The Real Estate Board of New York to The Fire Department of the City of New York

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REBNY thanks the Fire Department (FDNY) for the opportunity to comment on proposed rules concerning fire alarm systems.

REBNY deeply appreciates the work of the members of the FDNY who keep the city’s 1.1 million buildings and their occupants safe. As partners with the FDNY in this effort, the real estate industry shares FDNY’s belief that fire alarm systems should be designed, installed, and maintained safely and in accordance with code. At the same time, it is important that the process by which such systems are reviewed and inspected be both rigorous and efficient so that needed economic development projects can move forward.

With this in mind, REBNY commends FDNY’s proposed rules that will address challenges in the fire alarm system review and inspection processes to promote safe development in New York City. REBNY encourages FDNY to consider the following comments as this rule is finalized.

• Enable developers/owners to use different appropriately certified entities for the design certification and installation inspection: The proposed rule would codify the ability of credentialed professionals to certify certain fire alarm system design and installation in place of FDNY plan examination and inspections. This is an important step forward that will help improve the effectiveness of FDNY’s processes. The proposed rule could be improved if it were made clear that different certified entities could complete the design certification and installation inspection for the same project. The proposal is currently ambiguous on this point. Allowing different entities to make these certifications would help ensure that an adequate pool of qualified professionals is available to complete this work in a timely manner.

• Clarify the appropriate installation inspection process that a professional certifier should follow: To ensure best practices are followed, FDNY should make clear the steps that a credentialed professional should take to ensure that a fire alarm system has been properly installed. Greater specificity on the standards/protocols for conducting an inspection will help ensure the proposed rule achieves its intended impact.

Thank you for the opportunity to comment on the proposed rule.