Separate lighting work from electrical-use reporting
A business owning a New York City building may occupy one portion and lease another to a separate business. If the building is covered by Local Law 88, the owner should review both the lighting requirements and the covered-tenant-space submetering requirements. Replacing lamps with efficient models does not establish that the electrical measurement and reporting file is complete.
The Department of Buildings describes building coverage and particular tenant-space tests. Its current page identifies spaces over 5,000 gross square feet let or sublet to one person, and specified floors over 5,000 square feet occupied by multiple tenants. Have the responsible professional apply the actual definitions, exclusions, and measurement facts rather than using the number of lease documents alone.
Collect floor plans, leases and subleases, measured areas, electrical diagrams, dedicated-meter information, prior compliance documents, and monthly statement records. Reconcile the physical occupancy with the legal arrangements. A meter labeled second floor may serve equipment outside that floor or may not separately identify the space described in the lease.
Map circuits and applicable exceptions before procurement
The city describes an exception where a covered tenant space already has a meter dedicated exclusively to that space. That requires an actual electrical-use mapping, not a conclusion based only on the meter’s name or location. Ask the electrical professional to identify what each meter serves and document the supported treatment of every relevant space.
Consider a hypothetical owner-occupied building with a leased 6,400-square-foot area and another 6,000-square-foot floor divided between two tenants. These facts need review under different parts of the published space tests. The owner should not assume the second floor escapes review because neither individual tenant occupies more than 5,000 square feet.
If a hypothetical professional investigation shows three proposed metering points are needed, obtain a design addressing their actual loads and reporting. Do not infer the number of meters directly from the number of tenants. Shared systems, circuit arrangements, existing dedicated measurement, and the applicable rules can change the supported design.
Budget the complete measurement and statement process
Assume a hypothetical supported proposal includes three installed submetering assemblies at $2,200 each, plus $1,400 of circuit tracing and documentation. The initial modeled cost is $8,000. If a reporting service costs an assumed $45 per month, the annual recurring charge is $540 and the first-year combined amount is $8,540 before other work, fees, or operational changes.
The example distinguishes installation from ongoing information delivery. The city describes monthly statements for tenants or subtenants within covered spaces measured by submeters. Assign responsibility for collecting readings, preparing the required information, delivering statements, and preserving the records. A new device without an operating reporting process can leave the intended project unfinished.
The hypothetical costs do not establish the appropriate metering architecture or permissible billing terms. Utility regulation, leases, electrical requirements, and other law may affect the actual arrangement. Have the appropriate advisers resolve those matters before using the meter to change tenant charges. Keep the compliance information requirement separate from a commercial decision about recovering electricity costs.
Reconcile the filing history with current conditions
The current city page states that covered buildings already in compliance do not need additional compliance merely because they remain on a list. It also identifies the 2026 filing obligations for buildings that had not demonstrated compliance. As of this guide’s date, the stated May 1, 2026 filing date is past; an owner with an unresolved file needs prompt review of actual status and the applicable corrective process, rather than treating the date as a future planning deadline.
Reports require professional certification and supporting information, including relevant space lists and sample statements. Obtain the actual filed package and confirmation. An electrician’s paid construction invoice does not independently establish that the required report was submitted or that current tenant-space conditions match the certified file.
Retain the coverage determination, space and circuit maps, approved design, installation evidence, professional attestation, submission confirmation, and statement history. Recheck the arrangement when spaces are combined, divided, or sublet. This guide does not certify compliance or determine every billing rule. Its practical premises decision is to maintain a supported tenant-space and reporting file, so the building’s electricity project addresses the actual metering obligation as well as the visible lighting upgrade.
Sources & further reading
Consult the original guidance and its effective dates. These references support the educational discussion; their application depends on the specific facts.