As electric school buses and district fleet vehicles become increasingly common across New York State, the 2025 BCNYS has responded with a targeted fire suppression requirement. Under new BCNYS § 903.2.9, automatic sprinkler systems are now mandatory in bus storage and repair garages that house lithium-ion or lithium metal powered vehicles. This isn't a recommendation — it's a hard code requirement with a clear addition threshold that changes how these projects must be designed and filed.
KEY RULE: Additions Without a Fire Wall Affect the Entire Building
If an addition of 500 sf or more does not have a fire wall separating it from the existing structure, both the addition AND the existing building must receive full sprinkler coverage. A fire wall is not just a fire-rated partition — it must meet the structural independence requirements of the code to provide this separation benefit.
What the Code Says
The Notable 2025 Code Changes list issued by NYSED's Office of Facilities Planning on December 15, 2025 describes the change under Item #2 as follows:
"An automatic sprinkler system shall be provided throughout bus storage and/or repair garages that house lithium-ion or lithium metal powered vehicles. This requirement is applicable to additions 500 sf and greater. Unless the addition is separated by a fire wall from the original building, both the addition and existing structure will require full sprinkler coverage."
— BCNYS § 903.2.9, Notable 2025 Code Changes, NYSED OFP (12/15/2025)
Why This Matters: The Lithium-Ion Fire Risk
Lithium-ion battery thermal runaway events are fundamentally different from conventional vehicle fires. They generate significantly higher temperatures, can reignite hours after appearing extinguished, and produce toxic gases that complicate suppression. Standard fire protection designs for diesel bus garages do not account for these hazard characteristics. The code is catching up to a real operational risk that already exists in facilities that have transitioned to electric fleets without a corresponding update to their fire suppression infrastructure.
For new school transportation facilities and for districts adding EV charging infrastructure, this means the fire suppression system must be part of the core design from day one — not an add-on after permit issuance.
When Exactly Is This Triggered
The requirement applies to new construction and to additions of 500 square feet or greater. The trigger conditions are:
- The facility is a bus storage garage or bus repair garage
- The garage houses lithium-ion or lithium metal powered vehicles (electric buses)
- The project is new construction, or an addition of 500 sf or more
Traditional diesel, CNG, or propane bus fleets do not trigger this specific section. However, if a district plans to phase in electric buses into an existing garage in the future, the design team should evaluate the fire suppression system now to avoid a costly retrofit later.
The Fire Wall Rule: Understanding the Addition Impact
The most operationally significant aspect of this code change is the fire wall provision. When a qualifying addition is constructed:
| Addition Scenario | Sprinkler Requirement |
|---|---|
| Addition < 500 sf | § 903.2.9 not triggered |
| Addition ≥ 500 sf + fire wall separation | Addition only requires sprinklers |
| Addition ≥ 500 sf + no fire wall | Addition AND entire existing building require sprinklers |
| New construction, any size with EV fleet | Full sprinkler system required throughout |
The cost and schedule implications of the "no fire wall" scenario are significant. Retrofitting an existing structure with a full sprinkler system — including water supply upgrades, piping, heads, and alarm integration — can dramatically change project scope and budget. Identifying this early in design is critical.
Keep Your Filing Package Moving While Engineering Resolves the Design
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Access the Filing Tools →Filing Checklist for EV Bus Garage Projects
When preparing the permit submission package for a bus garage project involving electric vehicles, confirm the following with your design team before filing:
- Is the vehicle fleet lithium-ion or lithium metal powered? If yes, § 903.2.9 is triggered
- Is the project new construction or an addition ≥ 500 sf? Confirm the exact addition footprint
- If an addition: is a code-compliant fire wall provided between the addition and existing structure?
- If no fire wall: is the existing building included in the sprinkler system scope?
- Does the water supply calculation support full coverage of the required area?
- Is the sprinkler system integrated with the fire alarm system per the project's TM-1 documentation?
Context: Other EV-Related 2025 Code Changes
The § 903.2.9 change for bus garages is not the only EV-related update in the 2025 code cycle. The 2025 FCNYS also introduced FCNYS § 322, which establishes new restrictions and requirements for powered micromobility device charging — covering e-bikes, e-scooters, and similar devices stored or charged in any structure. Schools that allow staff or students to charge these devices on premises should review § 322 with their fire safety plan team. NYSED has indicated that specific guidance for schools will be provided in the upcoming 2025 Manual of Planning Standards (MPS).