Did you miss the LL 26/04 compliance deadline? Here’s what you need to know

By Andrew Pisani

As you’re no doubt aware, the compliance deadline for Local Law 26 of 2004 has come and gone. The law requires full sprinkler systems in all office buildings 100 feet in height or greater. Affected properties that are not in full compliance will receive a Local Law 26/04 violation. Dismissing such violations requires 100% completion of sprinkler system installation and submission of Final Sprinkler Report: Attachment B.

A couple of things to keep in mind:

• Now that July 1, 2019, has passed, the Department of Buildings (DOB) will no longer accept any hardship or extension letters.
• Installation of a Temp Loop on a vacant floor does not qualify as acceptable floor protection for LL 26/04 compliance.

Confirming LL 26/04 compliance

Submission of Final Sprinkler Report: Attachment B requires sign-off of every open sprinkler application—no matter how old—on the property. Even 99% completion of sprinkler system installation does not qualify for compliance. At the time of Final Sprinkler Report submission, DOB will verify sign-off of all sprinkler applications.

Exceptions

Two exceptions to the full-sprinklering requirement include landmarks and certain structural conditions.

Landmarks. Portions of a building that have protected status from the Landmarks Preservation Commission (LPC) may request a waiver of sprinkler compliance for that part of the property, such as a landmarked lobby. These requests must include a letter from LPC confirming this status. The commissioner will evaluate such requests and determine whether or not to grant a waiver, as well as to identify alternative fire safety measures that may be required to ensure public safety.

Structural conditions. Buildings with structural conditions that prevent installation of sprinkler piping in certain areas will require an engineer’s report attesting to this fact. Again, the commissioner will evaluate such requests and determine whether a waiver may be granted, as well as identify alternative fire safety measures that may be required.

The clock is ticking…

While the Department of Buildings (DOB) has not set a monetary fine for non-compliance, that may change. To that end, we strongly encourage buildings that are not in full compliance to remedy the situation before any financial penalties go into effect.

If you have any questions or need assistance bringing your property into compliance, please contact Metropolis Group at 212.233.6344.