Electrical Submetering in NYC:
Compliance and Opportunity
What is Electrical Submetering?
Many commercial and residential buildings use a single "master meter." Electricity comes into a building at bulk rate prices from the Utility, and landlords bill tenants for electricity based on flat fees or formulas derived from the space they occupy. Occupants pay for electricity as part of a monthly bill, but their energy use is not individually monitored or tracked.
Electrical submetering is the measurement of consumption after the master meter. Submeters (also referred to as power meters, electrical meters, and energy monitors) are installed after the master meter to measure individual electrical load.
The Benefits of Electrical Submetering?
One of the most exhaustive examinations of applying electrical submetering to commercial buildings was undertaken by the U.S. Department of Energy as part of the Federal Energy Management Program (FEMP) in 2007. This study showed that merely installing meters resulted in a 2% reduction in energy use through the Hawthorne Effect. 
Put another way, for every five buildings that are submetered, an entirely new building can be powered from the saving.
- Tenants win by saving money and reducing their energy use.
- Landlord’s win with considerably lower energy and operational costs.
- The environment wins with significant reductions in greenhouse gas emissions.
What Laws Govern Electrical Submetering in New York?
For owners, a common question is whether they can profit from submetering residential tenants. The rules are clear here. Landlords can charge residents up to, but not more than, the direct metered utility rate for electricity. The goal is to reduce electricity use by making those consuming it directly responsible for paying for it.
Local Law 88 (and add-on Local Law 132) require all non-residential buildings greater than 25,000 square feet to install electrical submeters for each large non-residential tenant space greater than 5,000 square feet. The submeters must be installed by January 1, 2025.
Building owners and property managers are not required to charge tenants for electricity based on the submeters installed. However, the meters must be installed by 2025 and tenants informed of their actual monthly electricity usage.
Many buildings in New York City are affected by LL97 and could face significant financial penalties if not compliant by 2024.
Urban Green Council has a great FAQ on how to do that here.
According to Marc Reimer of Bay City Metering, submetering provides the granular consumption detail that property managers and building owners need to reduce energy use and avoid potential fines. Mr. Reimer is not alone in these assertions. Many studies have shown that using submeters to allocate expenses based on actual energy use is one of the most effective ways to reduce consumption.
For more on the benefits and payback of submetering, see Making the Case for Energy Metering, ASHRAE.
Reducing a property's energy consumption with submetering not only sets property managers and building owners up for LL97 compliance, but can significantly improve building operations, allow for fair cost allocations, and increase tenant satisfaction.
Building owners must submit data for buildings that are larger than 25,000 square feet or if a building owner has two or more buildings on a single lot that are larger than 100,000 square feet. Property managers and building owners can see if their building falls under LL84 by checking the LL84 Covered Building List.
To comply with LL84, owners must submit data using the Environmental Protection Agency's (EPA) Portfolio Manager platform. This tool allows for the comparison of a building's energy efficiency with similar structures.
A qualified energy auditor typically carries out energy audits. The auditor is responsible for creating a report with recommended strategies for saving energy — complete with costs and payback expectations.
Compliance and Opportunity
But perhaps more important than being compliant is the amount of money you'll save on energy costs, improvements to failing building equipment, and increased tenant satisfaction.
How Much Does it Cost?
Multi-point meters can isolate and monitor energy use by circuit, aggregate circuit-level data in any combination required, and easily adjust to circuit changes. Existing buildings don't need costly rewiring or expensive extra equipment. For new builds, panels can be installed with less labour since no additional time is needed to validate complex layouts.
Multi-point meters have the added advantages of having a much smaller footprint than multiple single-point meters and lower per meter point deployment, integration, and maintenance costs. Multi-point meters allow for the metering of 6 or more circuits depending on the model and need. They are useful when measuring a large concentrations of circuits and a viable option for multi-load, granular data requirements.
- From Space Saver to Information Cornerstone: The Evolution of the Multi-Point Electrical Meter
- Making the Case for Electrical Submeters
- How to Choose the Right Electrical Submeter
- Successful Energy Management Through Submetering, Part 1
- Successful Energy Management Through Submetering, Part 2