If you’re confused about Local Law 152 Gas Pipe System Inspections, then you are not alone. It’s been a rough journey getting to where we are now.  

Timelines for inspection, filing inspection reports and certifications, navigating due dates by Community District/boroughs that are all on a staggered pattern – the process can be complicated as you work to determine expectations! It’s part of the job of property management, and we know you want concise and accessible information so that you can stay in compliance, a few steps ahead of the DOB. 

In this post, we will be examining the meaning of filing a Local Law 152 inspection extension, why you would need to file an extension, the difference between two different LL152 extensions, and much more! 

So, Where Do We Stand Now?

If your building is due for an inspection in 2022, we have some good news for you. As of March 2022, the DOB has amended Local Law 152 to allow for a 180-day extension to submit your compliance paperwork.

If you have not contacted a Licensed Master Plumber to set up your inspection, you may already be out of compliance and facing a hefty fine. The penalty used to be $10,000 but they have since amended that penalty to $5,000.

What Exactly Does It Mean To File For An Extension?

Filing an extension request relieves you from the stress of trying to meet an uncomfortable inspection deadline, giving you the extra time you need to put yourself together before contacting your Licensed Master Plumber for inspection. While filing for an extension request helps you avoid penalties, you may be subject to a fine should you miss the extended (new) deadline provided by law. 

Why You Need To File An Extension

Filing an extension request for extra time is a by-product of unforeseen circumstances. If your building has not received its approved LL152 inspection certificate and is required to have one performed, you will have until December 31 of your required filing year to have the inspection paperwork completed and filed. 

Here are some of the reasons why you need to file an extension for your gas piping inspection:

1. Faulty Conditions in Your Gas Piping System: In the event that your gas piping system develops a defective condition, you can apply for an extension to rectify these conditions. Some of these conditions may be due to gas leaks, worn or old parts affecting safe operations, illegal connections or non-code compliant installations, etc. Under the Service Notice of the New York Department of Buildings (DOB) page, an extension of 120 days can be allowed for the rectification or correction of such faulty conditions. 
2. Timing and Schedules Interference: Another reason you may wish to apply for an extension is due to clashing schedules. Dealing with major life challenges can also cause you to miss your deadline. Events such as the loss of loved ones, marriage, or divorce can take up your time and energy. People get busy and keep telling themselves they will get their gas piping inspection done on time. However, the law is set, and fines are in place should you default in conducting your inspection within the established time. 
3. Health Condition: If you are suffering from a health condition that renders you incapable of running an inspection, you can file for an extension pending when your condition improves. Section 28-116.2.4. of the New York local laws provide that the “final inspection shall be performed by the department in the presence of the permit holder, the registered design professional of record, or the superintendent of construction.”

Due Date Extension VS. 'Filing With Defects' Extension

There are two types of extension requests a homeowner can explore while filing for an extension; due date extension and 'filing with defects' extension. While both types of extension share certain similarities, they are, nonetheless, different and unique. 

Due Date Extension

A due date extension request is filed before the expiration of the original date provided under the law. In most cases, the application or filing is made close to the deadline or when it becomes evident that they can’t make the deadline. The building owner can file for a due date extension and proceed with the gas piping system inspection without being late. Therefore, this extension filing is made before a Local Law 152 compliance inspection is conducted by the Licensed Master Plumber (LMP). It gives owners an option to extend their deadline, which is usually within 180 days. It is a preemptive application that seeks to forestall an incident. 

'Filing With Defect' Extension

A filing for defect extension arises when an owner’s gas piping system is shown not to be in compliance with DOB criteria. Under such circumstances, the inspection results will be filed with the DOB as “filed with defects,” and the owner must then proceed to rectify the issues to pass the inspection. In other words, this extension filing occurs after an inspection showing the faulty state of the GPS. It is a retrospective application that is made to correct the defects observed in the Gas Piping System. Some common GPS defects include gas leaks, faulty gas supply installation, worn or old gas pipes, gas line blockage due to debris, and contaminants in the GPS like dirt, oil, or water. This extension is not automatic when one files their LL152 paperwork.

Our Thoughts On The Matter

We file these types of extensions requests for customers, and we believe this new extension (previously not in place) emerged as a result of the huge percentage of buildings that were due in 2020 and 2021 but yet to file their reports. The majority of past local laws (relating to façades, energy, elevators, etc.) applied to smaller classes of buildings, usually larger in size and having more professional owners.

The formal extension process applies to buildings due in 2022 and later years and is not intended to apply to buildings that are already supposed to comply. However, informally, the Department of Building (DOB) has offered hints, including an “off-the-record” email sent to us, that 2021 buildings can avail themselves of this extension.

We’re Here to Help. 

Years of experience and a close relationship with the DOB allows us to quickly determine the best course of action for you. We have developed relationships that allow us to keep abreast of changes that could affect deadlines.

It can be a cumbersome process to navigate, to make sure you are dealing with it all correctly. We’ll ask you a few quick questions to see if you’re eligible for an extension or if you’re in a position where you’ll need to get an inspection ASAP.

Contact JTG Master Plumbing today and let us set your mind at ease!