Beyond Measure

Ideas and news about electrical submetering.


Electrical Submetering Laws for Commercial Properties in the U.S.A.

There is a growing wave of regulation throughout the U.S. focused on the metering of electrical consumption. One after another, cities and states are establishing directives to reduce energy use and have tenants pay for the electricity they use.

What Does This Mean for Commercial Properties?

In some jurisdictions (such as New York and California), the laws regarding the submetering of commercial properties are detailed and precise. In other areas, standards are not yet in place or are just emerging, so the path is less clearly defined.

(For more on California Title 24, see Electrical Submetering in California: Fact, Fiction and Folly. For more on NYC Local Law 88, see Submetering in New York City: Compliance and Opportunity.)

Look to the Beginning to See the Future

To understand where legislation for the submetering of commercial properties is headed in states where regulations are less defined, it is helpful to look backwards.

ASHRAE, the American Society of Heating, Refrigeration and Air-Conditioning Engineers, first published their energy standard for commercial and high-density residential properties in 1975. Known as ASHRAE 90.1, the standard provides the minimum requirements for energy-efficient design.

Since its original publication there have been several iterations, and ASHRAE 90.1 has become a benchmark for building energy codes in the United States and a fundamental basis for codes and standards worldwide. It is frequently used as a baseline for comparison during energy retrofit projects and is an essential guide for engineers and other building professionals.

What ASHRAE 90.1 Means for Electrical Submetering of Commercial Properties

Historically energy management focused on equipment performance and overall energy use. Thanks to ASHRAE and other energy governing bodies, more focus is now being placed on precisely what should be measured and how that should be done.

Minimum energy-efficient requirements for designing and constructing new commercial properties and upgrading existing ones are now well established. Additionally, there is an increased emphasis on holding tenants accountable for the energy they use. Established best practices dictate that submetering commercial tenants with highly accurate, standards-based meters is an essential part of any submetering project.

New York City's Local Law 88, California's Title 24, and Seattle Energy Code Chapter 12 are all examples of legislation that put strict requirements on the submetering of electrical consumption for commercial properties and the types of meters that must be used to do it.

But What About States with Less well Defined Energy Regulations?

Not all states operate by the same standards. The map below shows energy code adoption for commercial properties in America.  All but 8 states seek some level of alliance with ASHRAE 90.1.

Source: "Status of State Energy Code Adoption,” Energy.Gov

If your state has not yet adopted ASHRAE-based standards or has not yet fully adopted all levels of ASHRAE 90.1, it’s a safe bet that they will at some point. Historically energy management laws and practices developed in New York or California spread across the country and become standard in other states.

If you are investing in your building today, assume all commercial tenant spaces will need to be submetered at some point — as will most common areas. There may be a differentiation in the level of square footage that will need to be metered, but expect some basics in terms of load types that will need to be monitored separately.

ASHRAE requires, for example, that interior lighting, exterior lighting, HVAC systems, electrical receptacles, and overall energy use be monitored. Some jurisdictions like California go further and require electric vehicle charging stations, water systems, and elevators to be measured separately.

Prepare for Both Today and Tomorrow

Understanding local regulations and best practices for submetering is crucial for optimal building performance and regulatory compliance. Being unaware can mean being on the wrong side of the law, with costly replacement costs for equipment that doesn't meet standards.

As the movement towards electrical submetering of commercial properties continues its rapid ascent, it’s helpful to understand how to choose the right type meter for your particular situation. We’ve put together a handy little guide (How to Choose the Right Electrical Submeter) to help you do just that.

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