Lamp Enforcement

New York City’s dense urban landscape is populated with more than a million buildings that annually consume $15 billion in energy and generate 75 percent of the city’s carbon emissions. The 22,000 largest buildings, concentrated largely in Manhattan, account for roughly 45 percent of total floorspace and energy consumption. Lighting is a major energy user, responsible for nearly 18 percent of energy consumption and resulting carbon emissions.

To reduce energy costs and carbon emissions, the New York City Council enacted major energy legislation on Dec. 9, 2009, that includes an ambitious law requiring large commercial buildings to upgrade their lighting systems. While this legislation has the immediate effect of creating instant opportunities for electrical contractors doing business in the city, it may have a more long-range and far-reaching effect if the policy proves successful in getting existing buildings to implement better energy efficiency.

Int. No. 973-A, which took effect immediately, requires large commercial buildings to upgrade their lighting by Jan. 1, 2025. Specifically, the law applies to buildings larger than 50,000 square feet, buildings combining with other buildings on the same tax lot to exceeding 100,000 square feet in total, and buildings held in the condominium form of ownership governed by the same board of managers and together exceeding 100,000 square feet in total. Another provision requires these buildings to submeter tenant spaces larger than 10,000 square feet and provide this information to the tenants, including monthly statements of electricity consumption and costs.

The law defines a lighting upgrade as meeting the minimum requirements of the New York City Energy Conservation Code (NYCECC). Exceptions include residential living spaces; spaces serving these living spaces such as laundry rooms; boiler rooms; hallways, stairways and corridors used for egress; emergency or security areas; assembly spaces in houses of worship; and lighting that meets code installed on or after July 1, 2010. The code has its own exceptions.

The NYCECC is based on the New York state energy code, with amendments making it more stringent. The 2007 state code is, in turn, based on the 2003 version of the International Energy Conservation Code (IECC) model energy code, with amendments, while referencing American Society of Heating, Refrigerating, and Air-Conditioning Engineers 90.1-2004 as an alternative standard. The lighting section of the code includes mandatory and prescriptive requirements for lighting controls (interior lighting controls, light-level reduction controls and automatic lighting shutoff), tandem wiring, exit signs, interior lighting power caps and exterior lighting. In September, New York state will adopt the 2009 IECC, which also includes separate control for daylight zones.

To demonstrate compliance, the owner must file a report with the New York City Department of Buildings, prepared by a registered design professional or a licensed master or special electrician, certifying that the lighting upgrade has been completed and that the work is in compliance with the technical standards of the city’s electrical code.

Speaking of the city’s energy code, Int. 564-A, enacted at the same time, refreshed the New York City Energy Code, closing the loophole enabling buildings to perpetuate noncompliant building systems if the owner performs a renovation on less than half of a given building system. Out of more than 40 states based on the IECC, only New York state exempted minor renovations. Starting July 1, 2010, all renovations requiring a building permit, even small ones, must demonstrate compliance with the city’s energy code.

Int. 973-A, however, does not explicitly spell out what version of the code must be complied with, based on when the lighting upgrade is completed. If the upgrade occurs in 2024, does the owner have to comply with, today’s energy code or whatever version of the code is in effect in 2024? As it is written, the language suggests to use whatever version is in effect at the time. This means building owners interested in managing risk might find it prudent to upgrade now rather than putting it off to the last minute, or else be forced to upgrade to a much stricter code than what is now in effect.
That’s not all it calls for. Int. No. 476-A requires large building owners to make an annual benchmark analysis of energy consumption to enable owners, tenants and potential tenants to compare energy consumption of different buildings. Int. No. 967 requires large private buildings to conduct energy audits once every 10 years and implement energy-efficient maintenance practices; all city-owned buildings larger than 10,000 square feet, meanwhile, will be required to conduct audits and complete energy-efficient retrofits that pay for themselves within seven years.

Critics of the legislation say building owners have too long to upgrade their lighting and that the code lacks a mechanism forcing them to do so. Proponents of the legislation welcome what is arguably the country’s most ambitious initiative to increase the energy efficiency of existing buildings, where energy-efficiency measures can have the biggest impact. Either way, for electrical contractors in New York, it means opportunity.

To read the text of Int. No. 973-A., visit, type “Int 0973-2009” in the search box, and click the Text tab.

DILOUIE, a lighting industry journalist, analyst and marketing consultant, is principal of ZING Communications. He can be reached at

About the Author

Craig DiLouie

Lighting Columnist
Craig DiLouie, L.C., is a journalist and educator specializing in the lighting industry. Learn more at and .​

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