What Specific Energy Efficiency Standards Must Buildings Meet Under LL84

 

 

You may know LL84 exists—but do you know exactly what your building has to prove? For commercial property owners and managers in NYC, Local Law 84 (LL84) is more than just another city regulation—it’s a direct call to action. This benchmarking law requires that buildings over 25,000 square feet submit detailed reports on their energy and water use every year. But simply filing isn’t enough. Understanding what standards your building must meet, and how compliance is measured, is the difference between staying ahead or falling behind on sustainable building practices. 

At its core, LL84 is about transparency and accountability. It uses tools like the ENERGY STAR Portfolio Manager to track building energy consumption and help NYC move toward a more energy-efficient future. For owners and managers, this means aligning operations with both the NYC building code and sustainability goals. The law doesn’t just demand data—it expects that data to show meaningful, measurable performance. If your building isn’t already optimized for energy efficiency, LL84 could expose costly inefficiencies. 

This blog breaks down the specific energy efficiency standards that LL84 expects your building to meet, and how to stay in full building compliance. Whether you're already benchmarking or just reviewing past submissions, we'll help you understand what matters most in your reports—and how to improve them. Stay tuned as we unpack the essentials and show you how to meet the requirements before the next deadline hits. 

 

What LL84 Actually Requires of Your Building 

Understanding the expectations of Local Law 84 means looking beyond simple compliance. Benchmarking isn’t just about uploading data—it’s about what that data says, how it’s collected, and how it's used to evaluate your building’s performance. Below, we break down the key standards your building is expected to meet under LL84. 

 

1. Use of ENERGY STAR Portfolio Manager 

All benchmarking data under LL84 must be entered into the ENERGY STAR Portfolio Manager, a free online tool developed by the EPA. It normalizes energy and water data, enabling performance comparisons across buildings of different sizes and uses. 

What this means for your building: 

• You must report 12 months of utility data for all energy types: electricity, gas, steam, oil, and water. 

• Your building receives a 1–100 ENERGY STAR score (if eligible). A score of 75+ is considered high-performing. 

• Even if your building isn't eligible for a score, the site’s source EUI (Energy Use Intensity) is still used to assess performance. 

Why it matters:
The Portfolio Manager is the city's central tracking tool. Low scores won’t lead to immediate penalties, but they signal inefficiency and put your property on the radar for future emissions caps. 

 

2. Annual Submission Requirements and Deadlines 

Every year, buildings over 25,000 sq ft must submit benchmarking data by May 1st. The submission must cover the entire previous calendar year. 

Compliance checklist: 

• Submit by May 1 using the correct property ID from the NYC Covered Buildings List. 

• Ensure utility data covers January 1 to December 31 of the prior year. 

• Include all meters and relevant building uses (e.g., retail, office, residential units). 

Penalties for non-compliance: 

• $500 per quarter for late or incomplete submissions. 

• Up to $2,000 per building annually. 

Tip: Automate data uploads via utility providers or submetering platforms to avoid missed deadlines. 

 

3. Data Accuracy and Metering Integrity 

Submitting flawed or estimated data defeats the purpose of LL84. The city expects clean, consistent, and auditable reporting. 

Common errors to avoid: 

• Outdated building size or use classifications. 

• Missing tenant meter data. 

• Incorrect reporting of vacant space or operating hours. 

What’s expected: 

• Square footage must match NYC tax lot records. 

• All energy-consuming spaces must be accounted for. 

• Tenant data should be aggregated or estimated based on known usage patterns. 

Best practice: Conduct annual walkthroughs to ensure your metering strategy aligns with actual energy use. 

 

4. Public Disclosure and Transparency 

LL84 benchmarking data is published annually via NYC Open Data. This means anyone—including tenants, buyers, or watchdog groups—can see how your building performs. 

What gets disclosed: 

• ENERGY STAR scores or EUI values. 

• Total energy use and emissions output. 

• Building use type and size. 

Why it matters:
Underperforming buildings risk reputational damage and tenant turnover. Improving your benchmark score boosts public perception and investor confidence. 

 

5. Implications for Broader Sustainability Laws 

LL84 doesn’t impose direct energy-efficiency mandates, but it sets the stage for laws that do—most notably Local Law 97, which sets emissions limits starting in 2024. 

Think of LL84 as: 

• A diagnostic tool: exposing inefficiencies before they become financial liabilities. 

• A compliance baseline: helping you measure where you stand today. 

• A pre-requisite: some incentive and financing programs require up-to-date LL84 data. 

Futureproof your property by: 

• Upgrading lighting systems and HVAC. 

• Conducting retro-commissioning. 

• Exploring renewable options like solar or cogeneration. 

 

6. Updating Operational Changes in Real Time 

Your benchmarking profile must reflect the current state of the building. That means updating Portfolio Manager when things change—not just once a year. 

You must update if: 

• A new tenant with extended operating hours moves in. 

• You add equipment that consumes more energy (e.g., data servers, restaurant kitchen). 

• A renovation alters your building’s square footage or use type. 

Why it’s critical:
If your operational changes aren’t updated, your efficiency metrics become skewed—leading to incorrect performance data, poor public scores, or even compliance penalties. 

 

7. Alignment with NYC’s Long-Term Energy Goals 

Local Law 84 supports NYC’s target to reduce citywide greenhouse gas emissions by 80% by 2050. Buildings are responsible for nearly 70% of emissions, making this law a foundational element of the city’s climate plan. 

How your building plays a role: 

• LL84 is step one: identify and report inefficiencies. 

• LL97 is step two: reduce emissions or pay fines. 

• Retrofitting now means avoiding large capital expenses later. 

Bottom line:
Treat LL84 as more than an obligation—it’s a strategic opportunity to lower costs, improve performance, and stay ahead of regulatory risks. 

If you're managing a commercial property in NYC, understanding LL84 isn't optional—it's essential. This law goes beyond data entry, requiring you to measure, verify, and publicly share how your building performs. From using the ENERGY STAR Portfolio Manager to ensuring accurate annual submissions and keeping pace with operational updates, compliance is as much about diligence as it is about strategy.