One of the major concerns of tenement reformers was conditions in dark interior rooms. The survey undertaken by the Tenement House Department found that there were "over 350,000 dark interior rooms, without any light whatsoever; that in a great majority of these rooms there are no windows at all, not even a window connecting with another room in the same apartment, [and] that many of these rooms are two rooms removed from the outer air." Although certainly not pleasant places in which to sleep, tenants probably appreciated the extra space that these small rooms provided and they paid additional rent for apartments with these inner rooms.

In response to the concerns of the reformers, the 1901 law mandated that a window be cut into the partition between an interior room and a room with windows looking onto the street, rear yard, or an acceptable air shaft, such "sash window having at least fifteen square feet of glazed surface, being at least three feet high and five feet wide between stop beads, and at least one-half thereof being made to open readily." As approved in 1901, the law only permitted a single interior room to be altered in this manner. Second inner rooms (e.g., the bedroom in each apartment at 97 Orchard Street) became illegal unless an air shaft was constructed for ventilation. The construction of such a shaft meant significant and costly structural change and would have resulted in the loss of rentable space since the shaft would cut into the square footage in each apartment.

The ban on second interior rooms provoked oppositon from tenement-house owners. The United Real Estate Owners' Association, a group "composed of the various local Real Estate Owners' and Taxpayers' Associations of the City of New York...organized for the purpose of safe guarding the interests of property owners" took the lead in protesting the law. In June 1901, the association established a Tenement House Committee "to oppose the restrictive and oppressive measures of the New Tenement House Law...[and] to test the constitutionality of its many burdensome features." By July, the committee had hired a lawyer and had decided that although "no attempt will be made to defeat such provisions as the lighting of halls and the ventilation requirements," they would oppose the provision that would force owners to remove from use second interior rooms.

In the fall of 1901, a lively debate ensued in the pages of the Real Estate Record and Builders Guide concerning the necessity of these changes, how interior bedrooms could be lit, and the expense that these changes would entail. The oppositon prevailed; a 1903 amendment to the original act legalized second interior rooms as long as they had sash windows cut into the partitions. A Real Estate Record editorial praised the "good sense of the Legislature" and suggested that owners promptly undertake the alterations required by the law.

97 Orchard Street was one of the minority of older tenements that already had windows cut into the walls between the kitchen and inner bedroom. However, windows had to be cut into the wall between the kitchen and parlor. These windows may have been added at 97 Orchard Street before 1901; all that is known is that they had definitely been cut through by July 10, 1902 when a Tenement House inspector surveyed 97 Orchard Street and reported the presence of these inner windows. Unlike the horizontal sliders of the earlier kitchen-bedroom wall windows, the windows added between the living rooms and kitchens were double-hung, with two panes in each sash.