With NYC’s Local Law 97 just around the corner, most owners are working feverishly to mitigate their carbon emissions and potential fines. But don’t forget about Local Law 88 (LL88)! LL88 requires buildings to upgrade their lighting and install submetering by January 1, 2025. Haven’t thought about LL88 yet? Don’t panic, there’s still time to get into compliance.
About LL88
LL88 generally applies to buildings that are above 25,000 square feet, or where 2+ buildings on the same tax lot together exceed 100,000 square feet. Refer to the LL88 Covered Buildings List (CBL) if you’re not sure about your buildings.
Deadlines:
- Installation must be finished by January 1, 2025
- Reports due to DOB by May 1, 2025
Fines
Noncompliant buildings will receive fines starting from $1,500-$3,000, with an extra $500 for every commercial tenant subject to the law. These fines will be levied annually, and there is a chance that noncompliance with LL88 could also impact your ability to pull future permits.
And that’s not all. For properties subject to LL97 Prescriptive Pathway installing the 13 Prescriptive Energy Conservation Measures (PECMs), noncompliance with LL88 lighting requirements will also result in a LL97 violation, adding an extra $10,000-$20,000 per building every year to your fines.
Lighting Requirements
Buildings are required to upgrade their lighting to comply with the latest version of New York City Energy Conservation Code (NYCECC) in effect at the time of installation. Already upgraded your lighting to meet code? As long as it was installed after July 1, 2010, your upgrades should be LL88- compliant.
For multifamily properties, the lighting requirements only apply to common area spaces, not to the individual dwelling units. For commercial buildings, lighting requirements apply to all spaces within a covered building.
Submetering Requirements
Buildings are required to submeter certain types of commercial tenant spaces. What counts?
- A tenant space larger than 5,000 gross square feet on one or more floors let or sublet to the same person; or
- A floor larger than 5,000 square feet consisting of tenant spaces let or sublet to two or more different persons
For multifamily buildings, submeters are only required for mixed-use properties with commercial spaces that are over 5,000 square feet in size. Submeters are not required for dwelling units or for common areas.
Reporting Requirements
Owners of covered buildings must hire a Registered Design Professional (RDP), Licensed Master Electrician, or Licensed Special Electrician to verify the work installed and submit a report to DOB by May 1, 2025.
Already have submeters installed for commercial tenants? Or already have code-compliant lighting? You’re not out of the woods yet, you will likely still need to have an RDP verify the work and submit to DOB that you are already compliant.
Don’t pay fines! Reach out to your Bright Power Account Manager for more information on LL88 for your buildings, or email info@brightpower.com to get connected.
Disclaimer: All guidance provided by Bright Power is based on the best available information from NYC Department of Buildings (DOB) Local Law 88 guidance. Bright Power is not responsible for any incorrect guidance.