What NYC Building Owners Need to Know About LL88 Submetering Requirements
As energy efficiency continues to take center stage in New York City's sustainability goals, building owners must stay informed and proactive. One of the key local laws influencing commercial energy management is Local Law 88 (LL88). Enacted as part of the Greener, Greater Buildings Plan (GGBP), NYC Local Law 88 focuses on improving energy use in large non-residential buildings through lighting upgrades and submetering requirements.
With 2025 bringing critical deadlines and increased enforcement, this article from The Cotocon Group, a leader in sustainability consulting services, breaks down everything building owners need to know about LL88 New York, specifically the submetering requirements.
What Is Local Law 88?
Local Law 88 (LL88) was introduced in 2009 as part of New York City’s effort to reduce greenhouse gas emissions and promote energy efficiency in large buildings. The law applies to buildings over 50,000 square feet and certain groups of buildings on the same tax lot that together meet or exceed this threshold.
LL88 mandates two key upgrades:
- Lighting System Upgrades to meet the latest energy code standards.
- Tenant Submetering for large non-residential tenants.
While lighting upgrades are a critical part of compliance, this article focuses specifically on submetering requirements, which are becoming increasingly important for Local Law 88 compliance in 2025.
Understanding LL88 Submetering Requirements
Submetering means installing electrical meters that track energy usage for individual tenants, especially those occupying large spaces. According to LL88 New York, any non-residential tenant space larger than 10,000 square feet must have a submeter installed.
The goal is simple: give tenants the ability to monitor and reduce their energy usage. When tenants understand how much electricity they consume, they’re more likely to adjust their behavior, invest in energy-efficient equipment, and reduce waste.
Who Must Comply with LL88 Submetering?
If you’re a building owner or manager in New York City, here’s who must comply:
- Commercial buildings larger than 50,000 sq. ft.
- Mixed-use buildings where the non-residential portion meets the threshold.
- Campus-style properties (multiple buildings on the same tax lot) that total 100,000 sq. ft. or more.
- Any non-residential tenant space of 10,000 sq. ft. or more.
As of 2025, these requirements are no longer optional. Compliance is mandatory, and failure to meet LL88’s submetering mandates can result in fines and violations.
Why Submetering Matters in 2025
The year 2025 marks a turning point for LL88 New York. Many of the law’s grace periods are ending, and the New York City Department of Buildings (DOB) has committed to ramping up enforcement. Submetering is no longer just a "green" upgrade — it’s now a legal necessity.
Here’s why submetering is so important:
1. Empowers Tenants
When tenants have access to their own electricity data, they’re empowered to control and reduce energy use. Submeters promote accountability and help tenants become partners in sustainability.
2. Improves Building Performance
Submetering helps identify inefficiencies within tenant spaces. Building owners can use this data to improve systems and guide future upgrades.
3. Prepares You for LL97
NYC’s Local Law 97 sets strict carbon emissions limits. Submetering helps monitor tenant energy use, which can impact your building’s total emissions. This makes it easier to stay in compliance and avoid LL97 penalties.
4. Reduces Utility Costs
By understanding how and when energy is consumed, both tenants and landlords can make smarter energy decisions. Over time, this leads to lower utility bills and improved ROI on energy investments.
What Are the Submetering Requirements?
The technical requirements of LL88’s submetering rules are outlined by the Department of Buildings. Here’s a simplified summary:
- One submeter per tenant space ≥ 10,000 sq. ft.
- Submeters must record real-time energy use, typically in kilowatt-hours (kWh).
- The system must have data storage capability and be able to track energy use over time.
- Monthly reports must be generated and shared with tenants.
- Submeters must be installed by a licensed electrician or qualified professional.
- Must comply with all DOB and NYCECC codes.
To avoid delays, owners are advised to consult with a Local Law 88 Consultant Service like The Cotocon Group, which can guide you through equipment selection, professional installation, and documentation.
Steps to Achieve Local Law 88 Compliance in 2025
1. Identify Tenant Spaces That Need Submeters
Start by reviewing your building’s floor plan. Identify all tenant spaces that exceed 10,000 sq. ft. and do not currently have submeters.
2. Hire a Local Law 88 Consultant Service
Working with professionals is essential. The Cotocon Group offers Local Law 88 Consultant Services that include audits, design planning, cost estimation, and project management.
3. Select and Install Submetering Equipment
Choose submeters that meet NYC’s technical specifications. Ensure proper installation by certified professionals.
4. Integrate with Your Building Management System (BMS)
Modern submeters can connect with your BMS or smart energy platforms to provide automated data tracking and reporting.
5. Train Building Staff and Notify Tenants
Educate your property management team and ensure tenants understand the purpose and benefits of submetering.
6. Maintain Monthly Reporting
Provide each tenant with clear, easy-to-understand monthly reports on their energy usage.
Benefits of Working with The Cotocon Group
As a leading Local Law 88 Consultant Service, The Cotocon Group makes Local Law 88 compliance easier and more cost-effective for NYC building owners.
Here’s what you can expect:
- Expert Submetering Planning
We assess your building, identify required spaces, and recommend the right equipment and layout. - Licensed Installation Management
We work with approved electricians and contractors to ensure compliance with DOB regulations. - Documentation and Filing Support
From compliance forms to DOB reporting, we handle the paperwork for you. - Energy Efficiency Insights
Beyond submetering, our sustainability consultants help identify other ways to improve your building's energy performance. - Long-Term Compliance Strategy
We help you integrate LL88 compliance with LL97 and other local laws to create a long-term building sustainability plan.
Common Mistakes to Avoid
Waiting Too Long
The 2025 deadline is firm. Delaying your submetering plan could mean costly violations.
DIY Submetering Installations
LL88 compliance isn’t a DIY project. Always work with qualified professionals to avoid safety and legal issues.
Incomplete Reporting
Failing to share energy reports with tenants could result in non-compliance, even if submeters are installed.
Choosing the Wrong Equipment
Not all submeters meet NYC’s specifications. Choosing incompatible equipment can waste time and money.
LL88 Submetering: A Legal and Environmental Responsibility
Submetering under NYC Local Law 88 is more than a checkbox for legal compliance — it’s a smart investment in the future. When done correctly, it enhances building transparency, improves efficiency, reduces carbon emissions, and prepares you for other local mandates like LL97 New York.
In 2025, compliance isn’t optional. If you’re unsure where to start, a Local Law 88 Consultant Service like The Cotocon Group can walk you through each step and ensure you avoid penalties while improving building performance.
Final Thoughts
Local Law 88 compliance for submetering is an essential responsibility for NYC building owners in 2025. Submetering not only satisfies legal mandates but also brings real benefits to landlords and tenants alike. It’s a practical step toward energy transparency, cost savings, and a greener city.
The Cotocon Group specializes in NYC Local Law 88 consulting and can help you meet all submetering requirements smoothly and affordably. With deep knowledge of LL88 New York and related regulations, our team offers end-to-end solutions to keep your building compliant and future-ready.
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