A plain-language breakdown of New York City Fire Department (FDNY) Rule 3 RCNY 608-01, from initial classification through ongoing operation and maintenance.
About this series: Decoded is written for the people who build, own, and occupy buildings. Each post takes a single fire or building safety reference document, strips away the jargon, and explains what it actually requires, why, and what it means for your project.
What is FDNY Rule 3 RCNY 608-01, and why was it created?
FDNY Rule 3 RCNY 608-01, “Outdoor Stationary Storage Battery Systems,” was adopted by the Fire Commissioner under the authority of the New York City (NYC) Fire Code Sections FC102.6.3 and FC901.6 and took effect on October 1, 2019.
The rule traces back to April 2018, when a working group coordinated by the City University of New York and the New York State Energy Research and Development Authority (NYSERDA), with FDNY participation, issued the first comprehensive guidelines for installing outdoor lithium-ion energy storage systems in the city. 608-01 turned those guidelines into enforceable design, installation, and emergency management requirements, including requiring full-scale testing to Underwriters Laboratories (UL) Test Method 9540A along with listing to UL 1741, UL 1973, and UL 9540.
Which battery energy storage systems (BESS) does the rule apply to?
608-01 governs the design, installation, operation, and maintenance of outdoor stationary storage battery systems in the city for all energy storage uses, including systems mounted on a trailer for mobile use. Rooftop battery energy storage system (BESS) installations count as outdoor for purposes of the rule.
Three categories fall outside its scope:
- Indoor battery systems
- Systems specifically designed and used for emergency, standby, or uninterruptible power supply (the Fire Code addresses those separately)
- Outdoor systems with an aggregate rated energy capacity of 250 kWh or less that are a component of an individual motor vehicle charging station, used for vehicle charging
How does Rule 3 RCNY 608-01 size a BESS, and why does it matter?
608-01 classifies every system as small, medium, or large based on its aggregate rated energy capacity, and the thresholds differ by battery technology (such as lead acid, nickel cadmium, lithium-ion, and flow). That classification determines which of the rule’s requirements apply: a permit, full-scale testing, an installation approval, a fire extinguishing system, and several other provisions are only triggered once a system crosses into the medium or large category.
Who holds responsibility once the BESS is operational?
Every outdoor stationary BESS must operate under the general supervision of a person holding an FDNY Certificate of Fitness. That person has to be trained and knowledgeable in the system’s installation and operation. Someone involved in its design or installation typically qualifies. They also have to hold the manufacturer’s installation and operating specifications for the BESS and any associated fire protection systems. And they must immediately report any emergency condition to the FDNY.
The Certificate of Fitness holder also has to provide technical assistance to the FDNY when asked, and to work with the battery management system’s monitoring facility to identify a subject matter expert (often a manufacturer’s representative) who can speak to the system’s design and performance during an emergency.
Separately, both the property owner and the business responsible for operating the system are on the hook for compliance with every installation, operational, and maintenance requirement in the rule, including the system’s eventual removal and lawful disposal.
What notice does the FDNY require for commissioning and decommissioning?
The rule sets different notice requirements depending on the system’s size. It’s critical to understand which apply to your system setup to avoid putting it out of compliance on a technicality.
Small systems:
The owner or Certificate of Fitness holder must email tech.mgt@fdny.nyc.gov no later than two business days after the system is commissioned or decommissioned, providing the following information on the battery asset:
- Battery type
- Manufacturer
- Rated energy capacity
- Name and certificate number of the responsible Certificate of Fitness holder
Medium and large systems:
The owner must notify the FDNY by email at least two business days before the *scheduled commissioning or decommissioning, giving FDNY representatives the option to attend. No confirmation is required, and the action can proceed in its absence.
*If the date changes, amended notice must go out as soon as circumstances allow.
Malfunctioning systems:
Removing or transporting any system that has shown abnormal temperature or gas emission readings, whether from physical damage, fire exposure, or another cause, must be coordinated directly with the Hazardous Materials Unit of the FDNY’s Bureau of Operations. The FDNY must be notified two business days ahead (or as soon as circumstances allow) by phone to the Borough Communications Office where the system is located.
What response times does 608-01 build in for emergencies?
The rule requires every BESS to transmit battery status and temperature data to a remote monitoring facility staffed on a 24/7 basis by trained personnel retained by the manufacturer or installer. If a system exceeds (or appears likely to exceed) thresholds that could lead to a system fire or explosion, that facility must notify:
- The FDNY — to alert the Borough Communications Office of the unsafe condition,
- The Certificate of Fitness holder — to get ready to respond, and
- The manufacturer — to make a qualified representative available
Two specific emergency response windows follow from there. Upon the FDNY’s request, both the Certificate of Fitness holder and the manufacturer must make a technically knowledgeable representative available within 15 minutes. Then, the Certificate of Fitness holder and an authorized representative of the property owner must physically respond to the location within two hours to assist with the incident.
Any system that undergoes a serious failure, including a fire, a release of flammable or toxic gas, or physical damage, must be removed from service immediately. It cannot go back into operation until it’s been evaluated by a trained and qualified person, repaired, tested, and formally re-commissioned by a Certificate of Fitness holder.
Are mobile or multiple battery systems treated differently?
Mobile systems, the kind mounted on a trailer for use at more than one location, still need equipment approval, and any limitations on their use are addressed as conditions of that approval. They don’t need separate installation approvals, and the commissioning and decommissioning notice requirements don’t apply either. However, a malfunctioning mobile system still must be coordinated with the FDNY the same way a fixed one would.
Installing more than one battery system on a single premises triggers a separate FDNY review and approval, specifically to prevent a large installation from being broken into several smaller systems to avoid the stricter requirements that come with size. That review doesn’t apply to multiple small systems, provided they aren’t part of a single installation or housed in a single enclosure, and they operate independently without being interconnected to each other.
What happens when a detector inside the enclosure activates?
When a fire or gas detector inside a battery system enclosure activates, the rule requires a distinct audible and visual local alarm, transmit a signal to the fire alarm system and from there to an approved central station, shut the battery system down if warranted, and trigger the enclosure’s ventilation and hazard mitigation measures. These responses trigger automatically, the same way a typical building fire alarm system operates, not through manual action by the central station. All fire protection systems protecting the installation, including any extinguishing and detection systems, must be monitored by an approved central station.
The emergency shutdown control (the e-stop) required at the installation is designed to shut down all battery system operations without affecting the fire protection systems and other safety measures the rule requires, so a firefighter using it isn’t disabling detection or suppression in the process.
Related Reading: BESS Certificate of Approval and Site-Specific Approval – New York City
Takeaway: Understand how FDNY requirements fit your specific battery asset and site configuration
Most of the compliance conversation on a BESS project happens before the system goes live. 608-01 makes clear the obligations don’t end there. Someone must hold the Certificate of Fitness. A technically knowledgeable representative must be reachable within 15 minutes. And every time the system is commissioned, decommissioned, or fails, the notice must be filed within the required timeframe.
Getting that operational structure implemented and documented before the system goes live saves a lot of scrambling later. It’s what keeps a BESS that’s approved on paper from falling out of compliance the first time it’s tested by an inspection or an emergency. Our credentialed subject matter experts work through this kind of emergency planning, training, and response strategy with BESS leads on every Sparc Energy project.
Questions about how 608-01 applies to your outdoor BESS in any of the five boroughs? Talk to an expert.
About the Author
Andrew Tivadar Fire Protection Project Manager | Sparc
Andrew Tivadar is a driven young professional specializing in fire protection engineering and consulting. Andrew has over 5 years of experience in fire protection engineering and holds a Bachelor of Science in Fire Protection Engineering from the University of New Haven. He has a diverse skill set and specializes in hazard analysis, life safety consulting, smoke control system testing and design, and fire alarm system design. He possesses hands-on experience and a collaborative approach to fire protection engineering consulting. Mr. Tivadar is also a leader in the fire service industry and has experience of operating and collaboration with members of the fire service industry at a high level. Andrew has collaborated on a variety of projects including residential high-rise buildings, high-rise office buildings, large arenas and convention centers, heathcare facilities and educational institutions.
