Key Highlights
- TM-2 is the application form, while COA is the FDNY approval outcome.
- NYC BESS approval begins with product-level safety documentation and testing.
- FDNY COAs may apply only to specific approved installation types.
- NYC approval reviews focus on thermal runaway behavior, fire propagation, hazardous gases, and emergency response.
What is TM-2 for BESS in NYC?
TM-2 is the FDNY application form used to request a Certificate of Approval, or COA, for a battery energy storage system product in New York City.
For BESS, the TM-2 process begins with FDNY’s review of the energy storage product itself. After receiving a COA, individual installations must still proceed through applicable New York City Department of Buildings (DOB) review, FDNY plan review and inspections, utility interconnection approval, and operating-permit requirements before operation.
A commercial search for “TM-2 approved BESS” usually points to a BESS product with an FDNY Certificate of Approval. The precise phrase is FDNY COA-approved BESS because TM-2 is the filing form and the COA is the approval.
TM-2: The FDNY Application Form
A TM-2 application starts FDNY’s product-level review. The application is filed through FDNY Business and is generally submitted by the battery unit manufacturer or an authorized agent.
For energy storage systems, the application type is Certificate of Approval. A TM-2 submission typically includes:
- Manufacturer information
- Product name
- Model numbers
- Intended use and installation scope
- Applicable testing standards and reports
- Supporting technical documentation
COA: The Approval Outcome
A Certificate of Approval is the document FDNY issues when a product meets applicable NYC requirements. For BESS, a Citywide COA authorizes the product for use throughout New York City. The certificate also defines the approved installation categories, capacity limits, conditions of use, and expiration date.
A COA applies to the product and its approved scope. It gives FDNY a documented product-level safety record before a project reaches detailed site review. Site-specific review remains a separate part of the NYC permitting process.
TM-1: Site-Specific Installation Review
TM-1 is a separate FDNY engineering application used for site-specific plan review where required. While TM-2 focuses on product approval, TM-1 applies to the installation of that product at a specific project site.
A product can have a COA and still require DOB review, FDNY site filings, fire alarm and fire protection review, inspections, utility interconnection approval, and operating permits before it can be placed into service.
What FDNY Reviews in a TM-2 BESS Submission
A strong TM-2 submission is a technical evidence package that demonstrates how the BESS was tested, how it performs under abnormal conditions, what safety systems are built into the product, and where it can be installed.
FDNY’s review typically focuses on:
- Product Listings and Test Reports: Nationally Recognized Testing Laboratory (NRTL) reports demonstrating compliance with key standards such as UL 9540, UL 1973, and UL 1741. Documentation should align with product literature, model numbers, capacity ratings, manuals, and the requested installation scope.
- UL 9540A Fire Propagation Data: Test results showing how the system behaves during thermal runaway events. FDNY uses this information to evaluate fire propagation behavior, mitigation measures, installation limitations, and approved deployment categories.
- Hazard Mitigation Analysis (HMA): An engineering assessment prepared by a New York State Registered Architect or Professional Engineer that identifies potential hazards and explains how the product’s design, monitoring, containment, and operating procedures address them.
- Manuals, SDS, and Monitoring Documentation: Installation manuals, operating manuals, Safety Data Sheets, emergency response plans, and remote monitoring information. FDNY reviews how the system is monitored, how abnormal conditions are escalated, and what information is available to operators and first responders.
FDNY COA Installation Types for NYC BESS
A BESS COA has a defined scope that specifies where a product may be installed. A product may be approved for certain installation types and excluded from others, making installation scope one of the most important details in the COA record.
Approved Installation Categories
FDNY’s public ESS COA list organizes approved products by installation categories. These include:
- Outdoor Ground, except Group R-3 Occupancy
- Outdoor Ground, Group R-3 Occupancy
- Outdoor Rooftop, except Group R-3 Occupancy
- Indoor, except Group R-3 Occupancy
- Group R-3 Occupancy, Outdoor/Rooftop/Garage
These categories exist because different installation environments present different safety considerations. Outdoor ground installations raise different access, exposure, and separation questions than rooftop, indoor, or residential installations.
What Group R-3 Means
Group R-3 generally refers to one- and two-family residential occupancy. FDNY separates Group R-3 from other installation categories because residential BESS installations are evaluated differently than commercial, industrial, utility-scale, and other non-residential deployments.
Group R-3 can affect how a product’s COA may be used and whether certain inspection, permitting, or operating requirements apply.
How to Read a BESS COA
A COA should be reviewed for the approved product, model, capacity, expiration date, and installation type. A product approved for outdoor ground installation should be described that way unless the COA expressly supports indoor, rooftop, or Group R-3 use.
NYC space constraints often push BESS siting toward rooftops, parking structures, indoor utility rooms, or constrained commercial sites. Those settings may present different safety and permitting challenges than a standard outdoor-ground deployment.
What Happens After a BESS Product Receives a COA?
A Certificate of Approval allows a BESS to enter the next stage of the NYC approval pathway. Site-specific approval determines whether a project can be constructed and operated.
After a product receives a COA, project teams typically move through the following stages:
- DOB and OTCR Review: The New York City DOB reviews the proposed installation, including system layout, fire protection measures, ventilation, structural support, electrical design, commissioning plans, and other site-specific considerations. DOB’s Office of Technical Certification and Research (OTCR) may also conduct material evaluations.
- FDNY Filings and Inspections: Depending on the installation, FDNY may require TM-1 filings, fire alarm review, gas detection review, suppression system review, inspections, and additional approvals related to rooftop access, fire apparatus access, or extinguishing systems.
- Operating Permits and Utility Interconnection: Before a system can be placed into service, project teams may need FDNY operating permits, emergency shutdown testing, remote monitoring documentation, and utility interconnection approval. Con Edison review remains separate from FDNY and DOB approvals.
Why Safety Architecture Matters for NYC BESS Approval
FDNY review focuses on evidence. The strongest product safety case shows how the BESS prevents ignition, controls thermal propagation, addresses hazardous off-gases, supports emergency shutdown, enables remote monitoring, and gives first responders clear information.
Thermal Runaway Prevention
Thermal runaway prevention starts with temperature control at the cell level. LiquidShield™ immersion cooling submerges battery cells in a dielectric, high fire-point liquid that maintains uniform cell temperatures, reduces the likelihood of thermal runaway, and prevents ignition.
Uniform thermal control also slows degradation, protects usable capacity, and supports long-term system performance. For NYC projects, reliable performance is especially important because space constraints, permitting requirements, and project economics leave little room for underperforming assets.
Hazardous Off-Gas Neutralization
BESS safety must address gases released during thermal runaway events. HazGuard contains hazardous off-gases inside the sealed module architecture, routes them through the system, and neutralizes them before safe exhaust.
That capability supports emergency readiness by addressing toxic gas hazards at the source. In a dense city environment, off-gas behavior affects siting confidence, first-responder planning, and the strength of the overall safety case.
First Responder and Siting Readiness
Clear emergency procedures are an important part of BESS safety. Remote monitoring, emergency shutdown capabilities, signage, system status information, and subject-matter expert contact paths support NYC review, inspection, and first-responder preparedness.
Safety architecture also influences where a system can be deployed. A BESS designed around thermal runaway prevention, ignition prevention, hazardous gas neutralization, and documented emergency response procedures aligns with the risks FDNY evaluates in urban installations.
EticaAG’s NYC TM-2 / COA Pathway
A fire-safe BESS architecture should support the evidence package FDNY reviews. EticaAG is in the process of applying for FDNY Certificate of Approval through the TM-2 pathway for its battery energy storage systems. The company is pursuing a broad approval envelope across NYC installation types, supported by LiquidShield™ immersion cooling, high fire-point dielectric liquid, and HazGuard hazardous off-gas neutralization.
Final approved installation categories will depend on FDNY review. EticaAG is building the TM-2 package around the evidence NYC authorities evaluate: UL testing, thermal runaway prevention, fire propagation control, off-gas neutralization, remote monitoring, emergency shutdown, and first-responder readiness.
NYC project teams can join the EticaAG NYC TM-2 project list to receive COA updates and reserve capacity for the first New York City BESS deployments.
TM-2 for NYC BESS Quiz
Test your understanding of FDNY COA requirements, UL 9540A, installation categories, and site-specific approval steps for BESS in New York City.
Frequently Asked Questions
What is TM-2 for battery energy storage systems in NYC?
TM-2 is the FDNY application form used to request a Certificate of Approval for a BESS product in New York City. It starts FDNY’s product-level review of the energy storage system. The approval outcome is the COA.
Is TM-2 the same as a Certificate of Approval?
TM-2 and Certificate of Approval refer to different parts of the FDNY process. TM-2 is the application form. The Certificate of Approval, or COA, is the FDNY approval outcome.
Does every BESS product need an FDNY COA in New York City?
FDNY guidance states that battery ESS for stationary installations and mobile systems require product-specific approval from FDNY. The 2025 FDNY guide notes a narrow exception for stationary ESS with an individual size of 2 kWh or less for outdoor use. Project teams should confirm current requirements with FDNY before relying on any exception.
What documents are required for a TM-2 BESS application?
A TM-2 BESS application typically requires NRTL reports, UL 1741, UL 1973, UL 9540, a full-scale UL 9540A report, a Hazard Mitigation Analysis, manuals, SDS, emergency management documentation, capacity information, installation-type notation, and remote monitoring details. FDNY may request additional information based on the product’s design, chemistry, or safety features.
Why does UL 9540A matter for NYC BESS approval?
UL 9540A provides test data on thermal runaway fire propagation. FDNY can use that data to evaluate fire behavior, gas hazards, mitigation measures, and installation conditions. It is one of the central evidence sources in a BESS COA review.
Does an FDNY COA approve a BESS installation site?
An FDNY COA approves the product within the scope stated in the approval. Site-specific DOB review, FDNY filings, fire alarm or suppression approvals, Con Edison interconnection, inspections, and operating permits may still apply.
