Avoiding Penalties: Best Practices for Timely Benchmarking Submissions

Local Law 84

Staying compliant with energy benchmarking laws isn’t just about sustainability — it’s about avoiding costly penalties. Local Law 84 and LL133 New York mandate that buildings track and report energy and water usage data annually. Failing to meet these deadlines can result in fines that add up quickly.

To help building owners, property managers, and real estate professionals stay ahead of the curve, this guide shares best practices for timely benchmarking submissions. Whether you’re new to NYC Local Law 84 or just want to avoid last-minute scrambling, following these practices can ensure compliance and help your property remain penalty-free.

Understanding Local Law 84 and LL133 New York

Local Law 84, also known as the NYC Benchmarking Law, requires owners of large buildings to annually measure and report their energy and water consumption to the City of New York. The law applies to:

  • Buildings over 25,000 square feet
  • Two or more buildings on a single lot with a combined area of 100,000 square feet or more
  • Condominium properties where the combined square footage exceeds 100,000 square feet

In 2016, LL133 New York expanded the benchmarking requirement to include mid-size buildings between 25,000 and 49,999 square feet. This widened the scope of compliance and emphasized NYC’s commitment to energy transparency.

These benchmarking reports provide valuable data to the city and building owners. It helps identify opportunities to improve energy efficiency, reduce emissions, and lower operating costs.

The Importance of Timely Submissions

Every year, benchmarking data must be submitted by May 1st. Missing this deadline triggers penalties that start at $500 per quarter, totaling up to $2,000 annually. Worse, multiple violations could tarnish your building’s record and lead to further scrutiny or compliance issues down the line.

Submitting on time ensures:

  • Compliance with NYC Local Law 84
  • Avoidance of financial penalties
  • Access to energy efficiency performance insights
  • A better ENERGY STAR score and potential energy savings

Why Submissions Are Often Delayed

Many building owners don’t realize that benchmarking isn’t just a one-click process. Delays often happen due to:

  • Missing utility data
  • Incomplete or inaccurate building information
  • Not assigning a benchmarking coordinator early
  • Lack of familiarity with the ENERGY STAR Portfolio Manager tool
  • Unawareness of changes in requirements (such as those introduced by LL133 New York)

Each of these issues can slow down the process. That’s why proper planning and guidance are essential.

Also Read: You Need to Know about NYC Local Law 97 Compliance

Best Practices for Timely Benchmarking Submissions

1. Start Early — As Early as January

Waiting until April to begin your benchmarking report is a mistake. Start as early as January to give yourself ample time to:

  • Gather utility data
  • Verify building details
  • Resolve data discrepancies
  • Review past year’s submissions

Starting early avoids the last-minute rush and allows time for quality checks.

2. Assign a Responsible Benchmarking Coordinator

Designate a staff member or hire a Local Law 84 Consultant Service to take ownership of the process. This person (or firm) should:

  • Be trained in the use of ENERGY STAR Portfolio Manager
  • Be familiar with the specific requirements of NYC Local Law 84
  • Have access to the building’s utility data and occupancy records

If managing in-house isn’t feasible, outsourcing to a trusted Local Law 84 Consultant Service ensures expert oversight and peace of mind.

3. Keep Utility Data Organized Year-Round

Utility data is the backbone of accurate benchmarking. To prevent delays:

  • Use an automated system or spreadsheet to track monthly usage
  • Create reminders to collect missing bills or meter readings
  • Sign up for utility data upload tools like Con Edison’s Green Button or DEP’s automatic data transfer system

Organizing this data regularly saves time when submission season rolls around.

4. Verify Property Details Every Year

Before submitting, double-check your Portfolio Manager profile to ensure:

  • Gross square footage is accurate
  • Property type is correctly classified
  • Ownership and contact details are current

Even small discrepancies can lead to errors or rejections by the City.

5. Stay Informed About Updates to the Law

NYC frequently updates energy laws and requirements. Stay informed on:

  • Threshold changes (like those introduced under LL133 New York)
  • New compliance deadlines
  • Additional data points that must be reported
  • Adjustments to fines and penalties

Subscribing to city newsletters or working with a Local Law 84 Consultant Service helps you stay up to date.

6. Perform a Pre-Submission Review

Before clicking submit:

  • Run Portfolio Manager’s data quality checker
  • Compare results with last year’s submission
  • Look out for unusually high or low readings
  • Ensure each field is complete and aligns with NYC requirements

A final review can catch mistakes and prevent future corrections or penalties.

7. Submit Ahead of the May 1 Deadline

Aim to submit at least 2 weeks in advance of the deadline. This buffer gives you time to troubleshoot submission errors, respond to feedback, or re-upload missing documents without risking late fines.

8. Keep a Record of Your Submission

Once submitted:

  • Download and save a PDF of your benchmarking confirmation
  • Store email receipts from the NYC Department of Buildings
  • Keep a record of your ENERGY STAR report for at least 3 years

Good recordkeeping helps in audits or disputes and ensures you’re covered in case of system issues or data loss.

The Role of a Local Law 84 Consultant Service

Managing benchmarking in-house can be complex and time-consuming, especially for large or multi-use buildings. A Local Law 84 Consultant Service can:

  • Handle data collection and submission on your behalf
  • Ensure compliance with both Local Law 84 and LL133 New York
  • Minimize errors, delays, and the risk of penalties
  • Provide insights into energy usage trends and reduction strategies

Many NYC building owners work with sustainability consultants like The Cotocon Group to manage their annual benchmarking and ensure they remain compliant.

How The Cotocon Group Helps

As a leader in Sustainability Consulting Services, The Cotocon Group specializes in helping NYC buildings meet energy benchmarking laws. Their team offers:

  • Expert guidance on energy and water data reporting
  • Assistance with Portfolio Manager setup and maintenance
  • Ongoing support for Local Law 84 and LL133 New York compliance
  • Energy efficiency strategies based on your building’s performance data

The Cotocon Group ensures your benchmarking submissions are not only timely but also insightful — helping you plan smarter building upgrades in the future.

What Happens If You Miss the Deadline?

Missing the May 1 deadline results in:

  • $500 fine per quarter
  • Up to $2,000 annually for non-compliance
  • Potential inspection or further scrutiny by city officials
  • Negative impact on your building’s environmental score

These penalties are easily avoidable with a bit of planning and the right support system.

Conclusion: Don’t Let Benchmarking Be an Afterthought

Annual benchmarking under NYC Local Law 84 and LL133 New York is a critical compliance task for building owners. With deadlines strictly enforced, timely submission is the only way to avoid penalties and improve your building’s energy efficiency.

By following the best practices shared in this article — starting early, staying organized, verifying data, and working with a Local Law 84 Consultant Service — you can ensure your property remains in good standing.

Benchmarking isn’t just a compliance requirement. It’s an opportunity to understand your building better, identify areas for improvement, and reduce operating costs. Don’t wait until the last minute. Make energy compliance a priority, and your building (and budget) will thank you for it.

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