The Cotocon Group: "2026 Is a Full Reset Year"
"2026 is one of those years where everything comes back into focus at once. Benchmarking, emissions reporting, energy grades, and audit cycles all converge. Buildings that plan ahead will have options. Buildings that wait will be reacting under pressure."
This warning from one of NYC's leading compliance advisory firms should be on every building owner's desk. The days of siloed compliance are over. The DOB is now coordinating enforcement across four separate laws simultaneously.
March 31
LL87
Energy Audit & Retro-Commissioning (2025 cycle)
⚠️ Physical inspection requiredMay 1
LL84 + LL97
Benchmarking filing + Emissions Report
⚠️ $268/ton fines collectedOct 31
LL95
Energy Grades posted at ALL public entrances
⚠️ Public visibility📅 The 2026 Deadline Wall
| Deadline | Law | Requirement | Penalty for Non-Compliance |
|---|---|---|---|
| March 31, 2026 | LL87 | Energy Audit & Retro-Commissioning Report due (2025 cycle) | No cap; DOB can issue violations, stop work, or revoke permits |
| May 1, 2026 | LL84 | Annual Benchmarking filing (2025 data) | $0.50/sq ft/month + public "F" grade |
| May 1, 2026 | LL97 | Annual Emissions Report (2025 data) | $268/metric ton over cap + interest on 2024 penalties |
| Oct 31, 2026 | LL95 | Energy Grade posted at all public entrances | $1,250 per violation (per door) |
⚠️ The Trap: Cross-Referenced Enforcement
If your LL84 benchmarking shows a sudden spike in energy use, the DOB will cross-reference your LL87 audit. If the audit shows deferred maintenance, the DOB will assume your LL97 report is inaccurate. You are no longer judged on a single filing—you are judged on consistency.
🔍 What the LL87 Auditor Actually Measures
What they measure: Exhaust gas temperature.
What it indicates: High stack temperature = scale insulation = heat going up chimney instead of into water.
The flag: Stack temp > 100°F above design = immediate efficiency loss flag.
What they measure: Temperature difference between inlet and outlet.
What it indicates: Low delta-T = fouled heat transfer surfaces = scale buildup.
The flag: Delta-T below 80% of design = replacement recommendation.
What they measure: Temperature of water returning to boiler from recirculation loop.
What it indicates: Cold return = heat loss in pipes = internal scale or insulation failure.
The flag: Return below 110°F = system inefficiency.
⚖️ The Good Faith Trap: What the DOB Is Now Asking
Building owners who filed Decarbonization Plans in 2025 believe they are protected until 2030.
They are partially correct. And that partial correctness is dangerous.
The DOB is now auditing "Good Faith" claims. They are asking:
"You said you would install heat pumps by 2028. That is great. But why did you let your existing boiler deteriorate so badly that it is emitting 30% more carbon today than it did in 2023?"
"Where is your maintenance documentation? Show us what you did to maintain the equipment you are still using."
Negligence is not "Good Faith." If you ignore the equipment you currently own, the DOB can revoke your extension and impose retroactive penalties.
🥚 Real Proof: Burnbrae Egg Farm Protects Entire Water System
Facility: Burnbrae Farms (Canada) — evolved into egg production in the 1940s, now an integral part of Canadian agribusiness, offering innovative products such as omelettes, liquid and hard-boiled eggs. Today, Burnbrae Farms eggs and egg products can be found in local grocery stores, restaurants, food-service operations, and homes across Canada.
The Challenge: Managing mineral scale across the entire farm's water piping system. Scale buildup was affecting water flow, equipment efficiency, and requiring frequent maintenance.
The Solution: Vulcan mineral descaler installed for the entire Burnbrae Farms water piping system — protecting every pipe, valve, and piece of equipment.
The Result:
- Complete system protected from scale
- Reduced maintenance across entire facility
- No chemicals, no salt, no ongoing costs
The Lesson: If Vulcan can protect an entire agricultural water system across decades-old pipes, it can protect your building's mechanical systems from the LL87 auditor's scrutiny.
Burnbrae Farms — Entire water piping system protected
⏰ The 60-Day Window: Act Before March 31
You have approximately 60 days before the March 31 LL87 deadline to perform internal inspections and install remediation equipment.
Immediate Action Items:
- Pull your 2015 LL87 audit. Compare equipment conditions then vs. now.
- Measure hot water return temperatures. Below 110°F = problem.
- Boroscope boiler tubes. Buildup thicker than a credit card = money lost.
- Contact Vulcan for a site assessment and pre-installation efficiency baseline.
✅ How Vulcan Prepares You for the LL87 Audit
Pre-Audit Documentation
Installation date + pre-installation efficiency measurements = proof you are proactively maintaining equipment.
Restored Delta-T
Heat exchangers return to manufacturer-specified temperature differential. Auditors see "properly maintained."
No Replacement Required
Auditor's verdict: "Verified efficiency improvement. No replacement required."
Good Faith Exhibit A
When DOB asks "What did you do to maintain equipment?", Vulcan is your answer.
When to Prioritize Vulcan Before March 31
- Immediate Priority: Any building with LL87 audit due March 31, 2026.
- High Priority: Buildings with boilers >20 years old or unknown maintenance history.
- Measured Deficiency: Any building where pre-audit inspection shows delta-T below 80% of design.
- Good Faith Documentation: Any building relying on "Good Faith" extension needs verifiable maintenance proof.
- Any Building With: Heat exchangers, boilers, cooling towers, or recirculating hot water systems. If it transfers heat to water, it scales. If it scales, the auditor flags it.
Don't Let the Auditor Find What You Could Have Fixed
60 days until March 31. Every day of scale is a day closer to a failed audit.
About the Author
Waslix- Clearly Clean Water (Vulcan Mineral Descaler) provides non-chemical, maintenance-free scale prevention solutions for commercial, industrial, and residential buildings. Vulcan is trusted by farms, hospitals, hotels, and industrial facilities worldwide.
