Code Analysis · FCNYS 2025

2025 ERCES Requirements: In-Building Emergency Responder Communications Systems Are Now Mandatory in New York State

The 2025 FCNYS and EBCNYS require approved ERCES in new buildings and Level 3 Alterations. Here's what fire alarm contractors and expediters need to know before filing.

February 5, 2026 6 min read FCNYS · ERCES · Level 3 Alterations

The ability for first responders to communicate via portable radio inside a building can be the difference between a controlled emergency response and a catastrophic one. The 2025 code cycle addresses this with a clear new requirement: approved in-building Emergency Responder Communications Enhancement Systems (ERCES) must now be provided in new buildings and existing buildings undergoing Level 3 Alterations, per the 2025 FCNYS and EBCNYS. For fire alarm contractors, this isn't just a new system type to be aware of — it's a system that directly interfaces with the fire alarm installation and must be coordinated before the TM-1 is filed.

WHAT IS AN ERCES?

An ERCES (Emergency Responder Communications Enhancement System) is an in-building radio frequency amplification system — typically a Bi-Directional Amplifier (BDA) with a distributed antenna system — specifically engineered to ensure first responders' portable radios maintain adequate signal strength throughout the building's interior, including basements, stairwells, and shielded areas. It operates on public safety frequencies and must meet signal coverage standards set by the authority having jurisdiction (AHJ).

What the 2025 Code Requires

The Notable 2025 Code Changes issued by NYSED's Office of Facilities Planning describes this under Item #16:

"New requirements for new and existing buildings with level 3 alterations. Approved in-building emergency responder communications enhancement systems (ERCES) for emergency responders shall be provided as required."

— FCNYS / EBCNYS § 510.2908, Notable 2025 Code Changes, NYSED OFP (12/15/2025)

Two important observations about this language: first, it is broad — the specific signal strength thresholds and coverage requirements will be defined by the AHJ (FDNY for NYC projects, local fire departments elsewhere). Second, the phrase "as required" signals that local adoption and AHJ interpretation will shape exactly which buildings are captured. Working with the authority having jurisdiction early in the project is not optional on these projects.

When Is ERCES Triggered

Project TypeERCES Required?Code Reference
New Buildings Yes FCNYS 2025
Level 3 Alterations (existing buildings) Yes EBCNYS § 510.2908
Level 2 Alterations Not directly triggered Confirm with AHJ
Level 1 Alterations Not triggered
Change of Occupancy Verify with RDP and AHJ Depends on scope

NYC NOTE: FDNY has had its own ERCES rules

New York City had already adopted ERCES requirements prior to the 2025 statewide code cycle, through FDNY directives and the NYCBC. If you work primarily on NYC projects, this new statewide requirement may largely align with what you're already filing — but the 2025 FCNYS/EBCNYS codifies this statewide for the first time, bringing the rest of New York's municipalities up to the same standard. Verify the applicable rules with the FDNY or the local AHJ for each project.

Why ERCES Matters for Fire Alarm Contractors

The ERCES isn't a standalone system that fire alarm contractors can ignore until another trade handles it. It directly intersects with the fire alarm system in two critical ways:

1. Supervisory monitoring via the FACP. The ERCES must be monitored for system trouble and equipment failure. In most jurisdictions, this is accomplished by connecting the ERCES's trouble output to the building's fire alarm control panel (FACP). This means there are wiring and annunciation requirements that must be coordinated between the ERCES installer and the fire alarm contractor, and those interface points must be reflected in the TM-1 or equivalent fire alarm system filing documentation.

2. Battery backup coordination. Like the fire alarm system, the ERCES must have adequate backup power to operate during a primary power failure. The backup power requirements and duration must be confirmed and documented as part of the system design, and must be coordinated with the electrical engineer of record.

More System Interfaces, Same Deadline Pressure

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The ERCES Design and Approval Process

The process for getting an ERCES approved involves several steps that need to start well before permit submission:

  • Frequency coordination: The ERCES must operate on the specific public safety frequencies used by the local emergency services. These are obtained from the AHJ and may require coordination with regional public safety communications authorities
  • Coverage testing: A pre-installation signal survey establishes the baseline in-building signal environment. Post-installation testing is required to demonstrate that the system meets the AHJ's coverage thresholds (typically 95% or 99% floor area coverage)
  • FCC licensing: The booster amplifier used in most ERCES installations requires an FCC license under specific rules for Part 90 boosters. This is typically handled by the ERCES specialty contractor
  • AHJ approval: The system design and installation must be reviewed and approved by the fire department having jurisdiction
  • Annual testing: Ongoing inspection and testing requirements apply after installation — this is something building owners and facility managers need to be informed of at project closeout

Filing Coordination Checklist for Projects with ERCES

On projects where ERCES is triggered, confirm the following during pre-filing coordination:

  • Is the project new construction or a Level 3 Alteration? Confirm the ERCES requirement applies
  • Has the ERCES specialty contractor been engaged and are they coordinating with the AHJ on frequency requirements?
  • Are the ERCES FACP interface points specified in the fire alarm system design and reflected in the TM-1?
  • Has the electrical engineer addressed ERCES backup power requirements in the electrical drawings?
  • Is the ERCES on the AHJ's list of pre-approved equipment types, or does it require a separate variance or approval?
  • For NYC projects: has the FDNY ERCES submittal process been initiated separately from the DOB permit application?

How This Fits the 2025 Code Picture

The ERCES requirement is part of a broader 2025 code trend toward integrated life safety systems. In the same update cycle, new rules for Mass Notification Systems (BCNYS § 917.2), elevator smoke curtains (BCNYS § 3006.3), and EV garage sprinklers (BCNYS § 903.2.9) all point toward fire alarm and life safety systems that are more complex, more integrated, and more documentation-intensive than their predecessors. The projects that handle this successfully are the ones where the fire alarm contractor, ERCES specialist, mechanical engineer, and expediter are coordinating from the design phase — not after the permit submission.

Frequently Asked Questions

An ERCES is a dedicated in-building radio amplification system for public safety frequencies — the channels used by police, fire, and EMS radios. A commercial DAS (Distributed Antenna System) serves cellular and commercial wireless carriers. They are separate systems with different regulatory frameworks, frequency bands, and approval authorities. Some buildings have both, but they are not interchangeable.

No. Based on the 2025 code changes, ERCES under the EBCNYS applies to Level 3 Alterations. Level 2 Alterations have different compliance obligations. Always confirm the alteration level with your design team — the distinction between Level 2 and Level 3 can significantly affect project scope and cost.

The ERCES design is typically performed by a licensed communications systems engineer or a specialty ERCES contractor. The system must be approved by the AHJ — in NYC, that's the FDNY. The expediter coordinates to ensure the ERCES approval documentation is in order for permit and certificate of occupancy purposes.

The ERCES supervisory signals — primarily equipment trouble — are connected to the building's FACP so that system failures are reported to the monitoring station and annunciated at the panel. Fire alarm contractors must reflect these interface points in the TM-1 filing documentation and coordinate the wiring requirements with the ERCES installer.

The ERCES requirement is not limited to schools — it applies to new buildings and Level 3 Alteration projects broadly. School projects under NYSED oversight that qualify will need to meet this requirement alongside the other 2025 code changes affecting educational facilities.
Disclaimer: This article is for informational purposes only, based on the Notable 2025 Code Changes List issued by the NYSED Office of Facilities Planning on December 15, 2025. Fire PDF Pro is not a legal or engineering firm. All design decisions and permit filings must be reviewed by a Registered Design Professional (RDP) and verified against official publications from the NYS Department of State, NYSED, NYC DOB, and FDNY. ERCES requirements may vary by jurisdiction and AHJ — always verify with the local fire department and the authority having jurisdiction before finalizing your design.