NYC’s Sub-Metering Law: Energy Efficiency in Commercial Buildings

Spreading responsibility for energy efficiency in commercial buildings

commercial-buildings-nyc.jpgNew York City’s Local Law 88 makes it one of the first cities in the nation to require electrical sub-meters to be installed in commercial buildings 50,000 square feet or greater in area, as well as in residential buildings with commercial tenants occupying over 10,000 square feet. Building owners are also required to upgrade their lighting to meet the city’s energy code with new light switches and LED bulbs.

In addition to installing a sub-meter for any tenant occupying 10,000 square feet or more, landlords will be required to deliver those tenants monthly statements showing electricity use. Smaller tenant spaces may share a sub-meter, with electricity allocated according to occupancy percentage.

The law doesn’t go into effect until 2025, giving landlords plenty of time to perform facility upgrades and adjust lease provisions as tenants move out.

The purpose of LL88 is to bring awareness of energy use to the actual end users—the tenants of a building—who often pay a flat rate or one based on square footage, and do not receive a monthly statement showing actual energy use. Depending on the lease agreement, sub-metering could help ensure that tenants pay only for the electricity they use.

Motivation for Conservation

The hope is that knowing how much energy they use will motivate tenants to take an active part in conservation through lighting controls, HVAC upgrades, better insulation, and other efficiency measures.

By passing this law, New York is acting in step with the new Federal energy efficiency law, which will require all Federal buildings to follow an “aligned” model for best practices that divides responsibility for utility use between landlord and tenants in large commercial buildings.

To help New York City building owners, condo associations, and property managers get up to speed on complying with LL88, the non-profit Urban Green Council, offers a downloadable checklist, training webinars, and other educational aids.

According to the Council, LL88 encourages, though does not require, real-time energy consumption data to be provided to tenants. Such data would come from an automated energy management system (EMS), such as as, which connects wirelessly to the local building network or the cloud.

Near-real-time tracking of energy use could help commercial tenants, such as restaurants, retail stores and convenience stores, implement strategies to reduce the amount of electricity used.

The same system could provide additional benefits from managing assets as well as tracking energy use. By monitoring the performance of HVAC equipment at multiple sites, portfolio managers could detect problems early to prevent equipment failures, and ensure comfortable temperature levels while preventing unauthorized adjustments. Incorporating lighting and other equipment controls into an EMS can maintain optimal performance without wasting electricity during downtimes. And the EMS can reduce utility costs by remotely scheduling equipment to keep demand charges low.

For restaurant and C-store chains, compliance with New York City’s LL88 using an asset and energy management system like SiteSage can lead to savings in a number of ways. And since SiteSage is now approved under the NYSERDA RTEM program, there’s an automatic rebate for restaurants, convenience stores, and retailers in NYC.


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