Green Roof Tax Abatement

Online comments: 5

• Inger Staggs Yancey

  Is there a way for a project to apply while awaiting this rule making process hearing?

  Why is a hearing necessary if as is said above, only “minor … edits” are being made? In the past, when this law has been updated in the same way, this process was not required and there was no delay to applicants.

  I think this rule making process is unnecessarily delaying the application of these minor updates to an existing law and process.

  Comment added November 1, 2024 12:37pm

• Inger Yancey

  If this step is necessary in order to enact the legislation signed into law by Gov. Hochul in June of 2024, updating and extending the property tax abatement program intended to incentivize green roof installation in NYC, then it has my full support.

  Comment added November 6, 2024 12:18pm

• Shino Tanikawa

  Thank you for the opportunity to comment on the proposed Amendment of Rules relating to Green Roof Tax Abatement.

  I am generally in favor of the proposed amendments which clarifies and streamlines the language of the rule.

  However, I have concerns regarding 105-01(e)(1) Filing.

  Whereas the prior rule allowed an architect or engineer to conduct the final inspection of the green roof, the proposed rule will require “an approved agency” to conduct the final inspection.

  The vagueness of the “approved agency” is of a significant concern since I am unclear who will decide which agency will inherit this responsibility. Further, assigning a city agency (assuming it is a city agency, not a state agency) to conduct inspections will likely delay the entire process due to perpetual understaffing of all city agencies.

  I recommend adding an architect or engineer back in the rule, perhaps as additional entities beyond an “approved agency” authorized to conduct inspections.

  The Green Roof Tax Abatement Program has been on hiatus since March 2023. I sincerely hope we can prevent any further delay in reinstating the program AND facilitating application and approval process for green roof projects currently under way.

  Please make the above change to the rule, and approve the new rule as quickly as possible.

  Thank you.
  Shino Tanikawa

  Comment added December 2, 2024 11:41am

• Shino Tanikawa

  Thank you for the opportunity to comment on the proposed Amendment of Rules relating to Green Roof Tax Abatement.

  I am generally in favor of the proposed amendments which clarifies and streamlines the language of the rule.

  However, I have concerns regarding 105-01(e)(1) Filing.

  Whereas the prior rule allowed an architect or engineer to conduct the final inspection of the green roof, the proposed rule will require “an approved agency” to conduct the final inspection.

  Elimination of self certification by an architect or an engineer, replacing it with a new requirement for “an approved agency” to conduct the final inspection is of significant concern since it can potentially add time and cost to the green roof project seeking the abatement. The law was amended this year to remove barriers to participation, so that the City can become more resilient. This particular proposed amendment creates an unnecessary new barrier.

  For green roof retrofit projects, in particular, I believe Directive 14 should still apply, allowing an architect or an engineer to conduct the inspection to sign off on the project. For new construction, there is a separate process for the certificate of occupancy that will ensure the project is constructed according to the submitted plan.

  I recommend adding an architect or engineer back in the rule, perhaps as additional entities beyond an “approved agency” authorized to conduct inspections.

  The Green Roof Tax Abatement Program has been on hiatus since March 2023. I sincerely hope we can prevent any further delay in reinstating the program AND in facilitating the application and approval process for green roof projects currently underway.

  Please make the above change to the rule, and approve the new rule as quickly as possible.

  Thank you.

  Comment added December 2, 2024 4:02pm

• Inger Staggs Yancey

  I would like to rescind my previous two comments, and to amend my comment from the hearing. But first of all, thank you for the opportunity to comment on the proposed Amendment of Rules relating to Green Roof Tax Abatement.

  I am generally in favor of the proposed amendments which clarify and streamline the language of the rule. However, I have concerns regarding 105-01(e)(1) Filing.

  It is appears that an accommodation is being made to allow green roof tax abatements, and the permit process they require, apply to new construction with roughly the same process as has been established for existing construction, namely the professionally certified Alteration Type 2 application with Directive 14 selected.

  Whereas the prior rule allowed an architect or engineer to conduct the final inspection of the green roof, the proposed rule will require “an approved agency” to conduct the final inspection.

  Elimination of self certification by an architect or an engineer, replacing it with a new requirement for “an approved agency” to conduct the final inspection is of significant concern since it can potentially add time and cost to the green roof project seeking the abatement. The law was amended this year to remove barriers to participation, so that the City can become more resilient. This particular proposed amendment creates an unnecessary new barrier. Additional experts will need to be hired by the owner, and additional time will be required for final sign-off. We need to increase access to the tax abatement, not constrict it further.

  For green roof retrofit projects, in particular, I believe Directive 14 should still apply, allowing an architect or an engineer to conduct the final inspection to sign off on the project. For new construction, there is a separate process for the certificate of occupancy that will ensure the project is constructed according to the submitted plan. Since the green roof permit application must be filed as a separate application from any related New Building or Alteration application, it seems unnecessary to add a separate entity, the “approved agency,” as the Certificate of Occupancy will already be part of that separate process, if required.

  I recommend reverting to the original responsible party which had been called the”registered architect or engineer,” and is now called “the design professional,” and adding it back into the rule’s final inspection sign-off process, as an additional entity to the “approved agency,” and that these two types of authorized, responsible parties are also both able to conduct required the inspections.

  The Green Roof Tax Abatement Program has been on hiatus since March 2023. I sincerely hope we can prevent any further delay in reinstating the program AND in facilitating the application and approval process for green roof projects currently underway.

  Please make the above change to the rule, and approve the new rule as quickly as possible.

  Thank you,
  Inger Yancey

  Comment added December 2, 2024 5:17pm