What Is Local Law 84?
A plain-English guide to NYC Local Law 84 — the annual energy and water benchmarking requirement for buildings over 25,000 sq ft. Covers the May 1 deadline, ENERGY STAR Portfolio Manager reporting, letter grade posting under LL33, and penalty structure.
Local Law 84: The Definition
Local Law 84 (LL84) requires the owners of NYC buildings over 25,000 square feet to report annual energy and water consumption to the city each year. The reports are filed through EPA's ENERGY STAR Portfolio Manager and are due by May 1 covering the prior calendar year.
LL84 is a reporting law — it doesn't cap energy use. Its purpose is to create transparency: benchmarking data is publicly published on the city's Open Data portal, letting owners, tenants, and buyers compare a building's energy performance to peer buildings.
LL84 also feeds into Local Law 97 (which caps emissions) and Local Law 33 (which publishes an A–F energy grade on the building lobby). Non-compliance triggers civil penalties.
Which Buildings Are Covered?
LL84 applies to:
- Any single building over 25,000 gross square feet
- Any two or more buildings on the same tax lot totaling over 50,000 gross sq ft
- Any two or more condo buildings governed by the same board totaling over 50,000 gross sq ft
The full list of covered buildings is published annually by the Department of Finance. If your building appears on the LL84 covered list, the reporting requirement is mandatory.
What Owners Must Report
Whole-Building Electricity
Total annual electricity consumption for all uses in the building — including tenant spaces (aggregated from Con Ed or the local utility, or from tenant sub-meter data).
Natural Gas & Steam
Any gas or steam consumption used for heating, hot water, cooking, or other purposes.
Fuel Oil
Buildings burning #2 or #4 fuel oil report total gallons consumed annually.
Water Usage
Total annual water consumption from DEP utility records.
Building Characteristics
Gross floor area, number of units (residential), operating hours, and other property attributes used to normalize benchmarking scores.
The LL33 Energy Letter Grade
Because of Local Law 33 (a companion to LL84), each covered building's ENERGY STAR score is translated into an A–F letter grade that must be posted at the building's main entrance. The grades are:
- AENERGY STAR score of 85 or higher — top performer
- BScore of 70–84
- CScore of 55–69
- DScore below 55
- FFailed to comply with LL84 benchmarking
- NBuilding not covered by ENERGY STAR scoring
The letter grade is publicly visible and affects tenant leasing, sale prices, and increasingly, lender underwriting.
LL84 Penalty Structure
- Failure to file by May 1: $500 quarterly penalty, up to $2,000 per year
- Repeated failures escalate and can push the building into the "F" letter grade under LL33
- Non-compliance shows up on the city's public benchmarking list
- Some lenders and institutional buyers now require LL84 compliance as a due-diligence item
LL84 and the Climate Mobilization Act
LL84 is one leg of NYC's building energy compliance stack. Owners of large buildings must also address Local Law 97 (carbon emissions caps), Local Law 87 (energy audits every 10 years), and Local Law 88 (lighting and sub-metering upgrades). The same efficiency retrofits often satisfy multiple laws — plan capital projects with all four in mind.
Need help with your LL84 annual filing?
BVS coordinates Portfolio Manager data collection, utility record aggregation, and the annual submission — plus keeps you ahead of the letter grade posting. Contact BVS for a free consultation.