There's a problem that comes up regularly in NYC existing buildings: the Building Code requires a stationary generator for emergency power, but the building simply doesn't have the space — no room for the generator itself, no room for fuel oil pumps, transfer switches, fuel oil risers, or the electrical risers that go with it. In the past, DOB handled this with a case-by-case special permission process. Now, there's a cleaner path.
Buildings Bulletin 2026-009, issued May 28, 2026 by DOB Assistant Commissioner Joseph Ackroyd, P.E., CFM, clarifies when an Uninterruptible Power Supply (UPS) system can serve as the emergency power source for a fire alarm system or in-building Auxiliary Radio Communication System (ARCS) — without any special permission from DOB. The authority comes from the 2025 NYC Electrical Code, section 700.12(E), which for the first time permits a UPS as an emergency power source without special permission. This Bulletin translates that code change into actionable field requirements.
SCOPE OF BB 2026-009
This Bulletin applies exclusively to buildings where no stationary generator is installed. If your building has a generator, the fire alarm system and ARCS must connect to that generator — full stop. The UPS path is for buildings without a generator and where installing one poses a genuine hardship. The Bulletin does not address lead-acid UPS units used for non-emergency power — a separate Buildings Bulletin will cover that. Relevant code sections: 2025 NYC EC 700.12(E), BC 2702.2.1.1, §28-105.1, §28-116.2.4.
What Changed: 2011 EC vs. 2025 EC
Under the 2011 NYC Electrical Code, using a UPS as a source of power for emergency systems always required special permission — there was no code path around it. The process was cumbersome, project-specific, and created delays on jobs where the answer was almost always going to be yes anyway.
The 2025 NYC Electrical Code, section 700.12(E), changes that by expressly allowing a UPS as a source of power for emergency systems without special permission. But it comes with an important carve-out: where a stationary generator is installed in accordance with the 2022 NYC Building Code, the UPS may not be used as the emergency power source. The generator takes priority, and the UPS option only applies when there is no generator.
THE GENERATOR RULE IS ABSOLUTE
If a stationary generator is installed in the building, the fire alarm system and ARCS must be supplied by that generator. You cannot choose a UPS over a generator — even if the UPS meets all the conditions in this Bulletin. The UPS-as-emergency-power path is available only where no generator exists.
Which Systems Can Connect to the UPS
Section II of BB 2026-009 limits the UPS emergency power option to two systems:
Fire Alarm System
Including systems with emergency voice/alarm communications (EVAC). Both the base fire alarm system and the voice/alarm communications component may be powered from the dedicated UPS.
In-Building ARCS
Where an Auxiliary Radio Communication System is provided in the building, it may also connect to the same dedicated UPS — provided all conditions in Section III are met.
Nothing else. The UPS is dedicated exclusively to these two systems and cannot supply backup power to any other electrical load in the building. This is a hard restriction, not a guideline.
Section III: The Full Acceptance Criteria
Where no generator is installed, a UPS may power the fire alarm system and/or ARCS — but only if it meets every requirement in Section III. The conditions are organized into three groups: battery and system standards, room requirements, and fire alarm monitoring of the UPS itself.
Section III.A
UPS Battery and System Standards
- Lead Acid batteries only. No lithium-ion, no VRLA variants outside Lead Acid — the Bulletin is explicit on technology type.
- NFPA 111-2013 compliance. The UPS system and its installation must comply with the Standard on Stored Electrical Energy Emergency and Standby Power Systems. Additional requirements from NFPA 72, as modified by Appendix Q (which permits batteries as a secondary power supply), also apply.
- UL listings required. Batteries must be UL 1989 or UL 1973 listed. The UPS system itself must be UL 1481 listed.
- Six-hour minimum runtime. The UPS must be sized to support the full fire alarm system load and the full ARCS system load simultaneously for no less than six hours.
- Red placard labeling. The UPS must display a red placard with white lettering identifying it as the UPS for the fire alarm system and ARCS, and stating that no other systems may use it.
- Dedicated use only. The UPS must not supply or provide backup to any other electrical load — no exceptions.
- 70 kWh aggregate capacity cap. The total capacity of the UPS system must not exceed 70 kilowatt hours.
- O&M compliance. Operation and maintenance must comply with section 604 of the Fire Code and the NYC Electrical Code.
Section III.B
UPS Room Requirements
- 2022 Fire Code indoor battery requirements. The room must comply with FC requirements for indoor battery installations, including smoke detection, location, and monitoring. FDNY Certificate of Approval per FC 608.5 and FC 112 is not required. The UPS location must also comply with NFPA 111 Section 7.2 and Building Code Appendix G.
- Ventilation. The UPS room must comply with 2022 NYC Mechanical Code section 502.4.
- Fire suppression, when required. A fire suppression system must be provided per BC 903.2 when required. Exception: when the UPS room contains only electrical equipment, an automatic sprinkler system is not required if the exception conditions in section 903.2 are met. Any provided fire suppression must comply with NFPA 111 Section 7.4.2.
- Smoke detection. Smoke detection must be provided in the UPS room in accordance with BC 907.2.23.
- 2-hour fire-rated room. The UPS and all associated system components must be housed in a room with a 2-hour fire rating.
Section III.C
Fire Alarm System Monitoring of the UPS
- Trouble signal monitoring. The UPS must be monitored for a trouble signal on the building's fire alarm system. Where the UPS cannot output a trouble signal, other means of monitoring approved by the Fire Commissioner may be accepted.
- Occupancy restriction when UPS is non-operational. If trouble or supervisory signals from the UPS indicate the system is completely discharged or non-operational, the protected area must not be occupied — unless FC 901.7 allows occupancy, or the UPS fault is corrected.
- Primary power monitoring. Primary power supplying the UPS must be monitored. Loss of primary power must generate a supervisory signal to the fire alarm system.
Quick Reference: UPS Acceptance Checklist
| Requirement | Applies When | Key Standard / Reference |
|---|---|---|
| Lead Acid battery technology only | Always | BB 2026-009 Section III.A.1 |
| UL 1989 or UL 1973 listed batteries | Always | BB 2026-009 Section III.A.3 |
| UL 1481 listed UPS system | Always | BB 2026-009 Section III.A.3 |
| Minimum 6-hour runtime (full FA + ARCS load) | Always | BB 2026-009 Section III.A.4 |
| Max 70 kWh aggregate capacity | Always | BB 2026-009 Section III.A.7 |
| Red placard with white lettering | Always | BB 2026-009 Section III.A.5 |
| Dedicated to FA/ARCS only — no other loads | Always | BB 2026-009 Section III.A.6 |
| 2-hour fire-rated room | Always | BB 2026-009 Section III.B.5 |
| Smoke detection in UPS room | Always | BC 907.2.23 via Section III.B.4 |
| FDNY Certificate of Approval | Not required | FC 608.5 / FC 112 — explicitly waived |
| Fire suppression system in UPS room | When required by BC 903.2 | Exception available for electrical-only rooms |
| Trouble signal monitoring on FA system | Always | BB 2026-009 Section III.C.1 |
| Primary power supervisory signal on FA system | Always | BB 2026-009 Section III.C.3 |
Permits and Inspections
Section IV is straightforward: an electrical permit must be obtained by a New York City licensed electrical contractor per AC §28-105.1 before work begins. After installation is completed, a final electrical inspection sign-off must be obtained per AC §28-116.2.4. Depending on the scope of the project, additional permits may be required.
WHAT THIS MEANS FOR YOUR FILING
The UPS installation under this Bulletin is an electrical permit job, not a fire alarm plan filing on its own. However, the fire alarm system monitoring requirements in Section III.C will almost certainly require a concurrent fire alarm alteration filing to add trouble and supervisory signal outputs from the UPS to the fire alarm control panel. Coordinate both scopes before pulling permits.
Fire Alarm Filings Still Require a TM-1
Whether you're connecting a new UPS to an existing fire alarm system or filing a full alteration, FDNY requires a completed TM-1. Fire PDF Pro pulls live DOB data — correct BIN, building class, construction type, occupancy group — and auto-fills it in seconds.
Auto-Fill Your TM-1 →Frequently Asked Questions
The information in this article is intended for general informational purposes and reflects the content of NYC Buildings Bulletin 2026-009 as published by the NYC Department of Buildings on May 28, 2026. It does not constitute legal, engineering, or professional code compliance advice. Building code requirements, DOB bulletins, and FDNY filing procedures are subject to change and may be interpreted differently based on project-specific conditions. Readers should verify all requirements with current official sources and consult with a licensed New York State professional engineer, registered architect, or qualified expediter before making project decisions. Fire PDF Pro and GLA Enterprise assume no liability for actions taken in reliance on this information.