Project teams in New York City are going to have to break a longstanding tradition: filing plans for permits on paper.
by Frank Scanlon, CTA ARCHITECTS P.C.
Major procedural changes occurred this Summer at the New York City Department of Buildings (DOB), with building officials no longer accepting paper filings for many common project activities. And by early next year, the new rules will cover many more aspects of most construction projects.
The digital transformation for filing permits, plans, and other documents with the DOB is well underway – and with it comes a host of changes that owners, design professionals, construction teams, licensees, and filing representatives must master.
The ongoing introduction of the DOB NOW online filing platform – with rolling deadlines for additional filing types to start mandatory use of the self-service system – began in 2015 and is planned to finish next year. Ultimately, all industry participants will do business online with the DOB through the platform, which has four main portals: “Build”; “Inspections”; “Licensing”; and “Safety.”
Safety may be the portal most familiar to property owners and managers, because it has been mandatory for approximately the last three years. Compulsory DOB NOW filing started in September 2016, approximately two thirds of the way through the Façade Inspection Safety Program (FISP) Cycle 8(A) filing window, and since then it is how users have filed, signed, submitted, and paid for FISP Report filings. (FISP Cycle 8 began in 2015 and wrapped up earlier this year, with Cycle 9 scheduled to open in February 2020).
DOB NOW’s first areas of focus went across many inspection and safety filings, with periodic transitions for mandatory use in other areas. The very first modules came online in 2015 with inspections enforcement documents for licensed professionals and tradespeople.
Mandatory use of DOB NOW began to apply directly to owners in 2016 with FISP in September 2016, and continued with boiler safety in August 2017, and elevator safety in September 2018.
More recently, starting in July 2019, DOB NOW began to apply to other common work types for both restoration and new build projects, including mechanical systems, structural work, plumbing, sprinklers, and standpipes. Other new areas starting in September of this year included certain types of boiler work.
These additional DOB NOW mandatory filing requirements will require more involvement from owners, because the online forms now require electronic signatures via their e-filing accounts. Owners and others must also pay the prerequisite fees online through DOB NOW.
These changes also mean the agency will no longer accept paper copies for drawings or most other forms for any of the disciplines that have shifted to mandatory DOB NOW filing. For instance, the DOB stopped accepting paper copies of plans as of July this year. For any disciplines that have yet to transition to the platform, however, filers for now must continue to use the historic paper document process.
An important change is that unlike past practice, project representatives must now execute separate filings – and secure separate approvals and permits – for each discipline that has transitioned to mandatory DOB NOW usage.
One piece of good news for owners and other project representatives who filed under FISP Cycle 8 and other inspections programs is that they can continue using the same e-filing account they set up for DOB NOW’s other filing requirements.
Owners using DOB NOW will ultimately have a tool that is designed to expedite the filing and approvals process. Significantly, it will allow owners to monitor progress on all of the filings for their projects.
But there also is the potential for added cost in the form of additional filing and professional fees, because each discipline will now require its own separate construction document set and filing, which calls for significant project team coordination. Project representatives will no longer be able to file a single set of documents illustrating the work of all disciplines, as was historically the practice.
Another potential wrinkle is that some of the platform’s mechanics are still in development. Filers of FISP Cycle 8 may recall a few difficult months late in the sub-cycle 8A filing window with DOB NOW glitches. There may be a period of confusion as the system undergoes a multi-year upgrade to work out such kinks.
But users may also remember that the FISP filing process eventually became a relatively “well-oiled machine” by the end of 8C, the last of the three sub-cycles. Similar growing pains and successful fixes are likely to continue as DOB NOW’s scope expands to include additional disciplines and work types.
Ultimately, potential uses of DOB NOW will continue to expand, and its final completion may be several years off. But with much of the initial rollout underway, DOB will have room to grow the platform’s scope, reach, and future plans.
Additional information on this subject is available at https://www1.nyc.gov/assets/buildings/pdf/dob_now_general_presentation.pdf
Frank Scanlon is an architect at New York City-based CTA Architects PC.