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5 Steps to File and Commission ARCS in NYC for Building Owners

October 1, 2026
5 Steps to File and Commission ARCS in NYC for Building Owners

Most high-rise buildings, underground structures, and most very large properties in New York City need an Auxiliary Radio Communication System, but FDNY grants exemptions when a building meets specific height, occupancy, and area limits under Bulletin #2022-01. Check your building's classification and Department of Buildings filing history first, then compare those figures against the bulletin's waiver criteria before you commit to a design.

TL;DR:

  • Buildings over 75 feet tall, with more than 250,000 square feet, or below-grade floors beyond code limits generally require an ARCS unless explicitly waived by FDNY.
  • FDNY exemptions depend on occupancy type, maximum height of 150 feet, and limited below-grade levels, but still require testing and acceptance inspections from licensed professionals.
  • Proper filing through FDNY Business with sealed drawings, detailed technical plans, and coordinated testing is essential to avoid delays and rejections.
  • Downward coverage issues are common in below-grade spaces, and overlapping antenna zones require detailed RF models and professional affidavits to meet FDNY standards.
  • Ongoing system maintenance, annual certifications, and recertifications are mandatory, with recordkeeping on site necessary for FDNY inspections.
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Table of Contents

Where ARCS is required under NYC codes

Building Code sections 916.3 and 907.2.13.2 set three main triggers for an Auxiliary Radio Communication System. A building needs ARCS when it qualifies as a high-rise, meaning that occupied floors sit more than 75 feet above the lowest level accessible to fire apparatus. It also applies to underground buildings, where occupied space sits below grade beyond the code's threshold, and to any structure with a gross floor area over 250,000 square feet regardless of height.

These triggers were reinforced in Department of Buildings code guidance tied to the 2022 Building Code cycle, which also folded in Appendix Q references for buildings that fall into gray areas between occupancy classes. Residential buildings classified R-2 get special treatment under the bulletin discussed below, so a residential tower does not automatically face the same requirement as a commercial high-rise of similar height.

Practically, the three triggers cover most large NYC construction:

  • High-rise threshold: occupied floor more than 75 feet above fire department vehicle access.
  • Underground buildings: occupied floors below grade beyond the code-defined limit.
  • Large floor area: gross building area exceeding 250,000 square feet.

Confirm your project's classification against your Certificate of Occupancy and filed drawings before assuming ARCS is or is not required. A building that seems mid-size on paper can cross the 250,000 square foot line once cellar and mechanical space get counted.

Exemptions and FDNY waiver criteria for ARCS

FDNY Bulletin #2022-01 lets certain buildings skip ARCS even when they technically meet a code trigger. The waiver path generally applies to:

  1. Buildings in occupancy Group R-1, R-2, or B.
  2. Structures with a highest occupied roof no more than 150 feet above fire department vehicle access.
  3. Buildings with no more than one story below grade.
  4. Properties that do not exceed the FDNY's maximum floor area threshold.

Meeting these limits does not grant an automatic exemption. FDNY still requires a commissioning test performed by an ARC System Professional, witnessed by a licensed PE, followed by an FDNY Department of Air Quality and Communications acceptance test confirming portable radio coverage is adequate without a dedicated system.

Filing and approval workflow on FDNY Business

Every ARCS project moves through FDNY Business, the portal FDNY uses for Technology Management applications. Filing the wrong application type is one of the most common reasons plans bounce back, so confirm you are selecting the ARCS-specific filing category before uploading anything.

The FDNY ARCS submission and approval procedures spell out the required package:

  • TM-1 application identifying the project, building, and design professional of record.
  • Certificate of Occupancy or Schedule A documenting current building classification and area.
  • Asbestos and landmark compliance forms where applicable to the project scope.
  • Sealed ARCS drawings showing the full system design, discussed in the next section.
  • ARCS Agreement between the building owner and the FDNY-recognized ARC company performing installation and testing.

Once the initial package is accepted, the design team requests Project Authorization through the portal. This step requires entering the licensed professional's information, current insurance data, and digital signature fields before FDNY assigns a reviewer. Incomplete insurance fields are a frequent cause of authorization delays, so gather that documentation before starting the online request rather than mid-submission.

Design and technical submission requirements

Plan examiners expect a specific set of technical drawings, not a general system diagram. At minimum, sealed ARCS drawings need to show the Distributed Radio Coverage (DRC) equipment location, placement of Radio Amplification Units (RAU) and antennas throughout the building, and the power supply configuration including battery backup runtime.

Wiring diagrams must note fire-rating requirements for cable runs between the DRC and remote antenna locations, since a break in fire-rated pathway protection is a common plan rejection point. Riser diagrams should trace the signal path floor by floor, and channel characteristics for the FDNY radio frequencies in use need to be documented clearly enough that a reviewer can verify coverage without cross-referencing separate files.

When a design proposes overlapping coverage areas, meaning two antennas cover the same zone to build in redundancy, FDNY typically wants supporting evidence beyond a drawing. That includes:

  • RF propagation models showing predicted signal strength across each floor.
  • Make and model data for every antenna, amplifier, and DRC component specified.
  • A design professional affidavit confirming the system was engineered to meet FDNY's coverage standards, per the ARCS submission procedures.

Clear, labeled propagation models tend to cut down on the back-and-forth that slows plan review, particularly on buildings with irregular floor plates or heavy below-grade parking that complicates signal modeling.

Commissioning, acceptance testing and TM-ARCS-2 reporting

Commissioning is where the design gets tested against real conditions. Testing must be performed by an ARC System Professional employed by an FDNY-recognized ARC company, and the individual conducting the test needs a B-03 Certificate of Fitness, per FDNY's B-03 guidance. A licensed PE witnesses the test and signs off on the results before submission.

The TM-ARCS-2 form is the official record for this process, used for initial commissioning, annual certification, and the five-year recertification cycle. Testing requires:

  • Delivered Audio Quality (DAQ) measurements taken across a defined test grid on every floor.
  • Signal strength readings at each grid point, recorded alongside the DAQ score.
  • Audio recordings captured during testing to document actual voice clarity.
  • Signed certification from the B-03 holder confirming test results match the form's pass criteria.

FDNY may conduct its own acceptance test after commissioning is submitted, and inspectors sometimes ask to remove an antenna temporarily to confirm that overlapping coverage claims hold up without it. Build that possibility into your test day planning rather than treating commissioning as a formality.

Pro Tip: Schedule your PE witness and ARC System Professional for the same test window. Rescheduling a DAQ retest because one party was unavailable is a common, avoidable delay.

Operation, maintenance and required recertifications

Once an ARCS is accepted, the compliance obligations do not stop. Daily checks of the dedicated radio console are required to confirm the system is operational, and some buildings supplement this with remote monitoring tools that flag faults between manual checks.

Annual certification requires resubmitting a TM-ARCS-2 form confirming the system still performs to standard, and every five years a full radio coverage survey must be conducted and compared against the original commissioning results using the same TM-ARCS-2 process.

Key ongoing obligations include:

  • Daily console checks logged and retained on site.
  • Annual certification filing through FDNY Business before the anniversary deadline.
  • Five-year recertification with a full coverage survey compared to baseline data.
  • Signed recordkeeping by a current B-03 Certificate of Fitness holder for every test event.

Retention periods for these logs matter during FDNY inspections, so building management should keep signed records accessible rather than archived off site.

Practical compliance checklist and estimated timeline

Before filing, confirm your Certificate of Occupancy, verify whether a fire alarm Letter of Approval already exists, and select your ARC System Professional and PE early. Waiting to line up these professionals until after plans are drafted is the single most common source of schedule slippage.

  1. Verify building classification and area against BC 916.3 triggers.
  2. Engage a PE and FDNY-recognized ARC company before finalizing design.
  3. File TM-1 and supporting documents through FDNY Business.
  4. Request Project Authorization once initial review clears.
  5. Complete commissioning, submit TM-ARCS-2, and prepare for acceptance testing.

Plan review typically takes several weeks per submission cycle, and incomplete insurance data or missing sealed drawings are the most frequent reasons FDNY returns a filing. Resubmitting quickly with the corrected field, rather than reworking the entire package, keeps the project moving.

Pro Tip: Ask your ARC company for a copy of their current FDNY company recognition letter before signing an agreement. An expired recognition can invalidate your commissioning test.

How Bazini Engineering supports ARCS compliance projects

Engineering firms can prepare sealed ARCS drawings, coordinate RF design with the installing contractor, and manage FDNY Business filings including Project Authorization requests. Engineers may also support commissioning oversight and review DAQ test results before submission to catch gaps early. Engaging an engineer during early design, rather than after drawings are drafted, gives the project the most room to correct course.

— Joseph

Integration with other building safety and communication systems

An ARCS does not operate in isolation. It typically ties into the building's fire alarm system so that activation events and radio system status can be monitored from the same fire command center, and battery backup for the DRC needs to be coordinated with the building's overall emergency power plan rather than treated as a standalone circuit.

Wiring pathways for ARCS often run alongside fire alarm and mass notification cabling, which means fire-rating requirements have to be coordinated across trades during design rather than resolved after conduit is already run. Buildings with a fire command center should plan ARCS console placement there from the start, since relocating it after installation is costly and can trigger a new round of plan review.

Coordination with the building's structural and architectural drawings also matters more than it first appears. Antenna and RAU placement depends on wall assemblies, ceiling plenum space, and shaft locations that are usually finalized well before fire protection systems are detailed, so late ARCS design can mean retrofitting equipment into spaces that were not built with it in mind. Looping in the ARC System Professional during the same design phase as fire alarm and sprinkler layout, discussed elsewhere in a building's overall fire suppression design, tends to prevent this kind of rework.

Integration with other building safety and communication systems — overview diagram

Key technical specifications and performance standards

FDNY's acceptance criteria for ARCS center on Delivered Audio Quality, measured across a defined grid on every floor during commissioning and recertification testing. The TM-ARCS-2 form sets the specific test items and pass criteria used to evaluate whether coverage meets FDNY's standard at each grid point.

Technician measuring ARCS radio coverage

System components generally include a Distributed Radio Coverage unit, Radio Amplification Units placed to extend signal into weak zones, and antennas distributed based on the building's floor plan and construction materials. Power design has to account for backup runtime during an outage, since the system needs to remain functional during the kind of emergency that would also affect building power.

Frequency and channel characteristics are tied to the FDNY radio bands in use citywide, and design drawings need to document which channels the system supports so plan examiners can confirm compatibility with fire department equipment. Because these specifications are set by FDNY rather than a general industry standard, a system designed to a generic public safety DAS specification will not necessarily satisfy NYC's ARCS requirements without adjustment.

Common challenges during ARCS installation and testing

Below-grade parking and mechanical spaces are a frequent source of coverage problems, since concrete and steel construction attenuates radio signal more than typical floor slabs. Buildings with multiple below-grade levels often need additional RAUs or antennas in these zones that were not anticipated in early design, which pushes commissioning costs and schedule beyond the original plan.

Overlapping coverage claims are another common sticking point. When a design relies on two antennas covering the same area for redundancy, FDNY's acceptance test may involve removing one antenna to confirm the other alone still meets DAQ standards, and designs that pass on paper with both antennas active sometimes fail this specific check.

Scheduling conflicts between the ARC System Professional, the PE witness, and FDNY's own acceptance testing staff are a practical, recurring delay. Coordinating all three calendars before locking in a commissioning date, rather than after, avoids the most common cause of a rescheduled test.

Finally, incomplete documentation, missing make and model data for antennas, an unsigned PE affidavit, or an expired ARC company recognition letter, is behind a large share of returned filings. Building these checks into an internal pre-submission review catches most of them before FDNY sees the package.

Recent updates in NYC ARCS code requirements

Bulletin #2022-01, issued in October 2022, remains the primary FDNY guidance for waiver criteria and commissioning expectations discussed throughout this article. The bulletin's revision consolidated earlier, less formal FDNY practice into a single documented standard, which gave design teams clearer criteria to work against than existed previously.

Beyond the bulletin itself, Department of Buildings code guidance tied to the 2022 Building Code cycle folded Appendix Q references into how ARCS applicability is determined for buildings that sit at the edge of occupancy classifications. Building teams working from older code cycle drawings should confirm their classification against current Building Code sections rather than assuming a prior determination still applies, particularly on projects that were designed years before filing.

FDNY's Technology Management filing requirements have also shifted toward the FDNY Business portal as the default submission channel, replacing older paper-based workflows for most ARCS application types. Teams still working from older filing instructions should confirm current procedure on the portal directly before assembling a submission package.

On-the-ground tips from real NYC ARCS projects

Hidden gross area, cellar mechanical rooms that push a building over 250,000 square feet, catches owners off guard more often than height does. Below-grade coverage is consistently the hardest part of a design to get right on the first try. Coordinating directly with plan examiners before finalizing drawings, rather than after a rejection, saves the most time.

— Joseph

Bazini Engineering: a direct partner for ARCS filings

If your building falls into an ARCS trigger or sits near the waiver threshold, Bazini Engineering handles the full path from design through filing: sealed drawings, fire suppression coordination, NYC permit filing, and commissioning oversight.

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Building owners can start with a pre-filing review of their services for building owners to confirm classification and next steps before drawings are drafted.

Sources

FAQ

What are the requirements for fire alarms in NYC?

NYC fire alarm requirements depend on building occupancy, height, and use, with specific triggers set in the Building Code and Fire Code for when a system is required and how it must be designed. ARCS is a separate but related requirement that can apply alongside a fire alarm system in qualifying high-rise, underground, or large-area buildings, as outlined in FDNY's ARCS submission procedures.

What is an ARCS system used for?

An Auxiliary Radio Communication System boosts portable radio signal for firefighters inside buildings where normal radio coverage is weak, such as high-rises, underground structures, or very large floor plates. It allows fire department personnel to communicate reliably throughout the building during an emergency response.

What are the requirements for sprinkler systems in the NYC Building Code?

Sprinkler system requirements in NYC are set by the Building Code based on occupancy type, building height, and use group, with specific design and coverage standards that differ by building classification. These requirements are addressed separately from ARCS, though both fall under the fire protection design a project's engineer of record coordinates during permitting.

What are the 10 codes used in New York City fire radios?

Specific numeric radio codes used by FDNY personnel are internal operational protocols and are not published as part of the ARCS technical requirements discussed in FDNY's bulletins or filing procedures. Building owners and design teams do not need this information to meet ARCS design, filing, or commissioning requirements.