NYC Local Law 84 (LL84) Compliance

New York City Local Law 84 (LL84) requires eligible buildings to annually benchmark and report their energy and water consumption using EPA’s ENERGY STAR® Portfolio Manager by May 1 each year. The law standardizes performance tracking so owners can compare results across similar properties, identify underperformance, and reduce costs and emissions.

What Is New York City’s Local Law 84?

New York City’s Local Law 84 (LL84) requires certain buildings to annually report their energy and, when applicable, water use by entering the previous year’s consumption data and key building details into ENERGY STAR Portfolio Manager (or another interface designated by the City). The law ensures consistent tracking of building performance, increases transparency, and supports citywide efforts to improve energy efficiency and reduce emissions.

Who Must Comply?

City Buildings

A building is a city building if it:

  • Is over 10,000 gross sq ft, as per Department of Finance records, and

  • Is owned by the City or the City pays all annual energy bills.

  • Two or more buildings on the same tax lot are treated as one. (§28‑309.2)

Exceptions:

  • Buildings in the Tenant Interim Lease apartment purchase program.

  • City-owned buildings 25,000 sq ft or less participating in specific HPD programs.

Covered Buildings

A building is a covered building if it is:

  • A single building over 25,000 sq ft, or

  • Two or more buildings on the same tax lot totaling over 100,000 sq ft, or

  • Two or more condominium buildings under the same board exceeding 100,000 sq ft, or

  • A city building. (§28‑309.2)

Exceptions include:

  • City buildings in the Tenant Interim Lease program

  • Class One properties

  • Low‑rise (≤ 3 stories) attached/detached/semi-detached structures where each dwelling owns and maintains its own HVAC/hot water systems, and no system serves more than two units, as certified by a design professional.

What’s Required?

1.Annual Benchmarking — May 1 Deadline

Data Requirements

  • Must include all utility accounts, including separately metered tenant spaces.

  • Owners must obtain meter data from utilities or make reasonable efforts to get it from tenants (who are required to provide it).

2.Public Disclosure

By September 1, the City publishes:

  • Energy Use Intensity (EUI)

  • Water use per sq ft

  • Scores/ratings

  • Year‑over‑year comparisons

3.Energy Efficiency Score & Grade

Each benchmarked building receives an annual score and letter grade:

Score/Grade

  • ≥ 85 (A)

  • 70–84 (B)

  • 55–69 (C)

  • < 55 (D)

  • Non‑compliance(F)

  • No score feasible / exempt (N)

4.Posting Requirement

Owners must post the grade near each public entrance within 30 days of receiving it (except grade N).

Penalties for Non-Compliance

DOB indicates that properties on the Covered Buildings List (CBL) must submit benchmarking reports; failure to report can result in violations and penalties. (Specific amounts and escalation schedules are handled by DOB enforcement; ensure on‑time filing to avoid fines.)

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How We Help

Complete LL84 Benchmarking Management

Annual data entry into the benchmarking tool for energy and water (when AMR applies).

Consultation with operating staff to ensure accurate building characteristics.

Utility & Tenant Data Coordination

Collecting all usage data across every meter and account, including tenant meters.

Documentation of all reasonable efforts to obtain missing data.

Recordkeeping & Audit Preparation

Maintaining compliant 3‑year archives of bills, tenant requests, and utility data.

Preparing owners for potential DOB audits.

Energy Efficiency Score & Grade Support

Ensuring score submission requirements under §28‑309.12.2.

Guidance on posting the building’s annual grade correctly.

Violation Prevention

Ensuring timely, accurate May 1 submissions.

Avoiding “substantially incomplete or inaccurate” rejections.

Owner Assistance Navigation

Helping owners access official city benchmarking assistance when needed.

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Why Choose IE Energy

Deep Expertise in LL84 Benchmarking

We specialize in New York City’s Local Law 84 benchmarking requirements—managing annual May 1 submissions, coordinating utility and tenant data for all metered spaces, and ensuring complete, accurate reporting through the ENERGY STAR Portfolio Manager benchmarking tool.

Compliance‑Focused Professional Oversight

Your benchmarking is handled with technical rigor. We ensure your building meets LL84’s strict accuracy, documentation, water‑metering, and posting requirements, so you stay compliant and avoid violations or rejected submissions.

Data‑Driven Understanding of Your Building

Our insights come from your actual energy and water usage—not assumptions. We analyze your building’s performance trends, ENERGY STAR scores, and year‑over‑year changes to identify where efficiency or operational improvements can make a measurable impact.

Cost‑Conscious, Requirement‑Aligned Guidance

We focus on the most efficient path to LL84 compliance. If certain LL84 exceptions apply (such as limited penalties for qualifying small buildings) or if your building is exempt from water benchmarking, we’ll help you navigate those provisions clearly and strategically.

Responsive, Client‑Centered Communication

You’ll receive clear updates, quick responses, and straightforward guidance throughout the process. No upselling, no confusing jargon—just reliable support that ensures your building is benchmarked accurately, on time, and in full compliance with the law.

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Questions & Answers

Frequently Asked Questions

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  • Failure to submit an annual LL84 benchmarking report is a violation. The Department of Buildings may treat missing or inaccurate data as if no benchmarking was performed. Certain small buildings may avoid penalties only if they requested City assistance at least 60 days before the deadline and corrected the issue within 60 days of receiving a notice.

  • Submitting late data can bring the building into compliance, but if DOB has already issued a violation, the late submission does not automatically remove or prevent the violation. For small qualifying buildings, penalties may be waived only if the owner followed the City’s assistance and correction timelines.

  • Owners who qualify for penalty relief have 60 days after receiving a notice of violation to correct the issue, provided they also requested benchmarking assistance at least 60 days before the May 1 deadline.

  • A successful LL84 submission appears as a completed, validated entry in ENERGY STAR Portfolio Manager and is transmitted to the City’s benchmarking system. Owners may also receive confirmation through the benchmarking interface or via their service provider.

  • Owners must report all energy and, when applicable, water usage for the previous calendar year, including every utility account and separately metered tenant space. Owners must also maintain benchmarking records—such as bills, tenant data, and correspondence—for three years.

Need More Help?

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Fill out the form below and our team will reach out within 1 business day to help you meet your LL84 benchmarking requirements—fast, accurate, and stress‑free.

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Call us at 909-906-0840
Email us at team@ieenergy.com