To the extent the plain language of RPL 216(1)(a)(1) is ambiguous, it is a fundamental principle of statutory interpretation that "when the statutory language at issue is but one component in a larger statutory scheme, it must be analyzed in context and in a manner that harmonizes the related provisions and renders them compatible" (Matter of Mestecky v City of New York, 30 NY3d 239, 243 [2017] [internal quotations and citations omitted]). In the case of GCEL, the statute exists within a broader landlord-tenant framework that includes Article 7 of the RPAPL and Article 7 of the Real Property Law (RPL). One significant provision of the RPL is 235-b, the statutory warranty of habitability, which obligates a landlord to maintain the leased premises in good repair and free of any "conditions which would be dangerous, hazardous or detrimental to their life, health or safety." In vindicating the rights afforded by RPL 235-b, a tenant's primary "means of persuading the landlord to maintain habitable premises" is through withholding rent and forcing the landlord to bring a nonpayment (Ruppert House Co. Inc. v Altmann, 485 NYS 2d 472 [Civ Ct, NY Co 1985] [Saxe, J.]). This right is impaired when a landlord can simply terminate the tenancy any time there are rental arrears, rather than file a nonpayment with its more generous cure provisions and the ability to litigate warranty of habitability defenses. For this reason, some courts have held that lease provisions allowing for early termination based on nonpayment are void where the tenant can show a viable warranty of habitability defense, since termination in such circumstances is inconsistent "with the public policy [rationale] expressed by the legislature in Real Property Law § 235-b" (Windy Acres Farm, Inc. v Penepent, 40 Misc 3d 63 [App Term, 2d Dept, 9th & 10th Jud Dists, 2013] [internal [*6]citation and quotation omitted])[FN4]
. By a similar token, allowing a non-renewal holdover, the functional equivalent of a for cause early termination holdover, against a rent-regulated GCEL-tenant solely because they owe rent would chill their ability under RPL 235-b to withhold based on serious health and safety conditions for fear of termination, especially given that a warranty of habitability defense is generally not a cognizable defense to a non-renewal holdover (see Blumenthal v Chwast, 2003 NY Slip Op 50029[U] [App Term, 1st Dept 2003]). Insofar as RPL 216 and RPL 235-b exist within the same statutory framework, they should be interpreted in a manner that avoids such a fundamental conflict, which is best accomplished by a blanket rule rejecting the viability of such proceedings.