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E-Micromobility Cabinet Review and Installation

E-Micromobility Lithium-Ion Battery Charging Accelerator

Over the past three years, NYC has seen a large surge in the use of e-micromobility devices such as e-bikes and e-scooters, most of which are powered by lithium-ion batteries. These batteries have become a leading cause of fires and even fire-related deaths in NYC.

FDNY is partnering with other City agencies to meet this difficult moment. To protect life and property while simultaneously supporting our communities’ needs, the FDNY is setting up interim lithium-ion battery charging cabinet review and installation processes.

NOTE: These processes are temporary. Upon publication of a battery charging cabinet standard by Underwriters Laboratories (UL), the FDNY will revise this process. The Fire Department anticipates that manufacturers seeking FDNY approval of their battery charging cabinet will need to have their product tested and listed to the applicable UL standard. Any cabinet or rack previously approved for use through a "Letter of No Objection" will remain subject to additional conditions, restrictions, and/or limitations.

Equipment Review for All Charging Cabinet Installations (as of 7/15/2024)

FDNY Reviewing Unit: Technology Management (TM)
Anticipated Timeline: 10-12 weeks

Fire Code
The Fire Code Section 309.3.3 requires that “Battery packs and other removable storage batteries shall not be stacked or charged in an enclosed cabinet (unless the cabinet is specially designed and approved by the department for such purpose).”

Product Testing
Prior to seeking Fire Department approval, the manufacturer (“applicant”) must arrange to have the charging cabinet tested by a testing laboratory to demonstrate that a battery fire induced in a compartment during the test does not propagate to adjacent batteries in other compartments.

  • The testing laboratory conducting the test must be a nationally recognized testing laboratory (NRTL).
  • A list of NRTLs is maintained by the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) and can be found on the OSHA website.

FDNY Application for Document Review
The applicant must complete and file online a TM-1 application for document review via the FDNY Business Portal. The application type for this application is the Engineering Application. The applicant must include any/all pertinent information, including:

  • Whether the cabinet is intended and recommended for installation and use indoors, outdoors, or both.
  • Test report: Video footage of the testing process (send link or upload)
  • Hazard Mitigation Analysis (HMA), prepared by a registered design professional
  • User manual and spec sheet of the product: Photographs

The applicant may request a meeting to discuss the product with the Technology Management team (within the Bureau of Fire Prevention) before such product is submitted for testing and/or an application is filed with FDNY. Direct requests to FDNY.BusinessSupport@fdny.nyc.gov.

Outcomes
The applicant may expect any of the following possible outcomes:

Letter of Deficiency (LOD) to be provided if:

  • Tech Management has any follow up questions
  • Tech Management requires additional information or documentation
  • Tech Management requests requires that the HMA be revised
  • Tech Management denies the application
    • The applicant must address the LOD if the application is continued
  • NOTE: If a Letter of Deficiency is unresolved or documents are not provided within six months, the application may be deemed to have been abandoned.

Letter of No Objection (LNO) to be provided if:

  • Tech Management has no objection to the use of the equipment for the purposes described in the application, subject to various conditions, restrictions, or limitations specified in the Letter of No Objection (for example, conditions may be imposed regarding installation, operation, and maintenance of the equipment, energy capacity, clearances, signage, ventilation, minimum room size, etc.)

Additional Considerations for Indoor Charging Cabinet Installations (as of 7/15/2024)

Additional Agencies Involved: DOB
FDNY Inspection Unit: Special Inspections Unit (SIU)

Fire Code
Where a charging cabinet is approved for an indoor location, Fire Code Section 309.3.3 requires that it be installed in a suitable indoor room or area that:

  • Has an adequate electrical supply and a sufficient number of electrical receptacles to allow the charging equipment for each powered mobility device to be directly connected to a receptacle
  • Is separated by a fire barrier with a minimum one-hour fire resistance rating from areas where repairs or servicing is conducted
  • Is provided with a portable fire extinguisher
  • Provides additional protection where six or more devices are charged:
    • Must be a dedicated room or area kept secure from unauthorized entry
    • Must be separated by a fire barrier enclosing the entire space with a minimum one-hour fire resistance rating
    • Must be protected by a fire sprinkler system
    • Must be protected by one or more smoke detectors or smoke alarms

*Additional requirements are set forth in FC 309.3.3.

Fire Code Section 309.3.3 prohibits:

  • The use of extension cords and power strips
  • Storage of combustible materials in the same space

Installation

  • The Letter of No Objection (LNO) that Technology Management provides to each manufacturer is product-specific with stipulations that are required to be followed for the installation of these products.
  • The end user must consult the manufacturer’s installation manual prior to installation of the equipment to ensure compliance.
  • All indoor installation would need to be reviewed and approved by the DOB. See DOB’s Information for Property Owners.
  • The indoor installation may be subject to subsequent FDNY inspection.

Additional Considerations for Outdoor Charging Cabinet Installations (as of 7/15/2024)

Additional Agencies Involved: DOT, DOB
FDNY Reviewing Unit: Technology Management (TM)
FDNY Inspection Unit: Special Inspections Unit (SIU)
Anticipated Timeline: 8-12 weeks

Fire Code
Where a charging cabinet is approved for an outdoor location, Fire Code Section 309.3.3 requires that it be installed in a suitable outdoor area that:

  • Has an adequate electrical supply and a sufficient number of electrical receptacles to allow the charging equipment for each powered mobility device to be directly connected to a receptacle
  • Is separated by a fire barrier with a minimum one-hour fire resistance rating from areas where repairs or servicing is conducted
  • Is provided with a portable fire extinguisher
  • Provides additional protection where six or more devices are charged:
    • Must be a dedicated room or area kept secure from unauthorized entry
    • Must be separated by a fire barrier enclosing the entire space with a minimum one-hour fire resistance rating
    • Must be protected by a fire sprinkler system Must be protected by one or more smoke detectors or smoke alarms

*Additional requirements are set forth in FC 309.3.3.

Fire Code Section 309.3.3 prohibits:

  • The use of extension cords and power strips
  • Storage of combustible materials in the same space

FDNY Application for Document Review
The applicant (in this case the end-user or cabinet purchaser) must complete and file a TM-1 application online for document review via the FDNY Business Portal for FDNY site plan review and approval of their proposed installation. The application type for this application is the Engineering Application. The applicant must include any/all pertinent information, including:

  • Site plan and surroundings
    • Include where shut off is located
    • Include wiring
    • Include demonstrated clearances
    • Supervisory contact: name and contact information for the person monitoring the equipment
  • Final approval of installation is conditioned upon an FDNY inspection.
  • The outdoor installation may be subject to subsequent FDNY inspection.

Installation

  • The Letter of No Objection (LNO) that Technology Management provides to each manufacturer is product-specific with stipulations that are required to be followed for the installation of these products.
  • The end user must consult the manufacturer’s installation manual prior to installation of the equipment to ensure compliance.
  • Final approval of installation is conditioned upon an FDNY inspection.

Outdoor Installation Clearances

  • Vehicle Impact Protection: Cabinets on roadways, sidewalks, and parking lots would likely need to be adequately protected from vehicle impact (e.g., jersey barriers).
  • Required Clearance: Cabinets would need to be located a minimum of 10 feet from the following exposures (except as otherwise provided):
    • Combustible materials or combustible waste;
    • Any building entrance or exit (5 feet for other building openings, including openable window or intake or exhaust vent);
    • Any building of wood frame construction;
    • Any subway entrance or exit (5 feet for any subway vent or other opening that is not a subway entrance or exit);
    • Any vehicle parking; and
    • Any vent or fill line of any flammable/combustible liquid storage tank.
  • Inspections: Final approval of installation is conditioned upon FDNY inspection.
  • Supervision: General supervision by a responsible person who must be familiar with the cabinet, the conditions, and restrictions related to its use is required.
  • Signage: Signage containing Emergency Contact Information and power shut off location is required in the event of an emergency.
  • Utility Coverings and Hardware: Utility shutoff valves/hardware cannot be covered or obscured in any way.
  • Openings: Basement and cellar doors and openings (e.g., windows) cannot be blocked or have their use hindered in any way.
  • Fire Escapes: Nothing shall be placed under a fire escape that blocks or hinders use of the fire escape and/or drop ladder. (FC1027.7; FC1027.7.4).
  • Fire Department Connections: In addition to maintaining clearance from fire department connections, same must be fully visible from the street (FC912.2.1). Fire department connections must be immediately accessible and cannot be blocked or obscured (FC912.3); and a working space of three feet in width and depth must be maintained, as well as 78" in height above fire department connections.
  • Hydrants: Five feet clearance on sidewalks; 15 feet clearance on roadways.
  • Elevated Structures: Conditions might prohibit installation under elevated structures.
  • Clearance from FDNY Driveways (Curb Cuts): 10 feet clearance is required, including on the roadway opposite FDNY driveways.

Note: Conditions that might be attached to such approvals are based upon a variety of factors that may or may not be specifically enumerated in the Fire Code or Fire Department rules.

More information: