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Electrical Submetering in NYC:

Compliance and Opportunity

New York State and New York City have implemented some of the most aggressive electrical submetering requirements for commercial and multi-unit residential buildings in North America. Do you understand what that means to you and your buildings?

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.

Graphic of electricity coming into a building's Master meter and then measured after the panel by a multi-unit Sumter
Submeters can measure energy use for tenants, departments, building equipment, or any other electrical load.

The Benefits of Electrical Submetering?

Submeters allow for the granular measurement of energy, right down to the individual circuit. Building owners and property managers can pinpoint energy use, identify failing equipment, and allocate costs fairly by installing submeters. Tenants pay only for the electricity they use, are accountable for their consumption, use less energy, and lower their electricity bills.
Reduce Energy Use, Save Money
There are several strategies for reducing energy costs, but few are as compelling and fundamental as submetering. Many studies have shown that using submeters to allocate charges based on actual energy use is one of the most effective ways to reduce consumption. 

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. [1]

But that was just the start. FEMP found that submetering aspart of a coherent, continuous commissioning program of benchmarking, analysis, and remediation can result in 15% to 45% savings. [2]
Win, Win and Win!
When tenants pay directly for their energy use, overall building consumption drops on average by 20%. That's an impressive saving that's comparable to installing an entire building automation system or changing all the windows in an office tower — at a fraction of the cost. 

Put another way, for every five buildings that are submetered, an entirely new building can be powered from the saving.
With Electrical Submeters installed...
  • 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?

New York State law requires that building owners and management companies use New York Public Service Commission (NYPSC) listed meters when billing residential tenants — while New York City has implemented some of the most aggressive submetering requirements for commercial and multi-unit residential buildings in North America. 
Residential Tenant Billing in New York State
At the State level, the New York Public Service Commission (NYPSC) has instituted strict requirements that govern electrical submetering in a residential building (including cooperatives, condominiums, and rental facilities). The rules affect how submeterers (building owners, property management companies, or third-party energy resellers) bill for electricity use — protecting residents while promoting energy conservation.

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.
NYPSC Approved Submeters
Multi-unit residential building owners looking to submeter residential tenants in New York State must install and use New York Public Service Commission (NYPSC) listed submeters. Contact Triacta for the complete list of approved meters.
Greener, Greater Buildings
Buildings generate 75% of the greenhouse gas emissions in New York City. The Greener, Greater Buildings Plan (GGBP) is a comprehensive set of energy efficiency laws designed to reduce NYC's carbon footprint and save consumers millions in annual energy costs.
What is Local Law 88
Local Law 88 (LL88) is part of the larger GGBP initiative, targeting energy efficiency in large existing buildings in New York City. New York was one of the first cities in the United States to require submetering for buildings over a specific size. 

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.
What is Local Law 97
Local Law 97 (LL97) is New York City's innovational emissions law that places carbon caps on most buildings larger than 25,000 square feet. The caps start in 2024 — with both emission goals and enforcement becoming increasingly demanding over time. The city's goal is to reduce CO2 emissions by 80% by 2050.

Many buildings in New York City are affected by LL97 and could face significant financial penalties if not compliant by 2024.
What does LL97 Mean for Your Building?
The first step is to determine if your property is subject to LL97. Generally speaking, if a building is subject to Local Law 84 (NYC Benchmarking Law), it is subject to the building emissions law. Check the Covered Buildings List for your property every year. If you are on the list, you need to determine your building's carbon emissions and limits.

Urban Green Council has a great FAQ on how to do that here.
How Can I Reduce My Building's Carbon Emissions?
Reducing a property's energy use is by far the most effective way to reduce its carbon footprint. There are several strategies for reducing energy costs, but few are as compelling and fundamental as submetering.

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.
What is Local Law 84
Known as the Benchmarking Law, Local Law 84 (LL84) requires building owners to submit yearly energy and water usage data. Reports are due May 1 of each year. Failure to comply will result in fines.

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.
What is Local Law 33
Under Local Law 33, owners of buildings subject to Local Law 84 must publicly display Building Energy Efficiency Rating labels. The labels, generated from data submitted to the EPA Portfolio Manager platform for LL84 compliance, give the public a snapshot of a building's energy performance relative to other NYC buildings. Building owners who pursue energy efficiency improvements are rewarded with higher energy grades.
Sample of Local Law 33 Building Efficiency Rating Poster
Building Energy Efficiency Ratings include a 1–100 ENERGY STAR® score and letter grade ( A–D). Scores are based on occupancy type, with a building's performance measured against similar structures. 
What is Local Law 87
Local Law 87 requires all commercial and residential buildings over 50,000 square feet to carry out an energy audit and retro-commissioning every ten years. The purpose of the review is to identify recommended but not required energy savings measures. The recommended actions are provided in an energy Efficiency Report (EER) to the building owner and filed with the New York City Department of Buildings.
Energy Audit
An energy audit is a systematic analysis of a building's energy equipment and systems — including boilers, chillers, electrical and lighting systems, and HVAC systems. The goal of the audit is to identify the most cost-effective improvements for reducing energy use. 

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.
Commissioning is the process of assessing how a building's equipment and systems function together — to ensure optimal energy efficiency. Retro-commissioning sees the same systematic approach applied to existing buildings that have never been commissioned. The goal is to ensure energy systems operate and are maintained according to the building's operational needs.
Energy Efficiency Report
Energy Efficiency Reports (EER) are a collection of Certification Forms and data collection tools that are submitted electronically. The forms contain the details of a building's audit status, the energy audit and retro-commissioning finding, and a statement of compliance from the building owner.

Compliance and Opportunity

While New York City's building emission and submetering laws are stringent — they are forward-thinking and fair. If property managers and building owners act now, there is plenty of time to put in energy savings practices and processes that will allow them to be compliant with all Local Laws, while meeting state-wide residential billing submetering requirements. 

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?

Submetering has developed considerably from its humble origins — with several advancements that have made circuit branch monitoring reliable and economical.
The More the Merrier
The evolution of multi-point electrical meters has created a cost-effective way to meet New York City’s stringent submetering and carbon emissions laws.

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.

Picture of one multi-point meter replacing several single-point meters
One multi-point meter (in yellow circle) replaces multiple, single-point meters.