ll154-frequently-asked-questions

Buildings


Code DevelopmentNYC CodesSustainabilityReference

Greenhouse Gas Emissions Reduction (LL97)
NYC Benchmarking Law (LL84)
Energy Grading (LL33)
Energy Audits & Retro-Commissioning (LL87)
Lighting Upgrades & Sub-Metering (LL88)
Solar & Green Roofs (LL92 & LL94)
Building Electrification (LL154)
NYC Energy Conservation Code

Greenhouse Gas Emissions Reduction (LL97)

NYC Benchmarking Law (LL84)

Energy Grading (LL33)

Energy Audits & Retro-Commissioning (LL87)

Lighting Upgrades & Sub-Metering (LL88)

Solar & Green Roofs (LL92 & LL94)

Building Electrification (LL154)

NYC Energy Conservation Code


Local Law 154 of 2021 Frequently Asked Questions

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Click a topic, or press the enter key on a topic, to reveal its answer.

Are existing buildings (not new construction) allowed to convert from oil to gas?

Yes, there is no requirement in the law that states that they cannot.

If there are plans for an existing building to be torn down and rebuilt, safety procedures require the natural gas utility to cut the gas service and then reinstall one (DnR) when construction is complete. Since this property already had gas service, will they get their gas service back?

Work that requires an application for a New Building or Alt-CO New Building with Existing Elements to Remain (alteration that must be filed as New Buildings as per Section 28-101.4.5) is subject to the combustion emissions limits under the law, unless it falls into one of the exceptions provided.

If a customer has an existing natural gas account, adds equipment, and now requires a larger gas service, is the utility allowed to upgrade the gas service to the property?

Yes. As long as the change does not constitute an alteration that will result in a change of certificate of occupancy (an Alt-CO New Building with Existing Elements to Remain application).

If a natural gas utility customer adds an extension to their existing building and they need a larger service, is the utility allowed to provide this? For example, a school adds an annex or a gymnasium.

If the alteration increases the floor surface area by more than 110% of the existing floor surface in accordance with Section 28-101.4.5, then no.

How do you count individual unit owners (coops, condos, townhouses, etc.) towards the 7-stories over/under total? One owner owns one floor, but the building could be multi-story.

Buildings will be considered as a whole for LL154, not based on partial ownership of individual floors.

If there are multiple buildings on a property all served by one gas service/meter/account, does that add up to the 7-story over/under threshold? For example, an office building upfront with additional production shops or garages at the rear the property.

No. LL154 applies to an individual building, as a whole, and not multiple buildings together.

If a building already has an active service and the building is subdivided into multiple units would the new units be allowed to request their own accounts/meters? For example, changing an office building into residential units.

Yes. As described, LL154 does not apply in this situation.

If the utility receives an application for gas service prior to Jan 2024, how long can the utility “hold” that request and still install a gas service once the building is ready for a gas service? New construction can take many years. A gas service is one of the last things to get installed.

The law states that the application for the approval of construction (New Building or Alt-CO New Building with Existing Elements to Remain) must be submitted to DOB before Jan 2024. Note that the exceptions provided in the law receive alternative deadlines.

If a building has a gas service but the meter was removed for non-payment, non-use, construction, etc. and now the customer is reconfiguring the interior and wants to re-establish a gas account, is the utility allowed to do this?

Yes. As long as the change does not constitute an alteration that will result in a change of certificate of occupancy (an Alt-CO New Building with Existing Elements to Remain application).

If a building owner applies for gas service prior to Jan 2024 and is rejected but conditions change later (revised application, entire redesign, community input, different planned usage, zoning change, re-reviewed, etc.) and it now meets qualifications, can the utility give them a gas service?

The effective date of application will be based on when the initial GC filing is submitted in DOB NOW. If the GC application is submitted prior to the implementation deadline, then that entire application will not be subject to LL154. The application will go through a plan review process where DOB provides objections to plans and the applicant revises them. If there is a major redesign to the initial application, then it will need to be resubmitted as a new, separate application, which will trigger LL154 compliance if submitted after the deadline.

If a natural gas customer on an interruptible (temperature-controlled) gas rate requests to switch to a firm (non-interruptible) gas rate, is that allowed after Jan 2024? What if they need a service upgrade to do this?

In preexisting buildings, a service change of this kind will not be affected by LL154. LL154 applies to work that requires an application for a New Building or Alt-CO New Building with Existing Elements to Remain (alteration that must be filed as New Buildings), unless it falls into one of the exceptions provided.

As a regulated utility, National Grid is obligated to provide gas service to anyone that submits a request. Does this take precedence over LL154?

No.

LL154 states, “The commissioner shall not approve an application for the approval of construction documents…” What data does the NYC DOB have on record to show that an application was submitted to NYC DOB, reviewed, and approved to get a gas service? What information can we request or look up on the DOB website (or obtain from the customer, plumber, builder, architect) to show they have approval for their job?

The effective date will be based on when a complete GC filing is submitted in DOB NOW. If the complete GC application is submitted prior to the compliance date, then that entire application is not subject to LL154. If the GC application is submitted on or after the compliance date, then the entire application is subject to LL154.

How is this new legislation being communicated to customers, plumbers, etc.? We would suggest outreach similar to Dept of Sanitation’s recent efforts around the revised rules to prevent rats by placing garbage at the curb later. This was a great example of an overabundant, clear communication plan through multiple channels.

Currently, DOB’s Sustainability Bureau conducts outreach regarding local law compliance and other matters related to sustainability. Furthermore, there is an existing infrastructure for receiving questions through email and providing responses from the proper units within DOB. We are in the process of adding an outreach package and communications plan specific to LL154, consistent with our current framework.

Is there a website, flyer, Technical Bulletin, hotline, etc. that a utility can tell customers about?

Currently, DOB’s Sustainability Bureau conducts outreach regarding local law compliance and other matters related to sustainability. Furthermore, there is an existing infrastructure for receiving questions through email and providing responses from the proper units within DOB. We are in the process of adding an outreach package and communications plan specific to LL154, consistent with our current framework.

Who is the main point of contact at DOB for these questions that we can point customers to if needed? The utility is receiving lots of questions and we cannot make a final decision on the interpretation of NYC regulations.

sustainability@buildings.nyc.gov