Lighting Upgrade Requirements for Local Law 88

Local Law 88 requires large NYC buildings to upgrade interior lighting and install electrical sub-meters in non-residential spaces. While compliance is mandatory, these upgrades also present a chance to modernize building systems, reduce energy costs, and support broader goals like Local Law 97. This article outlines the specific lighting and sub-metering requirements, key exceptions, and strategic upgrades that can unlock additional incentives and long-term value.

NYC Local Law 88 Overview

New York City Local Law 88 (LL88), enacted as part of the Greener, Greater Buildings Plan (GGBP), aims to reduce energy consumption and greenhouse gas emissions in large existing buildings. LL88 specifically mandates lighting upgrades and the installation of electrical sub-meters in non-residential spaces.

The law applies to:

• Covered buildings as defined in Local Law 84 (generally buildings ≥ 50,000 sq ft or multiple buildings on a single lot ≥ 100,000 sq ft)

• Non-residential tenant spaces ≥ 10,000 sq ft

Lighting Upgrade Requirements for Local Law 88

By the compliance deadline (initially January 1, 2025), covered buildings must ensure that all interior lighting systems meet the current NYC Energy Conservation Code (NYCECC) standards.

Key lighting upgrade requirements include:

• Replacement of T12 fluorescent lamps and magnetic ballasts

• Installation of high-efficiency fixtures (e.g., LED)

• Inclusion of automatic lighting controls, such as:

• Occupancy sensors

• Daylight sensors (in daylight zones)

• Time-of-day scheduling controls

• Provision for manual on/off controls in all spaces

• Zoning of lighting systems based on occupancy and function

Lighting systems must also be documented with as-built drawings or manufacturer specifications demonstrating compliance with current code.

Lighting Upgrade Exceptions

Some lighting systems are exempt from full upgrades if:

• They were already installed under a permit that complied with NYCECC at the time

• The system meets or exceeds the 2020 NYCECC or later requirements

• Historical or landmarked properties may apply for a variance or special consideration if compliance would compromise architectural integrity

Additionally, certain systems may be partially exempt if alterations would require major structural changes or would not be cost-effective, though these exemptions require DOB approval and documentation.

Upgrading interior lighting under Local Law 88 presents an opportunity to improve energy efficiency, reduce operating costs, and enhance the overall quality of your building. Now is the time to assess your existing lighting systems, plan targeted upgrades, and take advantage of available rebates and incentives. If you need support evaluating your building or developing a compliance strategy, contact our team today We can guide you through the process and help ensure your upgrades meet both code and performance goals.