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Local Law 84 and 87: A Quick Guide for NYC Building Owners

Updated: May 24, 2023

Energy Benchmarking is the practice of measuring how much energy a building consumes and comparing that against other buildings. In 2009, the New York City government implemented Local Law’s 84 and 87 to gather such data. Specifically Local Law 84, also known as the Benchmarking Law, requires buildings it covers to submit yearly data on energy and water usage. Local Law 87 requires buildings to carry out energy audits and retro-commissioning while submitting energy efficiency reports every 10 years.

Local Law 84 (LL84) Requirements

One of the earliest benchmarking laws and the first to be implemented in the country, LL84 requires all buildings larger than 50,000 square feet to annually benchmark their energy and water usage. The law encompasses almost 13,000 private properties and roughly 2,350 city owned properties.

In 2016, LL84 was amended through LL133 to require buildings of 25,000 square feet to benchmark their energy consumption, adding roughly 10,000 properties to the benchmarking data system, covering almost 60 percent of the overall square footage in New York City. All buildings under LL84 are required to submit energy consumption data but water consumption data is not required unless the property is equipped with an automatic water meter for at least a full calendar year before the data submission date.

Local Law 87 (LL87) Energy Audits and Retro-Commissioning

Energy Audit

An energy audit under LL87 is an analysis of a building's energy equipment, systems, and operations that identify cost-effective options to save energy and then recommend energy-saving strategies. The recommendations in an audit include new, better, and smarter equipment that typically involves a capital investment. However, LL87 does not require property owners to implement the recommendations.


Retro-Commissioning is the testing and re-tuning of systems in an existing building to improve energy efficiency in systems such as HVAC control, piping insulation, and the calibration of light sensors. The focus of retro-commissioning is fixing the systems that already exist. Unlike energy audits with LL87, retro-commissioning findings will require property owners to correct issues found during these tests.

All base building energy systems are covered in the energy audit and retro-commissioning including:

  • HVAC

  • Electrical and Lighting

  • Domestic Hot Water

  • Building Envelop

  • Conveying Systems

Am I Exempt from an LL87 Energy Audit?

There are 3 possible ways you can achieve exemption status from an energy audit:

  • If the building has received an EPA Energy Star for at least 2 of the 3 years preceding the filing of the building’s energy efficiency report.

  • If the building has received LEED certification 4 years prior to the filing of buildings EER

  • If the building is considered a “simple building” (lacks central A/C or has a system that cools less than 10% of an indoor area) and has implemented 6 of the 7 energy and water efficiency elements written in the law

Submitting Benchmarking Data

Benchmarking data will be collected through the Energy Star Portfolio Manager, which is an online tool developed by the EPA. This tool requires detailed building information upon initial setup, but when the information is stored, the yearly submittals are very simple.

When gathering your energy and water consumption data, the simplest ways to do this are to contact your corresponding utility companies, as most of these companies provide aggregated energy consumption data.

Final Thoughts

There are quite a few different things to understand pertaining to LL84 and LL87, so it is advisable to contact someone that can assist you with professional guidance to ensure you are following all guidelines set forth within each law. Working with a specialized engineering firm will assure that you are compliant in all areas of each law.

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