The Real Estate Board of New York Comment to the Fire Department on the Proposed Rule Related to Certification of Corrected Defects in Fire Alarm System Installations

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The Real Estate Board of New York (REBNY) is the City’s leading real estate trade association representing commercial, residential, and institutional property owners, builders, managers, investors, brokers, salespeople, and other organizations and individuals active in New York City real estate. REBNY thanks the Fire Department (FDNY) for the opportunity to comment on the proposed rule that would establish a certification program by which licensed professionals may certify correction of certain fire alarm system defects and eliminate the need for FDNY re-inspections of these conditions.

New York City has been experiencing an uptick in construction for the better half of the past decade, and as the built environment has grown, so too has the demand for FDNY’s inspection services. For this reason, REBNY supports this proposed rule that would establish a program that would allow licensed professionals to certify the correction of certain fire alarm system defects. Such a program would help reduce the administrative burden on FDNY, while continuing to ensure public safety and supporting development in the city.

REBNY believes that the proposed rule appropriately considers public safety by requiring that the licensed electrician or the fire alarm installer to be one of the two professionals needed to certify the correction. At the same time, we would encourage FDNY to provide additional clarity on the following items:

• If FDNY will be creating a new Certificate of Fitness for verification of corrected fire alarm system defects, what will be required to obtain such a Certificate of Fitness, and whether holders of an existing Certificate of Fitness could be eligible for any new Certificate of Fitness automatically.

• Additional specificity about the precise types of ineligible defects to avoid any ambiguity as to which defects may be corrected through professional certification.

• The process for issuing a Letter of Approval for projects that correct all defects through professional certification, including whether definitive timeframes for issuing Letters of Approval could be established.

Thank you for the consideration of these points.