The change that converts a one-off into a recurring cost

This is the part that is genuinely new and genuinely counterintuitive. From the April 2026 Service Update, describing the 1 RCNY § 103-10 amendments:

“The [no-gas-service utility statement] is required to be submitted every cycle, rather than once.”

And, by contrast:

“The certification stating that a building has no gas piping system is only required to be submitted once, rather than for every cycle. Also, this certification can now come from a utility company.”

So there are two different situations with opposite treatment. A building that has no gas piping at all certifies once, for $375, and is done. A building that has piping but no longer receives service — which is precisely the position of a building that electrified — must re-file every four years, at $480 each time.

And Local Law 142 tightened what that filing must say. The utility statement must now include “a certification that the building no longer receives gas service, including the last date upon which gas was supplied” and “a certification that the building was fully deactivated from service being provided by the utility, including the date upon which gas service was no longer provided.”

Getting a utility to produce a dated deactivation certification is not a five-minute task. A board that deactivated years ago and did not keep the paperwork has work to do.

The tension is worth naming plainly. Local Law 97 penalises a building for burning fossil fuel and rewards it, through the beneficial-electrification coefficient, for getting off gas. Local Law 152, as amended, then charges that building $480 every cycle, in perpetuity, to document the thing Local Law 97 asked it to do. Our budget approval page covers where these line items land.

The two-day notice is the new operational trap

Also from the § 103-10 amendments:

“The inspection entity is required to notify DOB of the performance of a gas piping system inspection at least two (2) days prior to the performance of the inspection.”

Two days' advance notice, using DOB's 2-Day Notification form, with cancellations submitted through a cancellation notification. A board that schedules a plumber for Monday on Friday afternoon has a compliance problem before anyone looks at a pipe. This is a duty on the inspection entity rather than the owner, but the consequence — an inspection that does not count — lands on the building.

Who may perform the inspection narrowed

From Local Law 142 of 2025, verbatim:

“The qualified individual working under the direct and continuing supervision of a Licensed Master Plumber who is authorized to conduct the gas piping inspection is required to hold a Journeyman Plumber Registration issued by DOB and to have successfully completed a DOB-approved training program.”

The law also “clarifies the inspection scope and instrumentation for gas leak detection” under § 28-318.3.2.² For a board, the practical consequence is to confirm that whoever actually walks the building holds the registration and the training — not merely that the firm employs a Licensed Master Plumber.

Penalties, and a waiver route that is new and useful

The penalty for failing to file the certification by the due date is $5,000, per DOB's December 2, 2021 service notice. DOB began issuing Notices of Deficiency for Cycle 1 non-compliance in January 2025.

Resolution now requires both money and paperwork: “Payment of the civil penalty and submission of a certification of inspection will be required to resolve a violation for failure to file certification,” with DOB noting that “Later this year, DOB NOW will require submission of the certification to resolve a violation.”

But there is a waiver, and it has a named channel:

“A waiver of civil penalties may be requested. The reasons, eligibility, and evidentiary requirements for the waiver of civil penalties [are in 1 RCNY §103]-10(h). To submit a waiver of civil penalties, complete a Waiver Request and email the supporting documents to [email protected]. Include the property address, Building Identification Number (BIN), and violation number in the subject line. NOTE: If you do not receive a response in ten (10) business days, email [email protected].”

A board carrying a $5,000 gas-piping penalty should read § 103-10(h) before paying it — the rule sets out the reasons, eligibility and evidentiary requirements.³

What a board can do

Look up your community district. Not your borough, not your neighbourhood — your CD number, which you can find through the City Planning community profiles. That single number tells you whether your certification is due this December, next December, or in 2028.

If your building has gas, book the inspection with enough runway for the two-day notice and the 60-day certification. Working backwards from December 31, the last comfortable inspection date is late October.

If your building electrified, find the utility deactivation paperwork now — and budget the $480 as a recurring four-year cost rather than a one-off.

If your building never had gas piping, do the $375 certification once and close the file. It is the one filing in this regime that does not come back.

Our New York condo safety inspections page covers the wider inspection landscape, and our reserve studies page covers how recurring compliance costs belong in a funding plan rather than in a surprise.