Guidance: All-Electric Buildings Act

All-Electric Buildings Act Guidance

CRBRA email to members about Pause on Gas Ban

Wednesday, November 12, 2025

I’m writing with an important update following my November 5 email regarding the status of the gas ban litigation. Today, the U.S. District Court issued an order that formally suspends implementation of the All-Electric Act while the appeal is underway. This means the State cannot enforce the new regulations during the appellate process.
What the order doesAccording to the court’s document:

The court issued an order that pauses the effective date of the All-Electric Act provisions while the case moves through the Second Circuit Court of Appeals.
The State is required to formally suspend or delay implementation of the ban until the appeal—and any potential U.S. Supreme Court petition—is fully resolved.
If the plaintiffs ultimately lose, the State must wait an additional 120 days after the final ruling before the suspended regulations can take effect.

Please note, this suspension is strictly a procedural agreement and does not indicate how the court will rule on the underlying legality of the gas ban.
What this means for members right nowProjects that would have been impacted by the January 1 implementation timeline will not be subject to the all-electric requirement during the appeal process.

This is a significant procedural development, and more action is expected as the appeal progresses. We will continue to update members as new information becomes available.

CRBRA email to members sharing update from National Grid

Monday, August 25, 2025

As you know, CRBRA has been closely monitoring the implementation of New York’s All-Electric Buildings Act (AEBA) and sharing updates as they’ve become available. The message below from National Grid reinforces much of what we’ve already communicated: beginning December 31, 2025, the only projects eligible for new gas hookups will be those with either a building permit in hand or a “substantially complete” permit application, as determined by your local municipality.

One important point National Grid makes here relates to letters of credit and deposits. If you move forward now with requesting gas infrastructure for a project, you could risk forfeiting those funds unless you meet the building permit or “substantially complete” application benchmarks by the end of 2025. This reiterates the importance of planning carefully for projects currently in design or early stages of permitting. Please review National Grid’s full message below for details, and reach out to them directly if you have project-specific questions.

From: Stephen Harris, Director, Consumer Connections NY

Beginning December 31, 2025, New York’s All-Electric Buildings Act (AEBA) will prohibit most new gas hookups for residential buildings of seven stories or fewer. The impacts of this change could be significant, especially for “inflight” projects, and National Grid wants to do what it can to help developers make informed decisions.

On July 25, the Department of State Building Codes Council (Codes Council) issued final rules on implementation of the AEBA. Under those rules, starting December 31, 2025, the only projects eligible for a gas connection will be those that either:
(i) already hold a valid building permit, or
(ii) have submitted a “substantially complete building permit application”— one that, in the judgment of the local authority having jurisdiction, contains all information needed to confirm compliance with the State’s Uniform and Energy Codes.

Developers that have not met one of these two benchmarks by year-end 2025 should anticipate being denied gas service and, therefore, must plan for all-electric systems. Note that it is the local jurisdictional authority (e.g., the municipal code enforcement official) that determines if a project has submitted a “substantially complete building permit application” — National Grid is not part of the building permit process.

Although the Public Service Commission is evaluating a limited exemption to allow new gas connections where grid constraints make electric service impracticable, no procedures or timelines have been announced, and the exemption is expected to apply only in rare, location-specific situations.

In short, to preserve the option of natural gas service, developers must have a building permit or a “substantially complete building permit application” before December 31, 2025; projects that miss this deadline will most likely be required to proceed as all-electric.

If you ask National Grid to proceed with gas infrastructure for your project now, you risk forfeiting your deposit/letter of credit unless you have a building permit or a determination by the local authority with jurisdiction of a substantially complete building permit application by December 31, 2025.

If you have questions for National Grid regarding your project, please reach out your project specific URD Job Owner, or feel free to contact me directly at: [email protected].

CRBRA will continue to keep you updated as more details become available. In the meantime, we encourage you to review the information above carefully and connect with your local building department or National Grid contact if you have project-specific questions.

CRBRA Email to Members regarding 7/25 Code Council Actions

Thursday, July 31, 2025

Over the past several days, there’s been a flurry of news articles and industry updates about the New York State Code Council’s recent decisions. Many have been dense or unclear. At CRBRA, we’re committed to helping you cut through the confusion, so we’ve broken down the key takeaways to help you better understand what these changes mean for your business.

All-Electric Mandate Effective December 31, 2025

Projects with a substantially complete building permit application submitted before December 31, 2025, are exempt from the updated codes and electrification mandates.
However, the term “substantially complete” is not clearly defined in the code. It’s a subjective standard that will likely be interpreted and enforced at the discretion of each town or municipality.
What to do now: Contact the local building department in areas where you're building to understand how they plan to define and enforce this requirement in your jurisdiction.

Public Service Commission Decision Still Pending

The PSC has been tasked with defining a standard of reasonableness for exemptions. (Thank you to many of you for submitting comments during our Call to Action!)
They have not yet released their definition. We're monitoring the case and will share updates when we receive them.

National Grid - 100-foot rule
On a related note, one of the concerns we addressed in our public comments to the PSC was the tariff imbalance for three-phase electric service. National Grid has informed us that a previous Commission Order (Case 16-E-0637) addressed this concern. "As set forth in the Commission's order in Case 16-E-0637, the applicant's 100 foot entitlement may include single or mutliple phase service depending on the requirements deemed necessary by the Company for service." Their public comments also addressed their support for the PSC to find "inflight mutli-phase projects may qualify for a Grid Exemption. For an inflight project to receive a Grid Exemption, the connecting utility would have to find that an exemption is necessary to prevent economic waste in connection with utility facilities and investments associated [with] the project." To read their full comments, click here.

CRRBA met with National Grid representatives in June and will continue to keep an open dialogue with them as we move towards the effective date.

Townhouse Sprinkler Mandate: Twin Homes Are Exempt

Fire sprinklers will now be required in all new townhomes under three stories.
But: Under NYS code, a townhouse is defined as three or more attached units.
We interpret that to mean two-unit homes (like twinhomes or duplexes) are NOT subject to the new sprinkler requirement.

We know these changes can feel overwhelming. Our commitment remains the same: to advocate for your interests and help you stay informed through clear, timely communication. Please don’t hesitate to reach out with any questions.