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, 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.

Promulgated January 3rd, 2026 and LIVE on DOB NOW July 27th, 2026.

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

An “Amendment of Rules relating to Gas Piping Inspections” have been adopted and became effective 01/03/2026. Click HERE to read the adopted rules. Refer to page 4, paragraphs 2 and 3 to determine your “no gas service” scenario.

Scenario 1 Requires an Inspection* by an LMP or RDP.
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.
For filings on or after July 27th, 2026 there will be a filing fee of $480 as the NYC DOB will move the filing process, consistent with the the new rules of January 3rd, 2026, to DOB NOW .
For more information, see Follow-up #8 for Local Law 152 of 2016.
*On a case by case basis, an inspection may be avoided. Contact Bill for details.

Scenario 2 An inspection by an LMP or RDP is not required.
At this time, 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.
For filings on or after July 27th, 2026 there will be a filing fee of $375 as the NYC DOB will move the filing process, consistent with the the new rules of January 3rd, 2026, to DOB NOW .

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
For more information, see Follow-up #8 for Local Law 152 of 2016.

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We have assisted many stakeholders with these scenarios and are happy to talk with you to answer any additional questions you may have.
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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: