Local Law 87
Energy audit and retro-commissioning requirements for NYC buildings over 50,000 square feet. Understand the 10-year compliance cycle, audit scope, and filing process.
What Local Law 87 Requires
Local Law 87 of 2009 (part of the Greener, Greater Buildings Plan) requires buildings over 50,000 gross square feet to undergo periodic energy audits and retro-commissioning (RCx). The law is designed to reduce energy consumption and greenhouse gas emissions from New York City's large building stock.
An energy audit is a comprehensive assessment of the building's energy systems, including HVAC, lighting, hot water, electrical distribution, and building envelope. The audit identifies energy conservation measures (ECMs) and estimates their cost and potential energy savings.
Retro-commissioning is a hands-on process of testing, adjusting, and optimizing the building's existing mechanical and electrical systems to ensure they operate efficiently. Unlike an audit (which identifies opportunities), RCx involves actually fixing operational issues found during the assessment.
Which Buildings Must Comply
Local Law 87 applies to:
- Individual buildings with a gross floor area exceeding 50,000 square feet
- Multiple buildings on a single tax lot that together exceed 50,000 square feet in total gross floor area
- City-owned buildings over 10,000 square feet (under separate city agency requirements)
The building size is based on gross floor area as defined by the NYC Department of Finance. This includes all enclosed space within the building envelope, measured to the exterior walls. Parking garages and mechanical spaces are included in the calculation.
Buildings that are primarily used for manufacturing or industrial purposes may have modified requirements. Consult the DOB for specific applicability questions.
Audit & Retro-commissioning Scope
The LL87 energy audit must meet ASHRAE Level II standards (or equivalent) and cover:
- Base building systems — HVAC (heating, ventilation, air conditioning), domestic hot water, and building envelope
- Lighting systems — Interior and exterior lighting, controls, and daylighting potential
- Electrical systems — Motors, pumps, fans, and electrical distribution
- Energy conservation measures (ECMs) — Each ECM must include estimated implementation cost, annual energy savings, and simple payback period
The retro-commissioning must include a master list of building equipment, operating sequences, and functional performance testing of base building systems. Any deficiencies found must be corrected as part of the RCx process, and corrections must be documented.
Both the audit and RCx reports are filed through the DOB NOW portal. The filing must be completed by a Professional Engineer (PE) or Registered Architect (RA).
Filing Deadlines (10-Year Cycle)
LL87 compliance follows a 10-year cycle, with deadlines based on the last digit of the building's tax block number:
- Block ending in 3 or 8 — Cycle deadline years ending in 2027, 2037, etc.
- Block ending in 4 or 9 — Cycle deadline years ending in 2028, 2038, etc.
- Block ending in 5 or 0 — Cycle deadline years ending in 2029, 2039, etc.
- Block ending in 6 or 1 — Cycle deadline years ending in 2030, 2040, etc.
- Block ending in 7 or 2 — Cycle deadline years ending in 2031, 2041, etc.
Building owners should begin the audit and RCx process at least 12 months before their filing deadline to allow adequate time for the assessment, analysis, and report preparation. Energy audits alone typically take 2-4 months; combined with RCx, the full process can take 6-12 months.
Penalties & Relationship to LL97
Failure to comply with Local Law 87 results in:
- DOB violations for failure to file the required energy audit and retro-commissioning reports
- Civil penalties for non-compliance, with fines that accumulate for continued failure to file
- Increased scrutiny under related energy laws, particularly Local Law 97 (carbon emission limits)
Local Law 87 works hand-in-hand with Local Law 97, which imposes carbon emission limits on large buildings starting in 2024, with stricter limits in 2030. The energy audit required by LL87 helps building owners identify the improvements needed to meet LL97's emission caps and avoid the substantial LL97 penalties ($268 per metric ton of CO2 over the limit).
Completing your LL87 audit proactively gives you a roadmap for the capital improvements needed to stay under LL97 emission limits.
How KomplyOS Helps
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Frequently Asked Questions
Which buildings must comply with Local Law 87?
Local Law 87 applies to all NYC buildings over 50,000 gross square feet. This includes individual buildings over 50,000 sq ft and multiple buildings on the same tax lot that together exceed 50,000 sq ft. City-owned buildings are also subject to the law.
What is the difference between an energy audit and retro-commissioning?
An energy audit is a systematic assessment of a building's energy use that identifies opportunities to reduce consumption and improve efficiency. Retro-commissioning (RCx) is a hands-on process of testing and optimizing a building's existing mechanical systems — HVAC, lighting controls, and building automation — to ensure they operate as intended. Both are required under LL87.
How often must LL87 compliance be completed?
Local Law 87 operates on a 10-year cycle. Buildings must complete both an energy audit and retro-commissioning and file the results with the DOB once every 10 years. The deadline year is determined by the last digit of the building's tax block number.
Who can perform LL87 energy audits?
Energy audits must be performed by a Professional Engineer (PE) or Registered Architect (RA) licensed in New York State. The auditor should have experience in energy systems and building performance analysis. Retro-commissioning must be performed by or supervised by a registered design professional.
How does Local Law 87 relate to Local Law 97?
Local Law 87 (energy audits) and Local Law 97 (carbon emission limits) are complementary. LL87 helps building owners understand their energy consumption patterns, while LL97 sets hard caps on carbon emissions. Completing an LL87 energy audit is an excellent first step toward identifying the capital improvements needed to meet LL97 emission limits.
Related Compliance Guides
Local Law 152 — Gas Piping Inspections
Periodic gas piping inspection requirements.
Local Law 11 — Facade Inspections
FISP requirements for buildings over 6 stories.
Local Law 26 — Elevator Inspections
CAT1 and CAT5 elevator testing schedules.
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