Local Law 87 and How It Supports Local Law 97 Compliance
If your building's tax block number ends in the digit "6," this is your filing year, and your Energy Efficiency Report (EER) is due to the Department of Buildings by December 31, 2026. Local Law 87 requires buildings over 50,000 square feet to complete a full ASHRAE Level II energy audit and retro-commissioning study once every ten years, evaluating how your building's HVAC, lighting, domestic hot water, and control systems are performing. The process typically takes more than a year from start to finish: the engineer needs to audit your building's systems during both the heating and cooling seasons to properly test equipment under both conditions, and only after that audit is complete can the building begin implementing its retro-commissioning measures.
Because the audit and retro-commissioning process can take significant time, buildings should not wait until their filing year to begin. If your tax block ends in "7," "8," "9," or "0," there is real value in engaging an engineer now so the required audit, testing, and retro-commissioning work can be completed well in advance of the applicable filing deadline. This work is allowed to be started up to four years in advance of the deadline. Each cycle tends to see a wave of last-minute sign-ups from that year's group, as we're seeing now with the 2026 buildings, but for the 2027 group, this fall is really the last practical window to start without risking an extension or delay. If your building falls outside that four-year early-start window, an off-cycle engineering study may still be worth considering to get ahead of 2030 LL97 exposure.
While Aurora is not a Registered Design Professional (RDP) with the certification to complete the LL87 filing itself, we work with a number of qualified engineering firms who specialize in this work, and we can help coordinate proposals if needed.
Here's why this filing is worth taking seriously beyond simply avoiding the penalty, which runs $3,000 for the first year and $5,000 annually after that. An LL87 report actually contains two distinct pieces. One covers the retro-commissioning measures, which are mandatory corrections to your building's systems, and which tend to be smaller in scope but still contribute to your building's overall emissions picture. The other covers broader energy efficiency projects, which aren't required by LL87 itself but are recommended because they may carry a strong return on investment. Both categories matter for Local Law 97. The report from our recommended engineering firms will show each project's ROI and its impact on your building's LL97 emissions, so you can see which measures are worth prioritizing.
Some of these recommended projects are worth pursuing now rather than later, since most buildings are facing LL97 penalties starting in 2030 when emissions limits become significantly stricter. Larger projects in particular require lead time, both to plan with an engineer and to secure funding, so the years remaining before 2030 shrink quickly once that lead time is factored in. Acting sooner also has a compounding benefit. Completing a project earlier gives you a full calendar year of post-project emissions data to establish a new baseline against the 2030 limit. That tells you whether you've already closed the gap, or exactly how much further reduction you still need, well before the deadline is bearing down on you.
If your building has already completed an LL87 filing in a past cycle, that report is still worth revisiting. We're reaching out to clients now to collect historical LL87 reports from the last several years so we can sit down together and review what was found, what was implemented, and what may still be worth pursuing as an LL97 strategy.
Separately, this is also a reminder about Local Law 95 energy grades. Buildings over 25,000 square feet are required to post their updated Building Energy Efficiency Rating Label, the letter grade based on your building's ENERGY STAR score, at each public entrance. The Department of Buildings makes the new grade available for download starting October 1, and it must be printed and posted by October 31. Missing it carries a $1,250 fine per year, and the grade must stay posted through the following October. Not every building receives an A through F grade. Some are issued an "N/A" instead, typically because certain building characteristics disqualify it from receiving a score. This year's grades should already be available, so it's worth checking the DOB NOW portal now.
Whether your building is filing this year, several years out, or somewhere in between, the earlier you start the LL87 process, the more useful it becomes, both as a compliance requirement and as a roadmap for your building's Local Law 97 path. Reach out to your Aurora Energy Advisors contact to talk through where your building stands and what the right next step looks like.
Market Analysis
Natural Gas
The October NYMEX contract expired on September 28, settling at $3.00 per MMBtu after climbing from the high $2.80s in late August to a roughly 2.5-month high near $3.20 in the week before expiration. The rise was driven by forecasts for lingering summer-level heat and a force majeure declared on TC Energy's Mountaineer Xpress pipeline in West Virginia, which raised concerns about Northeast supply. Prices dropped sharply on the contract's final trading day once TC Energy lifted the force majeure, restoring flows and easing that supply concern just as seasonal demand began to fade.
Electricity
NYISO Zone J wholesale electricity prices generally ran in the 3 to 5 cent per kWh range through September, a step down from prior-month levels. A warmer stretch from September 14 through 18 pushed prices to the higher end of that range, peaking on September 17 at just over 6 cents per kWh, before settling back toward the lower end for the final third of the month. With the region now firmly in the fall shoulder season, prices should stay relatively calm in the near term, though winter weather forecasts and actual cold snaps later in the season will be the next real test for NYISO pricing.
Crude Oil
WTI swung sharply in September as tensions between the U.S. and Iran escalated, ending a period of relative calm that had held since July. Prices climbed from the mid-$80s to the mid-$90s in the first half of the month, while Brent, the international benchmark, moved further, touching just above $108 intraday and settling above $100 on more than one occasion. Prices retreated in the back half of the month on renewed diplomatic talks and rising Middle East exports, with WTI settling around $89 to $90 a barrel by month's end as Saudi Arabia and the UAE ramped up shipments.
💡 Mitchell’s Tip: Invest in energy efficiency projects.