Learn How To Reduce LL97 Risk With Sub-metering
Published on: November 28, 2024

Introduction: Local Law 97 and 88 Require a Forensic Analysis of your Tenant Demographics

Many clients initially believed that Local Law 88 (LL88) was solely focused on lighting upgrades. They assumed that converting most of their spaces to LED lighting meant they were fully compliant—a common misconception within the business community. However, as the deadline approached, it became clear that LL88 compliance extends beyond lighting upgrades. The law also mandates adherence to lighting controlslighting power density standards, and tenant reporting requirements, which many overlooked until the last minute.

Here is a summary of the terms you can click on to view a summary of what they mean:

Local Law 88 Success Story That Speaks for Itself

Real Results, Real Impact

Existing Conditions

Local Law 88

This building features a combination of sub-metered tenants and tenants whose electricity costs are included in their rent. For tenants with electricity bundled into their rent, sub-metering is typically absent, making it harder to track and manage their energy consumption. These non-sub-metered tenants are a key focus of Local Law 88 and Local Law 97, as the lack of accountability for energy usage often results in inefficient practices. Addressing this issue is critical to improving overall energy efficiency and ensuring compliance with these regulations.

Manually read meters upgraded to electronic eMeters

Our team conducted a thorough survey of the tenants in accordance with Local Law 88 (LL88) and Local Law 97 (LL97) guidelines. The existing sub-meters relied on outdated high-voltage CTs and required manual readings. Manual data collection not only increases the risk of human error but also poses challenges for achieving accurate and reliable compliance with LL88 requirements. To meet compliance standards effectively, automated meter readings are strongly recommended over manual methods.

Remote Data Acquistion

sub-metering submetering sub metering local law 88

The building staff played a crucial role in the success of this project by installing a dedicated Modbus data highway. In just a few days, they efficiently ran twisted-pair cabling through 40 floors of electrical closets. This infrastructure allowed our team to remotely configure all meters seamlessly via the Modbus network, connecting them to our centralized data acquisition hub for streamlined energy monitoring and management.

Local Law 88 Reporting Compliance

Microsoft Power BI GreenConnect LC Associates Cutone

Our Submetering Service, powered by our proprietary GreenConnect™ technology, takes energy monitoring to the next level. Every day, our GreenConnect servers collect and analyze the building’s submetering data. This data is seamlessly integrated with tenants’ Local Law 88 (LL88) survey results to generate real-time Carbon Footprint insights. Whether tenants are sub-metered or not, they gain clear visibility into their energy consumption and, most importantly, their impact on New York City’s greenhouse gas emissions, empowering them to take actionable steps toward sustainability.

Local Law 97 Compliance using Sub-Meters

GHG Impact

Building owners are required to report their annual carbon footprint in compliance with Local Law 97. Each building’s greenhouse gas (GHG) emissions limit is tailored to its specific tenant profile. Exceeding this limit can result in hefty penalties of $268 per square foot for each unit of excess emissions.

Our GreenConnect system empowers clients to identify which tenants are surpassing their GHG limits, providing actionable insights to initiate discussions on improving energy efficiency and reducing emissions.

Local Law 97 Beneficial Credits using Sub-Meters

LC Associates A skyscraper with a dollar sign in the center, symbolizing financial growth. Background features a vibrant cityscape with arrows pointing upwards, indicating rising trends. The BE Credit logo is visible in the bottom-left corner. The sky is bright and dynamic. Con Edison Cash Incentives

Local Law 97 introduces the risk of significant fines for buildings that exceed their greenhouse gas (GHG) emissions limits. To address this, the Department of Buildings (DOB) has established a “Beneficial Electrification” policy, which recognizes energy usage from technologies like Cold Climate Heat Pumps (ccHPs) as a way to reduce GHG scores. Buildings that implement ccHPs before 2027 may use the electricity consumed by this equipment to offset their LL97 emissions calculations and avoid potential penalties. Our GreenConnect reporting services, powered by sub-metering data, streamline the process of tracking and reporting Beneficial Electrification to ensure compliance.

Outside Funding: NYSERDA OsEM Program

LC Associates A man in a denim shirt holds a large incentive check alongside an older man in a suit. Both men are smiling, and a group of people in the background claps and cheers. The check reads "LC Associates, LARGE INCENTIVE CHECK, $50,000.00, Business Owner. Con Edison Cash Incentives

Although there is no direct funding specifically for sub-metering services, we successfully offset some compliance costs through NYSERDA’s Onsite Energy Manager Program. This program helps reduce the expense of having an onsite energy manager, enabling compliance studies for Local Laws to identify cost-saving opportunities. For this project, we uncovered and secured funding for Local Law 11 upgradesccHeatPump installations, and lighting controls to date, helping our client achieve compliance while optimizing energy efficiency.

Understanding LL97 and the Carbon Trading Market

BMS Scheduling to lower Local Law 97 fines

To help building owners meet compliance more flexibly, NYC is introducing a carbon trading market, where owners of energy-efficient buildings that emit less than their allowable carbon limits can sell their surplus credits to those who exceed theirs. This market incentivizes energy efficiency and provides a pathway for buildings with high emissions to avoid steep fines while transitioning to compliance.

LC Associates and its GreenConnect Service will be in a unique position to leverage the NYC Carbon Trading market. 

Lighting Power Density

LC Associates Three individuals stand in a polished hallway with wooden walls and a modern decor. They hold various devices related to energy management. The text reads, "We Manage to Make the Most of your Facility’s Energy." The logo "LC Associates" is visible on the left. Con Edison Cash Incentives

Lighting Power Density is defined as the amount of electric power used for lighting over a given area.  

Surveyors will count the amount of lighting in a specific space in your building and then divide it by the square feet of that space. 

The surveyor will also categorize the space into one of the DOB categories (i.e. exam room, general office, kitchen, conference room, etc)

Green House Gas Emissions Limits

Local Law 88 Submetering

The DOB has assigned each space-use type a GHG emissions allowance – exceed the allowance, pay a fine. 

Surveyors will count the amount of lighting in a specific space in your building and then divide it by the square feet of that space. 

The surveyor will also categorize the space into one of the DOB categories (i.e. exam room, general office, kitchen, conference room, etc)

Monthly Tenant Environmental Impact Report

sub-metering invoice

Monthly tenant sub-metering reports must include environmental impact data.

Covered buildings must send a sample environmental impact report to the DOB.  These reports must be given to the tenants each month.  Among other information, the tenant must be made aware of their contribution to green house gas emissions. 

Occupancy and Daylight Controls

Each space must have an occupancy, scheduling or daylighting control.

Occupancy and daylighting controls must meet minimum NYECC specifications.  One of which is that they cannot be overridden by the tenant.  Many controls that we found are able to be overriden.

Space Use Type?

A census of each space type in a building must be taken.

The DOB has assigned Green House Gas emissions limits for each space type.  Building Owners must survey their building and categorize each space into a specific category.  For example an examination room, a laboratory, conference room, general office, etc.

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