NYC Local Law 154 and the New York State All-Electric Buildings Act for new buildings and gut renovations

The two laws at a glance

The two laws cover different places, start on different dates and are at different stages. New York City's law is in force; the state law has been upheld in court but is not yet being enforced.

NYC Local Law 154 dates and exceptions

Local Law 154 of 2021 prohibits the onsite combustion of fuels that emit more than 25 kg of CO2 per MMBtu in new construction. In practice, this rules out natural gas, propane and heating oil for space heating, hot water, cooking and clothes drying in covered buildings.

Which rules apply depends on the filing date of the complete initial GC application in DOB NOW, not on the construction date. The compliance dates are January 1, 2024 for Group R-3 and all buildings under 7 stories (excluding service hot water); December 31, 2024 for NYC School Construction Authority projects; December 31, 2025 for affordable housing under 7 stories (excluding service hot water); July 2, 2027 for all occupancies, including service hot water; and December 31, 2027 for affordable housing of 7 stories or more. Affordable housing here means a building in which at least half of the units are subject to a government affordability agreement.

If an application later undergoes a major redesign, DOB requires it to be resubmitted as a new application, and the rules in effect on the new filing date apply.

• Buildings used by a regulated utility for energy generation.
• Buildings operated by the Department of Environmental Protection for sewage or food waste treatment.
• Specific spaces where fossil fuels are necessary for manufacturing, laboratories, laundromats, hospitals and crematoria.
• Commercial kitchens.
• Emergency or standby power.

The exceptions apply to the listed spaces or equipment, not to the whole building. A restaurant kitchen in a mixed-use building may use gas while the apartments above remain all-electric.

Which renovation projects trigger Local Law 154

Most renovations in existing NYC buildings do not trigger Local Law 154. The deciding factor is whether DOB requires the work to be filed as a New Building.

When the classification of a project is unclear, the architect or engineer of record should confirm it with DOB's Sustainability Bureau before filing.

The New York State All-Electric Buildings Act and its court status

The state law requires most new buildings to use electric heating and appliances instead of oil, propane or natural gas. It first applies to new buildings of 7 stories or less, with commercial and industrial buildings over 100,000 sq ft initially excluded, and extends to all new construction from January 1, 2029. Existing buildings are not covered; owners may continue to use, repair and replace gas or propane equipment and may renovate or enlarge without triggering the law.

Gas and HVAC companies, trade associations and unions challenged both the state law and Local Law 154 as preempted by the federal Energy Policy and Conservation Act. On June 30, 2026, the U.S. Court of Appeals for the Second Circuit ruled 3 to 0 that neither law is preempted. Because the Ninth Circuit reached the opposite conclusion in 2024 in a case involving Berkeley, California, Supreme Court review is possible.

Under a stipulation filed on November 12, 2025, the state agreed not to enforce the law while the appeal proceeds. As published law-firm analyses describe it, the stay lifts on October 28, 2026 unless a timely petition for certiorari is filed with the Supreme Court, in which case the stay remains in place. As of this review in late October 2026, the state requirements are not being enforced. Because this may change within days, confirm the current status with your town or village building department, or with the New York State Department of State, before finalizing a design or filing a permit.

• Fully exempt: mobile homes, hospitals and medical facilities, farm buildings, critical infrastructure such as wastewater treatment facilities, and emergency backup or standby generators.
• Partially exempt: car washes, commercial kitchens, laboratories, laundromats, crematoria, fuel cell systems and manufacturing facilities, which must still use electric lighting, heating and cooling, and domestic hot water.
• Waiver: available for a new building when the local utility certifies in writing that it cannot reasonably provide electric service from the grid.

Designing an all-electric house or small building

An all-electric design works best when the electrical service, equipment and space are planned together at schematic design.

• Load calculation first: a licensed electrician performs an NEC Article 220 load calculation. A two-family house with heat pumps, heat pump water heaters, induction cooking and an EV charger can exceed a 200 amp service.
• Utility service request early: a new or upgraded service from Con Edison or PSEG Long Island is often one of the longest lead items on a new build.
• Cold-climate heat pumps: select equipment by its rated capacity at 5°F, as listed in the NEEP cold-climate air-source heat pump list, not by the nameplate capacity.
• Heat pump water heaters: allow for floor space, airflow and a condensate drain. Basements in NYC row houses usually work; small closets usually do not.
• Induction cooking and dryers: plan dedicated 240 volt circuits for the range, and consider heat pump dryers where venting is difficult.
• Standby power: both laws exclude emergency or standby generators, so a gas or propane generator can remain an option, subject to code, zoning and the engineer's design.

Incentives and tax credits in 2026

According to the IRS, the federal Energy Efficient Home Improvement Credit (Section 25C), which previously applied to heat pumps and heat pump water heaters, is not allowed for property placed in service after December 31, 2025. Con Edison and PSEG Long Island have offered heat pump incentives under the NYS Clean Heat program; terms and funding change during the year, so confirm current incentives with the utility before selecting equipment.

We are contractors, not tax advisors. For questions about how any credit or deduction applies to your project, consult a CPA, such as Copper River Tax (copperrivertax.com).

How we support new builds and gut renovations

For new houses, small multifamily buildings and gut renovations in New York City and on Long Island, we work with the architect or engineer to lay out an all-electric design that fits the available electric service, prepare the load calculation with our licensed partner electricians, file the utility service request early and sequence the permits so the schedule does not stall at the meter. Whether a specific filing is grandfathered is a question for your design professional and, where needed, your attorney.