Local Law 87 Compliance: Avoid Costly Mistakes in NYC

At a high level, Local Law 87 seems straightforward. Every 10 years, covered buildings in New York City must complete an energy audit and retro-commissioning, then submit an energy efficiency report (EER) to the Department of Buildings (DOB).

Most building owners understand this requirement. The problem is not awareness, it’s execution.

What appears to be a routine compliance task often becomes complex once the process begins. Multiple systems must be evaluated, documentation must align, and findings must be verified before submission. When these steps are not properly coordinated, projects can quickly run into delays, missed deadlines, or incomplete filings.

This is why many owners turn to local law 87 compliance consulting help. The challenge isn’t completing the audit, it’s managing the entire compliance process from start to finish.

What Local Law 87 Actually Requires

To comply with Local Law 87, buildings listed on the covered buildings list, generally those over 50,000 square feet or part of a tax lot exceeding that threshold, must complete two primary components:

• An energy audit, which evaluates building systems and identifies energy saving measures
• A retro-commissioning study, which focuses on how existing systems are operating and identifies deficiencies

Together, these form the basis of the energy efficiency report EER, which must be submitted to the NYC Department of Buildings based on the building’s tax block number.

The audit reviews major energy consuming systems, including HVAC, lighting systems, and the building envelope, while the retro-commissioning process focuses on optimizing base building systems and correcting operational issues.

It’s important to understand that while the audit identifies opportunities, the retro-commissioning measures often require corrective action and verification before submission.

The Timeline Mistakes That Create Compliance Problems

One of the most common issues with Local Law 87 compliance is timing. Many projects begin too late in the filing cycle, leaving little room to complete the required work.

Because compliance is tied to the building’s tax block number, deadlines are fixed. Waiting until the compliance year creates several risks:

• Limited availability of a qualified energy auditor or certified energy manager
• Insufficient time to complete testing across all building systems
• Lack of time to implement corrective measures identified during retro-commissioning

In addition, some testing, especially related to HVAC and energy systems, requires observing equipment under different operating conditions. Starting late reduces the ability to fully evaluate performance.

Projects that begin early have the flexibility to complete the audit, address deficiencies, and prepare a complete detailed report without rushing the process.

Common Energy Audit Mistakes

The energy audit portion of Local Law 87 is often treated as a checklist exercise. While it does involve reviewing utility bills and analyzing energy consumption, its real value comes from identifying meaningful opportunities to improve building performance.

A common mistake is focusing only on equipment rather than how systems operate. For example, replacing equipment may be recommended even when the issue is related to controls or scheduling.

Another issue is incomplete system evaluation. Audits should review all major energy consuming systems, but in some cases, important areas are overlooked or not fully analyzed. This leads to recommendations that do not address the root causes of energy waste.

When done properly, the audit should:

• Reflect actual building’s energy usage
• Identify realistic ways to reduce energy consumption
• Provide actionable insights—not just theoretical savings

Where Retro-Commissioning Efforts Often Fall Short

The retro-commissioning process is where many compliance efforts break down. Unlike the audit, which focuses on identifying opportunities, retro-commissioning is about verifying and correcting how systems operate.

This includes evaluating existing building systems such as HVAC, controls, and other base building systems to identify issues that are negatively affecting performance.

Common challenges include:

• Incomplete testing of system operation
• Failure to document deficiencies and corrective actions
• Lack of follow-through on required adjustments

In many cases, issues are identified but not fully resolved before the energy efficiency report is submitted. This can create compliance risks and reduce the effectiveness of the overall effort.

Retro-commissioning should not be treated as a formality, but as a critical step in improving building’s energy efficiency and ensuring systems operate as intended.

Documentation Issues That Delay Submissions

Even when the audit and retro-commissioning are completed, documentation problems can delay compliance.

The energy efficiency report EER must clearly reflect:

• Audit findings
• Identified energy saving measures
• Completed retro-commissioning work

Common issues include inconsistencies between reports, missing documentation, or unclear descriptions of corrective actions. Because submissions are reviewed by the NYC Department of Buildings, incomplete or unclear reporting can result in delays or rejection.

Coordination between energy engineers, auditors, and registered design professionals is essential to ensure that all documentation aligns and supports the final submission.

Using Local Law 87 to Improve Building Performance

While Local Law 87 is a compliance requirement, it also presents an opportunity to improve energy performance and reduce long-term costs.

When approached strategically, the audit and retro-commissioning process can help:

• Reduce energy usage across major systems
• Lower energy costs
• Improve overall system efficiency
• Support broader goals such as reducing greenhouse gas emissions

This aligns with initiatives like the Greater Buildings Plan, which focuses on improving the efficiency of New York City buildings and supporting more sustainable building designs.

Rather than viewing LL87 as a one-time requirement, building owners can use it to identify long-term improvements and optimize system performance.

A Practical Strategy for Successful Local Law 87 Compliance

The most successful compliance efforts follow a structured approach that focuses on planning, coordination, and execution.

Key steps include:

• Starting early (well before the compliance year)
• Coordinating the energy audit and retro-commissioning efforts
• Addressing deficiencies identified during testing
• Maintaining clear and consistent documentation

This approach reduces risk, avoids last-minute issues, and ensures that the final submission is complete and accurate.

Local Law 87 Compliance Consulting Experts

Navigating Local Law 87 compliance requires more than completing an audit, it requires managing the entire process from evaluation to submission.

At MIH Systems Group, we provide local law 87 compliance consulting designed to help building owners avoid delays, reduce risk, and improve system performance. Let’s talk to discuss your building’s compliance gameplan.