Two Buildings with Common Heating System and Fire Escape

Landlord asked the DHCR whether it had to register two adjoining buildings with three apartments each. In an opinion letter, the DHCR stated that the two buildings were separate enough to be exempt from stabilization. Each building had its own separate certificate of occupancy, separate entrance, roof, mailboxes, water, sewer, and electric lines. The buildings had separate real estate tax and water bills. The two buildings had one heating system and one fire escape, which had been added long after the buildings were first con structed. These two factors alone didn't integrate the two buildings enough to make them a single six-unit building.

DHCR Opin. Ltr. by Nathaniel Geller (10/10/90) [2-page document]