- The 1st 4 year cycle for Local Law 152 started on January 1st, 2020 and ended on December 31st, 2023.
- Each cycle year had the ability to defer the inspection to June 30th of the following year. IE: For 2023, an extension was available to June 30th, 2024.
- Cycle 1 saw some legislative iterations to the law along with new rules established by the NYC DOB.
- The 2nd 4 year cycle which runs through December 31st, 2027 started January 1st, 2024.
- As this second cycle progresses, the process has become significantly clearer for all stakeholders due to the valuable feedback provided over the last four years by plumbing industry trade associations, building owners, property managers, and Local Law 152 inspectors to the NYC Department of Buildings.
This page provides a series of questions and answers designed to highlight the key changes you need to be aware of for Cycle 2.
This page went live 8-6-2024 and will be periodically updated as more information is available.
In the meantime, if you have a question about anything that has not been addressed here or there is something that was addressed that you are not clear about; then feel free to click HERE and contact me.
Disclaimer:
All information presented throughout this site is relied on by us to the extent of our interpretation and is not in any form intended to be relied on as legal advice by any user of the information.
For legal advice all users are directed to review with their legal counsel.
What does the email notification and/or postal mail notification that was recently received from NYC DOB regarding Local Law 152 mean?
Starting around mid June 2024 the NYC DOB began sending emails and/or postal mail to owners to advise them of their Local Law 152 Cycle 1 compliance status.
One of 2 scenarios exist:
- You complied and had an inspection completed during cycle 1 and you are being notified in which year; 2024, 2025, 2026 OR 2027 that your next inspection is due for cycle 2.
- You did not have an inspection during cycle 1 and you are being notified that you will receive a NOD (Notice of Deficiency) for cycle 1 that does not carry a civil penalty. You are also being notified in which year; 2024, 2025, 2026 OR 2027, your next inspection is due for cycle 2 and that if you have an inspection done that the NOD will be dismissed. Failure to have an inspection in cycle 2 will carry a civil penalty of $5,000.
What if I had an inspection completed, as required, during cycle 1 and I had conditions to be corrected but did not have the conditions corrected. Am I subject to a civil penalty?
In July of 2024 KeepMyGas corresponded via email with the Local Law 152 area of the NYC DOB Plumbing Enforcement department and asked:
If an owner received and email and/or letter from the DOB indicating that “You have complied with Cycle 1” and during cycle 1 conditions requiring correction were identified on the GPS1 form and those items identified on the GPS1 have not been corrected yet will the owner be subject to a civil penalty for failure to file a new GPS2 within the 6 months allotted to indicate that the conditions identified have been corrected?
The department responded:
If the conditions were not corrected and the deadline was not met then they are not in compliance and will receive a notice of deficiency. This notice can be cured when inspections are done in cycle 2. Be advised that an NOD will not be issued next go around, a civil penalty will.
KeepMyGas interprets this to mean that so long as the corrections are made prior to the inspection to be completed in cycle 2 that the building owner will not be subject to a civil penalty for failure to make the cycle 1 corrections.
With that said, it is recommended that should this be your scenario that you contact us for additional guidance for your specific situation. Click HERE for our contact form.
Possible upcoming changes to Local Law 152 from the NY City Council.
On 2/28/2024 the NY City Council introduced Int 0429-2024 which would amend among other things, certain provisions of Local Law 152.
Click HERE to see Int 0429-2024 on the Legislation page of the NY City Council website. You can download a word doc of Int 0429-2024 HERE.
Take note of – page 4, § 28-318.3.2 Scope, lines 10 to 30. This appears to increase the scope of the inspection to include any commercial space with gas utilization equipment in any building to be inspected. This additional space in a building has not previously been part of the Scope of a Local Law 152 inspection.
Take note of – page 4, § 28-318.3.4 Reporting and correction of, lines 33 to 39 AND page 5, lines 1 to 30. This appears to define that certain conditions observed at a Local Law 152 inspection will not be required to be corrected if they do not pose an immediate hazard.
Take note of – page 5, lines 31 to 34. This gives the impression that the section of the law that required the inspection of buildings that do not have gas service will be repealed.
The City Council Committee on Housing and Buildings has a session scheduled on 10/08/2024 in the Council Chambers at City Hall.
Click HERE to see the calendar for the City Council Committee on Housing and Buildings and then click on Meeting Details & Agenda for the 10/08/2024 listing for more details.
We encourage you to attend on 10/08/2024 so you may have an impact on the final outcome of Int 0429-2024.
Is there an official NYC Buildings (AKA Department of Buildings DOB) web page that has a Step-by-Step Guide to Complying with Local Law 152 of 2016 Periodic Inspections of Gas Piping Systems?
Yes there is!
NYC Buildings, AKA The NYC Department of Buildings (DOB) has set up a special page for building owners to help them navigate the requirements of LL152 and coach you on the diligence to complete when you hire a Licensed Master Plumber to Inspect Your Building’s Gas Piping System.
You may access that page here: https://www1.nyc.gov/site/buildings/homeowner/local-law-152-of-2016.page
