Do Buildings Without Gas Still Need a Local Law 152 Certification?

This is one of the most common questions NYC building owners ask when reviewing their Local Law 152 obligations:

If my building doesn’t have gas, do I still need to file anything?

The short and accurate answer is: yes, in most cases, a certification is still required.

Here’s how it works and why so many owners get tripped up.

Local Law 152 Applies to Buildings, Not Just Gas Usage

Local Law 152 requires periodic gas piping inspections for most NYC buildings. Even if a building does not currently use gas, the Department of Buildings still requires formal confirmation of that fact.

From DOB’s perspective, the City needs documentation showing one of two things:

• Certifying that a building does not have gas service or any gas piping, or
• The building has gas piping but is not currently supplied with gas and does not have any appliances connected to gas piping

That confirmation is what keeps the building in compliance.

If Your Building Has No Gas Piping

If your building truly has no gas piping at all, typically built that way, you are not required to perform a Local Law 152 inspection which can be completed by a NYS Registered Design Professional or a NYC Licensed Master Plumber. For now, the GPS2 form certifying for a building that does not have gas service or any gas piping, typically built that way, can be uploaded to the NYC DOB using this DOB Filing Portal with no filing fee. We anticipate that at some point in Q2 of 2026 the NYC DOB will move the filing process to DOB NOW, consistent with the recent Amendment of Rules relating to Gas Piping Inspections (page 4, paragraphs 2 and 3). At that time, there will be a filing fee of $375.

If Your Building Has Gas Piping but is not currently supplied with gas.

For a building that has gas piping but is not currently supplied with gas and does not have any appliances connected to gas piping, the required paperwork can be uploaded to the NYC DOB using this DOB Filing Portal with no filing fee.  We anticipate that at some point in Q2 of 2026 the NYC DOB will move the filing processto DOB NOW, consistent with the recent Amendment of Rules relating to Gas Piping Inspections (page 4, paragraphs 2 and 3). At that time, there will be a filing fee of $480.

To acquire the letter from the utility, for this scenario, you will call the gas provider for your location; either ConEd or National Grid. Indicate that you are asking for a letter provided by the utility as per §28-318.3.5 Buildings Without Active Gas Service.

Note that it is easier to acquire this letter from National Grid simply by calling and asking for it. ConEd will often require a site visit and in some cases, require the gas service to be cut and capped in the street.

In both cases you often must be persistent and call several times to reach a customer service representative that is familiar with your request.

ConEd – 800-643-1289

National Grid – 718-643-4050

The Risk of Doing Nothing

Even buildings with no gas can face:

• DOB violations
• Civil penalties
• Complications during refinancing, sales, or insurance reviews

All of this is avoidable with the correct filing.

How Keep My Gas Can Help

If you’re unsure whether your building needs an inspection, a no-gas certification, or corrective action, Keep My Gas can review your situation and guide you correctly.

We help NYC building owners and property managers:

• Determine whether gas piping exists
• Complete the proper Local Law 152 filings
• Resolve violations tied to missing certifications
• Avoid unnecessary fines and delays

If you’re unsure what applies to your building, reach out and we’ll help you figure it out.