What Is the Local Law 152 No-Gas Certification, and Why Does It Matter for Heat Pump Conversions?
The local law 152 no gas certification heat pump conversion NYC process is the formal mechanism by which a building that has removed all gas infrastructure exits the city’s mandatory four-year gas-inspection cycle, permanently. Local Law 152 of 2016 requires most NYC buildings to have exposed gas piping inspected by a Licensed Master Plumber (LMP) every four years, with a certification filed with DOB. If you convert to a heat pump, terminate Con Edison gas service, and physically remove all gas piping, you are no longer subject to that recurring obligation, but you still must file a one-time certification to prove it. Skip that filing and DOB can issue a violation carrying a fine up to $5,000, the same penalty as missing the inspection entirely.
What Are the Two Fee Tiers, and Which One Applies to You?
This is where most owners and even some contractors get confused. The 2026 rule amendments created two distinct scenarios with different fees and very different long-term consequences.
| Scenario | What it means | Fee (per BIN) | Ongoing LL152 obligation? |
|---|---|---|---|
| No gas piping in building | All gas pipe physically removed from point of entry through the building | $375 | None, one-time filing exits the cycle |
| Gas piping present, no active gas service | Pipe remains in walls/chases but Con Ed account is closed or capped | $480 | Yes, must re-certify every 4-year cycle |
The $375 “Certification of No Gas Piping” is a one-time filing; once accepted, the building exits the cycle unless gas piping is later reinstalled. The $480 “Documentation of No Active Gas Service” applies when pipe is still physically in the building, even capped, abandoned, or behind drywall, and requires re-certification on the standard four-year schedule. Simply closing your Con Edison account without removing the pipe lands you in the more expensive, recurring bucket.
What Is the Full Step-by-Step Sequence to Exit LL152 After a Heat Pump Conversion?
Follow these steps in order. Skipping or reordering them creates filing problems or leaves the building legally in the gas-service category.
- Commission your heat pump system. Your HVAC contractor installs and commissions the ductless heat pump so the building has a confirmed heating and cooling source before any gas equipment is shut off. This is the prerequisite, Con Edison will not close a gas account until you can demonstrate an alternative heat source.
- Decommission all gas appliances. Boiler, water heater, range, dryer, every gas-fired appliance must be disconnected and removed or converted to electric. If even one gas appliance remains (a kitchen range, for example), the building still has active gas service and cannot file the $375 certification.
- Terminate Con Edison gas service. Schedule the Con Edison gas service termination after all appliances are offline. Con Ed will send a technician to shut off and lock the meter. Get written confirmation of service termination, you will need this for the LMP’s records.
- Physically remove all gas piping. An LMP must pull permits and remove gas piping from the point of entry (the Con Ed service lateral connection at the curb or building face) through all interior distribution piping. This is not a capping job, it is full removal. Any pipe left behind, even in a closed wall, disqualifies the $375 tier.
- Obtain the LMP’s (or RDP’s) signed certification. A Licensed Master Plumber or a Registered Design Professional (PE or RA) signs and seals the Certification of No Gas Piping. Note: a PE or RA can sign the no-gas certification only when no gas piping exists; they cannot perform the actual gas-piping inspection required for active-gas buildings.
- File through DOB NOW: Safety. As of July 27, 2026, all LL152 certifications must be submitted through DOB NOW: Safety (navigate to Compliance Filings, then Gas Piping Systems). The old standalone portal is closed and the paper GPS2 form is no longer accepted for new submissions. Pay the $375 DOB filing fee at submission.
What Is the Partial Conversion Trap That Catches Co-op and Brownstone Owners?
The most common mistake is converting heating to a heat pump while keeping gas for cooking or hot water. If a single gas appliance or any gas pipe remains anywhere in the building, you cannot file the $375 no-gas certification. The building is still in the $480 (gas piping present, no active service) or standard inspection category. This is a critical distinction for Brooklyn and Manhattan brownstone owners who want to keep a gas range, and for co-op boards where only some units have converted.
How Does This Work in a Co-op or Multi-Unit Building Where Only Some Units Convert?
In a master-metered co-op or condo, gas piping typically runs through common areas and branches into individual apartments. The LL152 inspection obligation is building-wide, based on the building’s BIN (Building Identification Number). If even one unit retains gas service or gas piping, the entire building remains in the inspection cycle. The board, not individual shareholders, is the responsible party for filing. A partial floor-by-floor conversion does not move the building into the $375 tier; that requires complete, building-wide pipe removal.
For boards weighing the financial path, review how keeping steam radiators while adding mini splits fits the Local Law 97 hybrid compliance strategy, since full gas removal may not always be the right sequence for larger buildings.
Comparison: Capping vs. Full Removal vs. No Action
| Path | LL152 Fee | Recurring Inspection? | DOB Violation Risk |
|---|---|---|---|
| Full pipe removal + $375 filing | $375 one-time | No | None after filing accepted |
| Cap only, close Con Ed account + $480 filing | $480 per cycle | Yes, every 4 years | Low if filed on time |
| No filing after heat pump conversion | $0 paid | Technically still required | High, up to $5,000 violation |
| Standard gas building, inspection + GPS2 | $35 per cycle | Yes, every 4 years | Low if filed on time |
Which Community Districts Have a 2026 Deadline?
If your building is in Community Districts 4, 6, 8, 9, or 16, your Sub-cycle C filing deadline is December 31, 2026. That covers parts of the Bronx, Brooklyn, Manhattan, and Queens. If you are mid-conversion and your district’s deadline is approaching, file a $480 certification now to avoid a violation, then upgrade to the $375 no-gas certification once full pipe removal is complete.
Common Mistakes to Avoid
- Capping instead of removing. A capped gas line left in the wall puts you in the $480 recurring category, not the $375 clean exit.
- Keeping one gas appliance. A gas range or gas water heater anywhere in the building prevents the full no-gas certification. Every appliance must go electric.
- Closing the Con Edison account without filing with DOB. Con Ed and DOB are separate systems. Terminating service does not automatically notify DOB; you must still file.
- Missing the cycle deadline while mid-conversion. If your community district deadline falls before you complete pipe removal, file the $480 interim certification to avoid a violation, then re-file the $375 when removal is done.
- Using a PE or RA for the wrong scenario. A PE or RA can sign the no-gas certification only. If gas piping is present, an LMP must perform and certify the inspection, there is no workaround.
- Assuming R-3 buildings are automatically exempt. One- and two-family homes in occupancy group R-3 are exempt from the inspection requirement, but should confirm their classification with DOB before assuming no filing is needed.
Frequently Asked Questions
Do I still need to file anything with DOB after removing all gas piping from my brownstone?
Yes. Buildings with no gas piping must still file a one-time Certification of No Gas Piping with DOB through DOB NOW: Safety. The $375 filing fee applies. Failure to file carries the same violation risk as missing a standard inspection, up to $5,000.
What is the difference between the $375 and $480 no-gas certification fees?
The $375 fee applies when all gas piping has been physically removed from the building. The $480 fee applies when gas piping is still present in the building but no active gas service exists. The $375 filing is a one-time exit from the LL152 cycle; the $480 filing must be repeated every four years.
Can my HVAC contractor file the no-gas certification?
No. The certification must be signed and sealed by a Licensed Master Plumber or a Registered Design Professional (PE or RA). Your HVAC installer handles the heat pump side; you will need a separate LMP to pull the gas removal permit, complete the work, and sign the certification.
What happens if only some units in my co-op convert to heat pumps?
The building remains in the standard LL152 inspection cycle as long as any gas piping exists anywhere in the building. The $375 no-gas certification is only available after building-wide pipe removal. Partial conversions do not change the building’s overall LL152 obligation.
Where exactly do I file the no-gas certification in 2026?
All LL152 filings, including no-gas certifications, go through DOB NOW: Safety as of July 27, 2026. Navigate to Compliance Filings, then Gas Piping Systems. The former standalone gas-piping portal is closed and the paper GPS2 form is no longer accepted for new submissions.