Local Law 87 of 2009 — Energy Audit & Retro-commissioning
Every covered NYC building files an Energy Efficiency Report once a decade, in a year set by its tax block number. Missing it costs $3,000 the first year and $5,000 each year after, with no cap.
What Local Law 87 Requires
LL87 requires two things every ten years: a comprehensive energy audit and a retro-commissioning study of the building's base systems, compiled into a single Energy Efficiency Report (EER) filed with DOB.
The audit assesses the major energy systems (HVAC, lighting, envelope, hot water, controls) and recommends conservation measures with cost and payback estimates. The recommendations are optional; owners aren't required to implement them.
Retro-commissioning is a hands-on tune-up of the base systems against a DOB-specified checklist, and its deficiency findings do have to be corrected. Both the findings and the corrective work go into the EER.
Under DOB's LL87 rules, both components are performed or supervised by a NY-licensed design professional with recognized energy-audit or commissioning credentials.
Who's Covered, and finding your filing year
LL87 covers a smaller set of buildings than LL84 or LL88: buildings over 50,000 gross square feet, or two-or-more buildings on the same tax lot or governed by the same condo board with combined area over 100,000 sqft. Buildings between 25,000 and 50,000 sqft have LL84 obligations but not LL87.
The filing year comes from the last digit of the building's tax block number: blocks ending in 6 file by December 31, 2026, blocks ending in 7 in 2027, and so on, repeating every ten years. The block number is on your property tax bill and in Department of Finance records.
Tax Class 1 homes are exempt, and buildings less than ten years past their first Temporary Certificate of Occupancy may not need the cycle yet. ENERGY STAR or LEED certification can exempt the audit or RCx portion, and substantially rehabbed buildings can apply for a 10-year deferral. None of these are automatic; each is documented as part of the filing.
The 4-Year Audit Window
The energy audit can't be more than four years old when the EER is filed, so an audit done early for other reasons (capital planning, rebate qualification) may not be reusable.
The window is a reason to line LL87 up with other work: the audit overlaps with retrofit planning, LL97 options, and LL88 lighting scope, so a well-timed audit can serve several purposes.
Deadlines, extensions, and deferrals
The EER is due December 31 of the building's assigned filing year. Per DOB's published process, a one-year extension can be requested by October 1 of the due year (Form EER2, $155), evaluated case by case; substantially rehabbed buildings can instead seek a 10-year deferral (Form EER1). DOB has also shifted individual cycle deadlines in the past, so confirm the current year's dates on the DOB LL87 page.
Recently renovated buildings often qualify for the deferral without realizing it; check before defaulting into the audit cycle.
Penalties
LL87 penalties have no annual cap, which makes them the most expensive in the 2009 package to ignore.
A building five years past its deadline owes $23,000 before the audit and RCx work itself, and outstanding penalties may need to be resolved before a late EER is fully accepted. Curing late still beats letting the meter run.
Figures reflect DOB's published penalty schedule, checked July 2026.
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Common Pitfalls
Starting too late, or auditing too early.
The audit and RCx take 6–12 months done properly, and the audit can't be more than four years old at filing. Time the work to the EER deadline, in both directions.
Reading the audit as the whole obligation.
Audit recommendations can be declined; RCx deficiencies can't. Owners who see the ECM list sometimes conclude LL87 requires no work at all.
Paying for a cycle a certification would have waived.
Buildings that already hold ENERGY STAR or LEED certification routinely skip the exemption paperwork and pay for full audit/RCx cycles they didn't need.
How LuxNet Helps with LL87
The EER itself is certified work that goes through firms with the credentials LL87 requires. We supply the lighting and controls data layer the audit depends on: fixture inventory, controls and sensor verification, and the LL88 overlap. For a building with an open LL88 obligation, one survey feeds both.
A scoping call settles the structure: coordination with your existing EER auditor, a referral if you need one, or a survey deliverable that hands into the audit directly.
How do I find my LL87 filing year?
Is the audit different from the retro-commissioning?
Do I have to implement the audit's recommendations?
Who can perform the LL87 audit and retro-commissioning?
What's the penalty if I miss the deadline?
Can I get an exemption with ENERGY STAR or LEED certification?
Does LL87 overlap with LL88?
The Audit Only Happens Once a Decade. Make the Lighting Layer Count.
If your building has an LL87 cycle and an open LL88 or LL97 planning need, LuxNet can survey the lighting and controls layer once and package that data for the right compliance professionals. Start with a building check; we'll scope the right structure from there.
Penalty figures and compliance details reflect DOB's published rules and can change. This page is general information, not legal or financial advice; confirm specifics with DOB, your utility, and your own professionals.
Last updated: July 2026. NYC building compliance rules, deadlines, and DOB procedures may change.