Question of the Month: What is the best approach to New York City Local Law 88 compliance? - by George Crawford

George Crawford, Green Partners

Compliance with New York City Local Law 88 now includes an add-on Local Law – LL 134. The combination of these two Local Laws requires that every building, or more specifically, every building over 25,000 s/f in New York City, upgrade their lighting to LED. For multifamily buildings, this requirement is limited to common areas (residential units are excluded). Commercial buildings are required to upgrade lighting throughout – every last s/f including both common areas, as well as offices and retail. Compliance also includes the sub-metering of tenants, if not already metered.

As to the best approach to compliance – there is no one size fits all answer, but let’s start with some questions and answers  to fill in the blanks.

Deadline? The deadline for LL 88/134 compliance is January 1, 2025.

Lighting Plan? Your lighting retrofit will last a very long time. Make sure to develop a plan and keep track of progress as you will need records of work performed.

Lighting code?  Existing lighting in many buildings does not meet code. LL 88/134 compliance is an opportunity to fix this problem. Focus on fire stairs and egress deficiencies.

Up front cost? A lighting upgrade does not come cheap. Your capital budget plan should include available Con Ed funding to minimize investment cost.

Utility funding?  Con Ed funding is available for LL 88 lighting upgrades for both multifamily and commercial properties. You will need to work with a Con Ed partner to qualify.

Benefits?  Substantial cost savings and quick paybacks are the norm. Cost savings include both lower utility bills as well as lower, much lower, levels of lighting maintenance.

Timing? When do you start the process? You should start sooner rather than later to benefit from the ongoing savings and to lock in Con Ed funding.

How to navigate the process for the best result?  Model your project so that you work with hard numbers. Start with your existing lighting configuration, including current annual electric charges, maintenance costs and lamp replacement costs.

This is the “before” – the existing conditions benchmark that you can use to evaluate the cost effectiveness and payback of each proposed LED retrofit option. If you work with a Con Ed partner who has access to Con Ed computer software, your Con Ed partner will be able to model each of your retro-fit options, so you can make accurate comparisons. Once you make your selection, be sure to have samples installed of each of the different LED products that are to be included in your retro-fit.

Your Con Ed partner will be able to navigate the Con Ed funding application process for you. With Con Ed involvement, you will benefit from Con Ed’s project oversight, including before and after inspections.

George Crawford is the principal of Green Partners, New York, N.Y.