By Brian Healey, VP of Sales & Marketing, Pearl Street Systems & Engineering
"We converted to LED years ago”, or “We just converted to LED last year…so we're already Local Law 88 compliant."
I hear some version of this consistently from building owners and facilities teams across New York City. It's an understandable assumption — but in most cases, it is not correct.
Over the years, Pearl Street has surveyed more than 100 million square feet of commercial space — commercial office towers, hospitals, universities and multifamily properties. Across all of it, one pattern shows up time and time again: an LED retrofit that looks complete on paper but was never actually designed to energy code.
What Local Law 88 Actually Requires
Local Law 88 (LL88) is part of New York City's broader push to reduce building energy consumption. For lighting, LL88 requires covered buildings to upgrade lighting systems to meet the current energy code.
Alongside the LED conversions, the second part of LL88 is where most buildings fall short. This code isn’t a lighting FIXTURE requirement — it's a lighting SYSTEMS requirement.
Where LED Retrofits Fall Short of Compliance
In our walkthroughs, the gaps tend to fall into a few consistent categories:
Existing Occupancy Sensors “All our office space already has sensors.” But the sensors are occupancy-only with no vacancy setting option. Some are disabled or non-functional due to tenants trying to override them over the years. Even the functional ones have maxed out timeouts set to 30 minutes when the code requires 15 minutes or less.
No Occupancy sensors The fixtures went in, but the cost adder for occupancy controls compared to the added energy savings hurt the retrofit’s ROI, and therefore, were excluded from the project scope.
No Daylight harvesting Well if occupancy sensors hurt the project payback, forget about daylight harvesting! Adding low voltage daylight zones wouldn’t have even been a thought when putting together the project.
With that said, it is worth mentioning that fixture-integrated controls are now making these requirements much more feasible from an ROI-standpoint. This will be discussed as a separate topic in the near future but feel free to reach out for an immediate conversation about this technology
Documentation gaps. This is in addition to lighting retrofits. But it is the most unfortunate situation I come across when Pearl Street Systems assists NYC customers with Local Law 88 support.
Here’s the situation: Their building was constructed (or gut-renovated) after LL88 went into effect in 2010, and therefore, the lighting systems SHOULD be compliant with the code. However, they cannot track down the dated project drawings and documentation that confirms the lighting was up to the energy code at the time.
Any one of these will put the entire building out of compliance.
What Owners Should Do Next
If your building completed an LED retrofit at some point or has existing LEDs/controls from the original construction, it's worth verifying rather than assuming - Reach out to an industry expert light Pearl Street. We will want to:
- Walk the building and check whether any existing controls are properly functioning and up to code
- Review control sequences against what was originally designed and commissioned
- Confirm your documentation is complete enough to support a compliance filing with DOB, including any retrofit/IGLA submissions if applicable
- Identify whether lighting system changes/reductions have occurred since the original installation
Sometimes that review confirms everything is in order. Just as often, it surfaces real opportunities — for energy performance, occupant comfort, and compliance — that a building owner didn't know existed.
That's one of the reasons this work stays interesting after 14 years in it. No two buildings are the same, and the ones that look "done" are often the ones most worth a second look.
If you're not sure where your building stands on Local Law 88, Pearl Street can help you!