NYC energy code
  • Installing sub-meters for non-residential tenant space of more than 5,000 square feet
  • Submitting monthly power-use statements to sub-metered tenants

The compliance period begins on 1 January 2025. However, building owners need to design a specific compliance path to reduce inconvenience for tenants and residents. 

Required Upgradation of Lighting Systems

Non-residential lighting comprises around 18% of energy use and emissions from NYC properties. Due to the lack of awareness regarding energy patterns, tenants in large buildings often end up consuming an increased amount of electricity. 

Advanced lighting technology has made it possible to reduce energy consumption through more efficient systems. Upgrading lighting equipment will translate into operational savings for businesses and promote sustainability at the same time. 

This requirement of upgrading the lighting systems is mentioned in Article 310. According to this article, the covered buildings under LL88 lighting requirements include:

  • All buildings over a gross area of 25,000 square feet
  • Two or more properties exceeding 100,000 square feet on the same tax lot
  • Condominium properties under the same managerial board collectively going beyond 100,000 gross square feet

Under this requirement, property owners should install new lighting systems or modify the existing ones to meet the current standards. Upgrades should take place in lighting controls. Interior and exterior equipment, exit signs, and more. 

Property owners will need to present a compliance report to the department. A licensed electrician or a registered design professional is only eligible to prepare the report. This particular report validates compliance and completion with NYC Electrical Code standards. 

Electrical Sub-Meter Installation in Tenant Spaces

A large number of buildings depend on one meter to track their electricity consumption. As a result, they end up billing non-residential tenants on the basis of a standard rate. So, properties don’t consider the actual consumption of tenants before charging them. 

Individual tenants might prefer to reduce their power consumption. But, it is only possible if they have an overview of their usage patterns. Under LL88, building owners will have to make this information available to tenants by installing sub-meters. 

Individual tenant submetering is compulsory for all buildings billed through rent inclusion. Properties with floor plates wider than 10,000 square feet will also have to follow this requirement. Some establishments might need to submeter the entire floor to provide adequate information. 

All tenants with sub-meters must get monthly statements of their energy consumption. These statements should clearly define their charges. If it’s a space with a shared sub-meter, the statements will reveal the percentage of the area leased by the tenant. 

Why Should You Opt for Lighting Upgrades Now?

The deadline for complying with the LL88 requirements does not come until 2025. But it’s a smart move for property owners to opt for lighting upgrades from now. If you are asking why, here are some reasons:

  • The authorities are constantly evaluating the law and modifying it. Therefore, the future regulations under the NYC Energy Conservation Code are likely to be stricter. As a result, upgrading your lighting systems according to the new requirements can be a more expensive affair. 
  • Local Law 88 specifically revolves around installing upgrades in tenant spaces and shared areas. Property owners should begin earlier because it will be most cost-effective with already occupied tenant areas. 
  • Upgrading the overall lighting system of your building can be highly expensive. But you can divide the installations into multiple smaller projects if you start now. As long as you can complete all the upgrades by 2025, you can segment the installations into as many parts as you want. Therefore, you won’t have to bear high upfront costs at a time. 

Remember that you don’t have to opt for upgrades if certain lighting system components fulfil the Building Code’s criteria in NYC. Upgrades are also not necessary for properties with lighting-power densities adhering to the code. However, doors and other partitions should completely separate the tenant and shared spaces from the remaining portion of the establishment. 

According to Section C405 updates in 2016, lighting controls are a necessity for commercial usage. Additionally, this section highlights the highest power densities for lighting systems in different properties. But, these densities will differ according to the type of occupancy. 

Similarly, there are rules regarding the usage of high-efficiency fixtures and lights. In residential areas, at least 75% of the lighting systems should have highly efficient fixtures. 

Planning Meter Upgrades for LL88 Compliance

The need for submetering is compulsory when the entire establishment uses one Con Edison meter. It is also applicable if different building portions have individual meters. Moreover, it is essential to divide your establishment into multiple portions according to the stipulated parameters of the NYC Building Code

Installing meter upgrades in tenant spaces can be highly disruptive. Therefore, a planned approach is necessary for it. Moreover, waiting for the approval of a phased upgrade is smart for enabling building owners to plan upgrades after tenants move out. 

Both manual and automatic meters are available to comply with Local Law 88. While manual meters are less expensive, you will find them time-consuming and tedious to operate. Unless tenants are proficient in reading manual meters, they won’t be practical choices for your property. 

Even though automatic meters are expensive, they are worth the investment because of their easy-to-use nature. You can access these meters even from a distance. 

Sub-metering won’t directly help in saving energy. But, with easily accessible power usage data, tenants will become more conscious. Large renters will save more power with separate meters because they want to save on utility bills as much as possible. 

Conclusion

Investing in lighting and sub-metering upgrades is not just about complying with Local Law 88. It also helps in bringing down power usage and carbon emissions. But, installing these upgrades requires professional expertise. That’s where The Cotocon Group will come to your rescue. Our expert engineers and consultants will help you install these upgrades while causing minimal disturbances to tenants and residents. So, contact us today!

FAQs:

What is the last day for complying with LL88 requirements?

All NYC property owners should comply with LL88 mandates by 1 January 2025. 

What is the penalty for LL88 non-compliance?

Building owners might have to bear hundreds or thousands of dollars of fines for LL88 non-compliance. The exact penalty will depend on the extent of the violations and the dimensions of the property. Remember that multiple violations trigger cumulative fines and severely impact the total property budget.