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Codes & Regulations


The design, construction, and operation of buildings throughout the United States is governed by building codes and other regulations and laws. This regulatory framework is typically enacted and enforced on the State or municipal level. 

In New York City, as in much of the country, so-called model codes developed by the International Code Council (ICC) were adopted by the City Council and amended to address the particular circumstances in the nation’s largest city. In addition to the building codes there are multiple Local Laws, also passed by the City Council, governing the City’s building stock.


In 2009 a landmark set of four Local Laws, collectively known as the Greener Greater Buildings Plan (GGPP), was passed with the intent to reduce building-related energy use and associated greenhouse gas emissions. This set of laws recognizes the fact that New York City has a massive building stock that is a major consumer of energy and water resources and emitter of greenhouse gases, and that presents a very significant opportunity to drive up building efficiency and reduce the City’s carbon footprint.

Local Law 85 of 2009, and Local Law 1 of 2011– NYC Energy Conservation Code

Local Law 1 of 2011 defines the energy code for the City, superseding Local Law 85 of 2009 which was part of the original GGBP package. The 2011 NYC Energy Conservation Code (NYCECC or City Energy Code) is an adoption with amendments of the 2010 New York State Energy Conservation Construction Code (NYSECCC or State Energy Code), which in turn is based on the 2009 edition of the International Energy Conservation Code (2009 IECC) published by the International Code Council (ICC).  The ICC is a member-based organization that provides a comprehensive set of model codes from energy conservation, to building safety, to fire prevention.  In addition, Local Law 1 defines responsible parties for code compliance within New York City’s permitting framework and delineates documentation and inspection requirements.

Local Law 84 of 2009 – Benchmarking

Local Law 84 requires that large buildings over 50,000 square feet annually benchmark their energy and water consumption, using the U.S. Department of Energy’s Energy Star Portfolio Manager(a web-based benchmarking platform) to generate and file a compliance report with the City. The results are made public by the City, which publishes an annual Local Law 84 Benchmarking Report analyzing the huge city-wide dataset of results.

The intent of the law is to raise awareness among owners and property managers about how their buildings perform and compare to similar buildings in the marketplace. To read the report PDF, click the image. 

Local Law 87 0f 2009 – Energy Audits & Retro Commissioning

Local Law 87 requires that the same group of large buildings complete professional energy audits and perform retro-commissioning of their energy systems once every ten years. The initial compliance year for a building is determined based on the last digit of its tax block number. Buildings must file an Energy Efficiency Report (EER) with the City summarizing both the results of the audit and the retro-commissioning.

The intent of the energy audit requirement is to ensure that building owners and property managers are made aware of energy efficiency opportunities in their portfolios so that they can be acted upon if deemed financially or otherwise attractive. The intent of the retro-commissioning requirement is to ensure that the building’s energy systems operate as intended and that energy is not wasted due to malfunctioning or improperly operated equipment.

Local Law 88 of 2009 – Lighting Upgrades and Sub-metering

Local Law 88 requires that, no later than by 2025, those same large buildings must bring all lighting systems into compliance with the City Energy Code in effect at the time of the upgrade, and will sub-meter all tenant space larger than 10,000 square feet.

The intent of the law is to take advantage of the dramatic improvements in lighting technology and efficiency in recent years. For many buildings with old inefficient lighting systems, these lighting upgrades represent an economically attractive proposition with a short payback period.


There are numerous other Local Laws on the books regulating various aspects of the design, construction, and operation of the City’s buildings. Here we will only introduce two of them that specifically address lighting systems in commercial buildings.

Local Law 47 of 2010 – Daylighting and Occupancy Sensing in Egress & Corridors

Local Law 47 amends the City’s building code to allow either electric lighting or daylighting to provide sufficient lighting levels for the safe use of paths of egress and corridors. The electric lighting can to be controlled by either photo sensors or occupancy sensors. Prior to the enactment of this law, buildings were essentially forced to electrically light these spaces continuously.

The intent of this law is to reduce or eliminate the energy waste resulting from electric lighting in egress paths and corridors being turned on regardless of whether they are occupied or daylit.

Local Law 48 0f 2010 – Additional Occupancy Sensor Requirements

Local Law 48 amends the City Energy Code requiring that vacancy sensors (manual-on, auto-off) be installed in offices smaller than 200 square feet, conference/meeting rooms, classrooms, and employee lunch and break rooms. This means that upon entering a space an occupant has to manually turn on the lights as opposed to relying on an auto-on function.

The intent of the law is to reduce or eliminate the energy waste resulting from the auto-on function of many occupancy sensors that turn on the lights once an occupant enters the room, regardless of whether daylight levels are sufficient for the tasks to be performed in the space.


The 2010 State Energy Code comprises six chapters. The bulk of the technical requirements is contained in Chapter 4 - Residential Energy Efficiency, and Chapter 5 - Commercial Energy Efficiency. Local Law 1 adopted the State Energy Code for New York City as the 2011 NYCECC and at the same time replaced Chapter 1 – General Requirements – in its entirety,  and amended Chapters 2 and 6 to address the City’s unique circumstances and advance its policy objectives. However, to date the 2011 City Energy Code has not been published as a consolidated volume. Practitioners involved with designing, constructing, and operating buildings in compliance with the City Energy Code have to consult three separate documents – the 2010 State Energy Code, Local Law 1, and Local Law 48 which further amended the State Energy Code. These three documents together constitute the City Energy Code. 

As a result of this structure, the technical requirements delineated in Chapters 4 and 5 are identical in the State’s and the City’s Energy Code (with the exception of the City’s Local Law 48 amendment). Instead of following the energy efficiency requirements for commercial buildings contained in Chapter 5 (hereinafter also referred to as “NYC/NYS path”, the Energy Code permits the use of ASHRAE Standard 90.1-2007 – Energy Standard for Buildings Except Low-Rise Residential Buildings as an alternative compliance path (hereinafter referred to as “ASHRAE 90.1 path”.) This is a less stringent standard in some areas, in particular relative to the lighting systems, as it has more generous exceptions, exemptions, and allowances, and fewer lighting control requirements.

A project design team must select one of two compliance path options for the entire project. For instance, it is not permissible to follow ASHRAE 90.1 for the mechanical systems and the NYC/NYS path for the building envelope.

Obviously, having two different compliance options with differing requirements in effect at the same time is fundamentally problematic and confusing. However, the governing bodies developing these codes and standards (ICC and ASHRAE) have realized this and plan to address the issue in the next versions of the codes/standards by effectively harmonizing them.

An additional important resource is Buildings Bulletin 2010-32, clarifying the conditions under which an addition, alteration, renovation, or repair to a lighting or electrical power system or control equipment may not be required to comply with NYCECC.


Responsibility to ensure compliance with the City Energy Code rests with design professionals such as registered architects or professional engineers. Different individuals can be responsible for the three regulated groups of building systems—envelope systems, mechanical and service water heating systems, and lighting and electrical systems—or a “lead professional” can assume responsibility for the entire project.

The required documentation to be submitted to the Department of Buildings comprises three main components:

  • Professional Statement: A signed statement by the responsible registered professional(s) certifying that the design and construction complies with the City Energy Code under the chosen compliance path.

  • Energy Analysis: Summary of an analysis comparing the design’s energy systems and envelope against the prescriptive code requirements for those systems.

  • Supporting documentation for results of the energy analysis. For the lighting system this would typically include luminaire schedules and reflected ceiling plans.

Detailed energy code compliance and documentation requirements can be found in the Department of Buildings’ Rule 5000-01.

There are three accepted formats for the energy analysis at the heart of the documentation package:

  • Tabular Analysis: A table, organized by discipline, comparing the proposed value of each regulated item in the scope of work with the respective prescriptive value required by the energy code.

  • COMcheck software: A free energy analysis tool developed by the Department of Energy for the purpose of analyzing and documenting energy code compliance. COMcheck has all the code requirements built in, the results are automatically calculated, and submission-ready output documentation is quickly generated.

  • Whole-building energy modeling, also known as the Performance Path. The results from the energy model are then summarized in the Energy Cost Budget Worksheet.

In addition, the City Energy Code requires certain progress inspections for the regulated systems. For the lighting systems this means that interior lighting power, exterior lighting, and lighting controls have to be inspected and signed off on by a registered professional prior to the final inspections.


Lighting efficiency is addressed in section 505 of the Energy Code – Electrical Power and Lighting Systems. This section’s provisions can be sorted into three main categories as shown in the following diagram: 

  • Mandatory requirements related to lighting controls, wiring and exit signs (505.2 through 505.4)

  • Prescriptive requirements related to Interior Lighting Power (505.5)

  • Mandatory requirements related to Exterior Lighting (505.6)

The following paragraphs review the main requirements for the lighting systems per the City Energy Code and Local Laws.

Space Control

The most fundamental and simple control requirement is space control. Any room with floor-to-ceiling partitions must have a manual switch in the room or a clearly labeled remote switch.

Auto Shutoff

Both the NYC/NYS and the ASHRAE 90.1 paths require that buildings larger than 5,000 square feet must have an automatic control device to shut-off lighting based on scheduling, an occupancy sensor, or a signal from another control system. In effect, this means that almost all buildings must install some form of lighting control panel with scheduling control—unless every light in the building is controlled by a sensor.

Local Law 48 and ASHRAE 90.1 take this requirement a step by further by also requiring that vacancy controls (manual-on, auto-off) be installed in offices smaller than 200 square feet, classrooms, employee lunch/break rooms, and conference/meeting rooms.

Light Reduction Controls

The NYC/NYS path stipulates that, where switches are required (essentially all rooms), the installed lighting must have the capability to reduce the lighting load by at least 50%. This can be accomplished through dimming, bi-level, or multi-level switching.


Daylight Zone Controls

The NYC/NYS code path requires that luminaires in a space’s daylit zone—15 feet into a space from a perimeter window and 2 feet to either side of the window—must be connected to a separate control. Note, however, that automatic daylight dimming or daylight harvesting controls are not required.

Sleeping Unit Controls

Sleeping units in hotels, motels, etc. must have a master switch in each room to control all permanently wired luminaires and outlets. A proven way to meet this requirement is via a hotel key card master switch.

2.5  Exterior Shutoffs

Exterior lighting designated for dusk-to-dawn operation must be controlled by a photo-sensor or an astronomical timeclock to prevent operation during daylit hours.


The following chart provides a summary of the principal requirements discussed in this section and how they are represented in the current and expected future structure of codes, laws and standards.


Lighting Power Density (LPD) refers to the amount of power used for electric lighting purposes per square or linear foot. The energy code sets limits on interior and exterior LPD that are used to calculate total interior and exterior lighting power allowances.

Interior Lighting Power Density

There are two methods to determine a project’s interior lighting power allowance(s): A simple whole-building method, and a more involved space-by-space method (per ASHRAE 90.1 path only). Both methods essentially multiply prescribed LPDs for building areas or individual spaces with their respective areas, arriving at a total lighting power allowance (in Watts) for the project.

Once this total has been determined it is permissible to exceed the code-prescribed LPD in some areas of the project as long as other areas that stay sufficiently below their limits compensate for it, so that the total allowance is not exceeded. This concept is known as “tradable” spaces.

Furthermore, both the NYC/NYS and ASHRAE 90.1 paths currently provide an allowance for display lighting, which must be separately controlled and specific to displaying objects or areas. ASHRAE 90.1 currently also provides an additional allowance for decorative lighting such as wall sconces and chandeliers. However the decorative lighting allowance is slated to be removed from the coming 2010 version of ASHRAE 90.1.

The energy code also regulates how to calculate the actual installed lighting load. For all screw-based luminaires the maximum labeled wattage has to be used - not the wattage of the actually installed lamp (which could be lower). This is true for low voltage lighting as well, requiring the rated wattage of the transformer supplying power to the system, not the actual wattage of the installed lamps, to feed into the calculation. In effect, the energy code is steering design teams towards ballasted types of luminaires such as fluorescent or LED.

2.7  Exterior Lighting Power Density

Determining a project’s exterior lighting power allowance is similarly based on the concept of maximum LPD values. Per the current NYC/NYS path and future ASHRAE 90.1 path, these maximum values are based on specific exterior lighting zones determined according to the zoning districts defined by New York City’s Department of City Planning.

Exterior lighting zones range from lighting Zone 1 for park land, allowing for the least amount of exterior light, to lighting Zone 4 for commercial districts such as Midtown Manhattan, allowing for the most exterior lighting to be installed.


As the codes and regulations change this section will be updated. 

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