ARCS 2.0: What FDNY's Proposed High-Rise Radio Overhaul Means for Your Plan Filings

On March 14, 2025, FDNY Chief John Esposito testified before the NYC Council Committee on Fire and Emergency Management and formally described the department's proposal for ARCS 2.0 — a next-generation replacement to the in-building auxiliary radio communication system currently mandated under NYC BC § 916. The proposal comes alongside the FDNY's 2025 Strategic Plan, which identifies ARCS 2.0 as a department-wide infrastructure priority, and the FDNY's FY 2025 Regulatory Agenda, which signals incoming rule modifications affecting every TM-1 and plan submission that touches an existing or new ARCS installation.

If you work high-rise in this city — whether you're filing TM-1s, managing ARCS submissions through FDNY Business, or sitting on the design side — this is a proposal you need to understand now, before the code revisions land.

ARCS Today: What the Current Requirement Looks Like

Before getting into ARCS 2.0, it's worth establishing what the current system actually requires — because a surprising number of filings get tripped up on the scope triggers and exceptions.

Under 2022 NYC BC § 916, an Auxiliary Radio Communication System is a wireless, bidirectional in-building radio network — base station, building-wide antenna system, and dedicated radio console in the lobby — designed to carry FDNY portable radio signals throughout a building regardless of construction type or floor depth. It runs on exclusive FDNY frequencies and must operate continuously, including during power outages.

Who triggers the requirement today:

• All newly constructed high-rise buildings — defined as any building with an occupied floor located more than 75 feet above the lowest level of FDNY vehicle access, irrespective of occupancy
• Buildings with a total gross area exceeding 250,000 square feet
• Existing buildings undergoing major alterations that trigger full code compliance

The 2022-01 Exception — and why it matters:

FDNY Bulletin 2022-01 (effective immediately upon release in October 2022) created a significant carve-out. The Bureau of Operations determined that current FDNY portable radios provide adequate coverage in many buildings over 75 feet without ARCS enhancement. Accordingly, a building is exempt from installing an ARCS system when all four conditions are simultaneously met:

• Occupancy is Group R-1, R-2, or B (per NYC Building Code)
• Height of the highest roof surface is 150 feet or less above the lowest level of FDNY vehicle access
• The building has no more than one story below grade
• Total gross area does not exceed 250,000 square feet

The Interference Problem ARCS 2.0 Is Designed to Solve

Council Member Marmorato opened the March 14, 2025 hearing by raising a specific and pointed concern: reports of firefighter radio interference in high-rise buildings, drawing a direct parallel to the communications failures that cost lives at the World Trade Center on September 11, 2001.

Chief Esposito's response was both reassuring and candid. He confirmed that FDNY communications have improved substantially since 9/11, with ARCS installations being a direct result of those lessons. But he also acknowledged a known limitation in the current system architecture: inter-building interference.

The problem occurs when an ARCS system in one building activates — and its signal bleeds into an adjacent building where FDNY units are actively operating on the same radio frequency band. The systems are designed to use exclusive FDNY frequencies to prevent external interference, but when two proximate buildings are both running ARCS hardware on the same frequency allocation, activation in one can create noise in the other.

Esposito was explicit that this has not, to date, materially impaired firefighting operations. But the department's position is clear: the goal of ARCS 2.0 is to eliminate this failure mode entirely, not manage it. That distinction matters for how the new technical criteria will be written.

What ARCS 2.0 Actually Proposes

Based on publicly available information — the City Council testimony, the FDNY 2025 Strategic Plan, and the FDNY FY 2025 Regulatory Agenda — the ARCS 2.0 proposal has three core components:

1. Elimination of inter-building interference through updated system architecture. The specific technical mechanism has not been published in final form, but the stated objective is to design away the scenario where one building's ARCS activation creates radio frequency conflict in an adjacent building. This will almost certainly require changes to the RF specifications and antenna design criteria currently in the ARCS Technical Criteria Document.

2. Expansion of in-building coverage to EMS personnel. Current ARCS systems operate exclusively on FDNY fire radio frequencies. According to the FDNY Strategic Plan 2025, ARCS 2.0 will expand in-building radio coverage to include EMS units. This is a meaningful scope expansion — it will add system requirements and may affect the equipment specifications required in ARCS filings.

3. Reduction of legacy compliance costs for building owners. The FDNY Regulatory Agenda explicitly states that the intent of the ARCS rule modifications is to reduce cost and administrative burden for building owners. The proposed changes will align the ARCS Technical Criteria Document with current FDNY radio systems and simplify the documentation required to be filed through FDNY Business.

Current ARCS vs. ARCS 2.0: What We Know

What This Means for Your Filings Right Now

The ARCS 2.0 proposal creates a planning horizon problem for contractors and expediters: projects designed today will be built and inspected under whatever code is in effect at the time of permit issuance or inspection. Here's how to think about it:

Projects currently in design and filing: Use the current requirements. BC § 916, the July 2024 ARCS Submission Procedures, and Bulletin 2022-01 are the governing documents. There is no retroactive obligation and no transition trigger until a final rule is published and adopted.

Projects with long design cycles (24+ months out): Build awareness of ARCS 2.0 into your project schedule. Once the technical criteria are published for public comment, there will typically be a notice period before adoption. Projects that span the adoption date may face mid-stream scope changes. Inform your design professionals early.

Projects in existing buildings with legacy ARCS: The regulatory agenda's stated intent is to reduce costs, not mandate wholesale replacements. But once the rule is final, existing systems may face recertification or upgrade requirements depending on the transition provisions. Watch the rulemaking closely.

The Current ARCS Plan Submission Process (July 2024 Update)

While waiting for ARCS 2.0 to take shape, the current submission process — per the FDNY ARCS Plan Submission and Approval Procedures document revised July 11, 2024 — is what governs every active project. This is a three-phase process: Plan Approval, Commissioning, and Inspection/Acceptance.

Phase A — Plan Filing and Approval

Phase B — Commissioning Test Report

The commissioning test report application is filed through FDNY Business under "ARCS Commissioning Test Report" application type. The package requires all of the following:

• TM-1 indicating "Commissioning Test Report" and the ARC system type in the Job Description (not required for 5-year recertification)
• RDP affidavit confirming the system is designed, installed and operates in compliance with FCC regulations, FC 511, BC § 916/917, NFPA 72 as amended by Appendix Q, and 3 RCNY 511-01 (not required for 5-year recertification)
• As-built riser diagrams and floor plans, sealed and signed by the RDP (not required for 5-year recertification). If device locations or quantities differ from the approved drawings, a PAA must be filed first.
• Completed TM-ARCS-2 — the Visual and Functional Testing Form, completed by the holder of the ARC System Professional Certificate of Fitness (B-03). This is the annual/recertification testing document — it is not the same as ARCS 2.0.
• Copy of the B-03 Certificate of Fitness of the individual performing the test
• Full Commissioning Test Report per 3 RCNY 511-01, including test grid floor plans, DAQ and signal strength results, and individual audio recordings per test grid. Audio files must be submitted in .ZIP files organized by floor or sequential floor groups.
• Overlapping Coverage designs require additional tests with all antennas disconnected on the test floor, completed for all below-grade floors, all roof levels, and every 3rd floor. Results must be clearly labeled to differentiate normal vs. overlapping coverage conditions.
• Comprehensive equipment list — all manufacturer names and part numbers for all equipment, devices, and cables (not required for 5-year recertification)
• NRTL listing details for all devices, cables, and equipment (not required for 5-year recertification)
• Spectrum analyzer make, model, and last calibration date
• Copy of DOB Certificate of Occupancy or approved Schedule A
• Fully executed ARCS Owner Agreement with FDNY signatures (not required for 5-year recertification)
• Copy of the ARCS Letter of Approval (recertification applications only)

Upon acceptance of the commissioning test report, Technology Management issues a Letter of Acceptance. The 5-year recertification must be submitted no less than once every five years per 3 RCNY 511-01 § G.4.

Phase C — Inspection and Acceptance Test

What to Watch For as ARCS 2.0 Moves Through Rulemaking

The FDNY rulemaking process for ARCS 2.0 will follow a defined public process. Here are the specific milestones worth tracking:

• Publication of the proposed rule in the NYC Rules database — this is the official public notice. It will include the specific modifications to the ARCS Technical Criteria Document and a 30-day public comment period.
• Public hearing — the FDNY is required to hold a public hearing for rules of this type. This is where industry stakeholders (contractors, expediters, building owners, engineers) can submit formal comments.
• Final rule adoption and effective date — the effective date in the final rule is the date from which new submissions must comply. Projects already approved before the effective date are typically grandfathered under prior requirements, unless a PAA is filed after adoption.
• Updated ARCS Technical Criteria Document — the revised criteria document will be the operative technical standard for all new designs once the rule is adopted. Watch for changes to the RF coverage requirements, antenna specifications, and equipment listing requirements.

The most reliable way to track ARCS 2.0's progress is through the FDNY section of the NYC Rules portal ↗ and the DOB Industry Notices page ↗, both of which publish bulletins and proposed rules as they move through the process.