The Department of Buildings just issued another round of Notices of Deficiency for Local Law 152 filings. Here’s what that means, and what teams need to do going forward:
What Is A Notice Of Deficiency?
Per the Department (and in the context of LL 152), Notices of Deficiency (NODs) are warning letters for missed gas piping filings.
As a reminder, inspections are required once every four years for gas piping systems at most properties. If a building doesn’t have a gas piping system, they must submit a certification from a registered design professional confirming the same. There’s even a third compliance path for properties that have gas systems which aren’t currently supplied with gas.
The Department has issued NODs previously, for Cycle 1 – Subcycle A. This most recent round is for Cycle 1 – Subcycle B, including properties across Community Districts 2, 5, 7, 13, and 18 in all boroughs.
How Do We Respond?
We spoke with the DOB to get some clarity around this issuance round. Right now, if your team received an NOD, there isn’t much you can do in response – with one major exception.
These NODs carry a $0.00 penalty (shown in their records and reflected in your SiteCompli or InCheck account), so there’s nothing to pay. These recent issuances have a status of Waived – Pending Dismissal. It’s possible this may automatically change/be adjusted by the Department going forward, but there’s nothing for your team to file in response.
Here’s what you can and should do: make sure you’re on track to file your inspection, certification, or compliance paperwork for the next cycle. Missing another subcycle will likely result in a violation and accompanying $5,000 penalty instead of a warning.
Most buildings in this issuance round are due at the end of this year (December 31, 2025). If you’re not sure which subcycle your property falls into, you can check here in your account on the Local Law 152 page.
You can also get more details on the specific steps to compliance on the DOB’s website.
We’ll keep you posted on any announcements or updates regarding Notices of Deficiency or Local Law 152 requirements. As always, don’t hesitate to reach out to our team if there’s anything we can help with!