The next step in benchmarking NYC buildings

A proposed bill would expand NYC’s annual energy and water benchmarking law to buildings larger than 10,000 square feet.

Original publication by Urban Green Council • March 5, 2025

This article was originally published in December 2022. It was updated on March 5, 2025 with new data and analysis in light of a more recent version of the same City Council bill and renewed interest from Urban Green and other environmental groups.

Intro 185: A proposed City Council bill would extend benchmarking requirements to report annual energy and water use to buildings over 10,000 square feet (SF). Benchmarking is already a well-established requirement for NYC buildings over 25,000 SF. If passed, this bill would require about 22,000 new, smaller properties to disclose data.

Why It Matters: Buildings contribute more than two-thirds of NYC’s carbon emissions. Benchmarking data reveals insights that can help owners and tenants improve efficiency, lower carbon and save money. The robust energy data we already have from large buildings sets a crucial baseline for decision makers to measure climate progress, promoting accountability and informing smart policies like Local Law 97. Lowering the size threshold would give us information about energy use in a broader set of buildings.

Benefits of benchmarking down to 10,000 SF

Empowers owners with energy insights: Whole-building energy data can be used to inspire efficiency improvements, compare performance with similar properties, and track progress.

Drives the market for efficient buildings: Public data helps push demand for efficiency and highlights opportunities for operators and service providers to make energy-saving upgrades in thousands of new buildings.

Guides equitable solutions for tenants: Increases transparency for those living in NYC’s small multifamily buildings and can guide improvements that address energy burdens and housing quality.

Allows for simple, low-cost reporting: Compliance is easy and affordable with automatic utility data upload and existing tools like ENERGY STAR Portfolio Manager.

Advances NYC’s climate strategy: Unlocks new data to drive further energy and carbon savings in buildings, NYC’s highest-emitting sector.

History

In 2009, Urban Green helped advance Local Law 84, which required benchmarking for buildings over 50,000 SF—roughly 16,000 total properties—and municipal buildings larger than 10,000 SF. But today’s proposed change would not be the first time NYC lowered the benchmarking size threshold. In 2016, the law was expanded to all buildings over 25,000 SF—adding roughly 10,000 newly covered properties. 

Extending benchmarking requirements to all buildings over 10,000 SF would nearly double the number of properties that NYC has annual energy data for. And we would not be the first city to do so. San Francisco and Washington D.C. already benchmark private buildings over 10,000 SF, while Fort Collins, CO includes those over 5,000 SF. 

Benchmarking can kickstart progress in a new group of buildings

To date, most NYC climate policy has pertained to buildings over 25,000 SF, and has been significantly shaped by benchmarking data. But 33 percent of greenhouse gas emissions in 2023 came from the city’s one million smaller buildings. Little is known about their energy use, making them a critical but overlooked piece of NYC’s climate strategy. 

Benchmarking offers an easy first step to spur action in buildings down to 10,000 SF. It requires only annual energy reporting, not retrofits, but lays the groundwork for smarter energy management. The EPA estimates that benchmarked buildings cut energy use by around 2.4 percent per year. And the data can motivate new efficiency work when it is used to inform tailored building improvements, project energy bill savings, and create energy scorecards like NYC’s energy grades.

NYC’s comprehensive benchmarking dataset tells the success story of the city’s large and midsize properties:

• Carbon emissions dropped 26 percent since 2009;
• 77 percent of facility managers made operational improvements, and 75 percent invested in new equipment in response to the law; and
• Site energy use declined 10 percent in mid-sized buildings between 25,000 to 50,000 SF after the law was expanded in 2016 to cover them.

Extending benchmarking again to properties over 10,000 SF can unlock similar gains and drive progress toward NYC’s climate goals. 

A win for NYC residents in small multifamily buildings

Benchmarking offers a path to energy savings for more New Yorkers. The most common type of building between 10,000 to 25,000 SF —about 38 percent—are multifamily walk-ups with more than six units. These buildings have historically lacked incentives for efficiency upgrades, leaving residents with higher utility costs and poorer living conditions.

Benchmarking can change that. Understanding energy use trends can inspire operational improvements that lead to lower bills, cleaner air and healthier homes. The data can also help decision makers center equity as they navigate climate solutions for smaller buildings. For example, exposing where inefficient properties overlap with environmental justice areas can help ensure resources are directed to where they’re needed most.

As NYC transforms its building stock to meet climate goals, small multifamily buildings can’t be left behind. Data is the foundation for energy management, and benchmarking would shed light on these overlooked properties, laying the groundwork for targeted strategies that meet their unique needs.

Supporting owners new to benchmarking

Reporting annual data is fairly straightforward, but benchmarking may be new for owners of buildings between 10,000 to 25,000 SF. If they have fewer staff or less experience managing energy use, a little extra help could go a long way.

Luckily, some easy-to-follow steps already exist that will be critical to ensuring the benchmarking process is accessible for small buildings too:

1. Automated upload of utility data

Utilities are required to enable the automatic upload of whole building electricity and gas data to ENERGY STAR Portfolio Manager for buildings in NYC that currently benchmark. Automating the data upload streamlines reporting for owners and preserves data quality with fewer errors. It’s critical that smaller buildings in NYC have this capability if they are required to benchmark.

2. Robust support from a help center

Newly covered buildings would benefit from some extra hand-holding in their first reporting year. Currently, NYC offers a free assistance service via its NYC Sustainability Help Center. Ensuring that trained staff are available to answer questions, walk building owners through the benchmarking process, and provide training and informational resources will be key for smaller buildings as they get the hang of a new process. The Help Center can be accessed by emailing Help@NYCsustainability.org or calling (212) 566-5584.

Further reading