NYC’s Local Law 87: More Than a Path to Compliance

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The Greener, Greater Buildings Plan was enacted in 2009 to increase the energy efficiency of New York City’s large buildings. With its creation came new regulations to help building owners better understand and optimize their annual energy and water usage. Among those regulations was Local Law 87 (LL87), the energy auditing and retro-commissioning law. With the recent passage of the Climate Mobilization Act and Local Law 97 (formerly Int. 1253), many property owners are wondering where LL87 stands and how it relates to Local Law 97 (LL97).

LL87 requires all buildings in New York City that are larger than 50,000 square feet to perform an energy audit and retro-commissioning every ten years. The energy audit, performed by an energy professional who visits the building, gives building owners an evaluation of their building’s energy performance, how effectively their equipment is functioning, and what improvements could be made to reduce energy consumption and increase building comfort. Retro-commissioning is a tune-up for the building to ensure that the equipment is operating as intended.

How LL87 Relates to LL97 (and LL33)

The best way to think about an LL87 audit is that it should provide a roadmap to achieve the carbon emissions targets in LL97. And the retro-commissioning that is required in LL87, if done right, should help capture low-cost carbon savings.

Note that Local Law 87 applies to buildings 50,000 square feet or more, whereas LL97 applies to buildings 25,000 square feet or more. Buildings 50,000 square feet and over are subject to both. Another difference between the laws is that LL87 applies only to the “base building systems” whereas LL97 applies to the whole building, including tenant usage.

And while LL87 and LL97 are both completely separate from Local Law 33 (the New York City ordinance that requires buildings above 25,000 square feet to post an energy efficiency grade at each public entrance beginning in 2020), the required retro-commissioning measures and energy efficiency improvements uncovered in your energy efficiency report will help you increase your ENERGY STAR Portfolio Manager score, and in turn, your building’s city grade.

How to Select an LL87 Provider

For those with limited exposure to energy audits and retro-commissioning, it may seem daunting to find an expert. Fear not! Here’s a list of questions you can ask potential vendors that should allow you to make an informed decision and get the most value out of LL87 compliance and set you up for LL97 compliance.

How long have you been providing LL87 services?

Those who have been providing these services for more than five years will have a strong understanding of the law, how it’s changed, how any proposed changes will impact their current processes, and what actions will produce a real solution.

How quickly can you get my energy audit and retro-commissioning study done?

While you might want speedy action from your provider, be wary of providers that say they can complete everything in just a few weeks. It takes much longer to complete a comprehensive energy efficiency report and retro-commissioning study. To be on the safe side, we recommend that you plan for the whole LL87 audit and retro-commissioning to take at least six months.

Do you have a Professional Engineer (PE) or Registered Architect (RA) on staff?

The proposed changes to LL87 include requiring a Registered Design Professional to sign off on all energy audit and retro-commissioning reports. Should each of the proposed changes get accepted, you’ll want to be prepared. Ensure your provider has a PE or RA on staff to enable compliance.

What is your approach to retro-commissioning and energy auditing?

Some think retro-commissioning and energy auditing are straightforward. But, an experienced retro-commissioning agent or auditor looks at the building, and all of its systems, as part of a living, dynamic being. Fixing one thing impacts other systems, and conversely, not fixing one system can cause problems in others. You should work with a partner who understands building science and can help you plan for the future by approaching the building holistically.

Additionally, your provider should be thorough and fully investigate the building. So if your energy efficiency report comes back with only a few items, your agent may not have been looking as closely as they should. That should raise concerns, especially if you use your LL87 report as a roadmap to LL97 compliance.

Once the LL87 energy audit and retro-commissioning are done, what do you do?

For most providers, the answer will be, “we’re done.” But a comprehensive and holistic provider should be able to guide you to select and implement the right energy and water improvements with an eye towards LL97 compliance. We work with our clients to help them select the highest impact improvements that will not only keep them in compliance but will also increase the performance of their buildings, decrease their carbon emissions, reduce maintenance issues, heighten tenant comfort, and produce energy savings.

I need to install the list of prescriptive measures in LL97. Can you help?

Some providers may combine their LL87 and LL97 prescriptive measures services into one package to streamline the process for their clients. That’s what we plan to do.

What is your approach to high-performance buildings?

Even high-performance buildings need tune-ups. An experienced agent will have worked with all kinds of buildings and systems and should be able to share examples of when they have optimized high-performance systems.

Where Do You Go From Here

If you have questions about energy audits, retro-commissioning, or anything energy-related, Bright Power is always here to help. Our team of experienced auditors and retro-commissioning agents is ready to help you comply and increase the performance of your building. Contact us to speak to an expert today.

FAQS:

When did local law 87 start?

The Greener, Greater Buildings Plan was enacted in 2009 to increase the energy efficiency of New York City’s large buildings. With its creation came new regulations to help building owners better understand and optimize their annual water and energy consumption. Among those regulations was Local Law 87 (LL87), the energy auditing and retro-commissioning law.

What are LL87 requirements?

LL87 requires all buildings in New York City that are larger than 50,000 square feet to perform an energy audit and retro-commissioning every ten years. These periodic energy audits, performed by a professional, give building owners an evaluation of their energy performance, how effectively their equipment is functioning, factors that impact their energy bills, and what improvements could be made to reduce energy usage and increase building comfort.