Narrative Statement

Narrative Statement

The Loft Board’s rules establish an Occupant Review of Plans Process, commonly known as the Narrative Statement Process. The process provides IMD tenants an opportunity to review and comment on the owner’s construction plans for converting the building to legal residential use. The Loft Board has concluded that this process, which involves the tenants in the details of legalization, is necessary because the process of legalization generally involves substantial construction work and may necessitate basic changes to individual units.

Within fifteen (15) days of filing an alteration application at the New York City Department of Buildings (DOB), the owner of an IMD building must provide the IMD tenants and the Loft Board with a Narrative Statement, describing the work to be performed and explaining why it is necessary. The Board's rules provide details as to what a narrative statement must contain. Following the filing of the statement, Loft Board staff will schedule an informal conference with the owner and the tenants. The purpose of the conference is to help the tenants understand the details of the owner's legalization plan. When necessary, the Loft Board staff will try to mediate disputes arising from the proposal.

If the parties reach an agreement on the details of the legalization plan, the Board will provide certification that the narrative statement process has been completed. DOB will not issue a work permit without this certification. If, however, an agreement cannot be reached on some aspect of the legalization plan, the tenants may choose to file:

  1. an alternate legalization plan with DOB
  2. a diminution of services application, or
  3. an unreasonable interference application

with the Loft Board.

If DOB approves the tenants' alternate plan, or the tenants’ proposal does not require a DOB review, the Board may choose to initiate a proceeding to determine which proposal should become the basis for the actual work to be performed in the building. The issue in such a proceeding is whether the owner's plan would unreasonably interfere with the tenants' use of their units. The narrative statement process will be deemed complete after the unreasonable interference claim, diminution of services claim, or alternate plans case(s) has been decided by the Loft Board and (1) the owner has verified that there have been no changes to the plans that were last presented in the narrative statement process and (2) the owner files with the Loft Board a cleared DOB objection sheet.

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