FDNY’s Approved Energy Storage List Shows Five of Twenty Certificates Expired or Awaiting Renewal
Twenty Certificates of Approval appear on the FDNY Bureau of Fire Prevention’s roster of energy storage systems current as of September 2026. Five of them carry a date that has already passed.
Three are flagged expired. Tesla’s Megapack 2 lapsed November 8, 2025. Sungrow’s PowerTitan lapsed April 17, 2026. Fluence’s Gen 6 Cube lapsed September 5, 2026.
Two more are flagged “COA Renewal Pending.” Both belong to SimpliPhi, against expiration dates of May 5, 2025 and May 30, 2025. Those certificates have carried pending status for roughly seventeen months.
The list. Certificate numbers run from 8000 through 8019. Each product is classified by size under 3 RCNY 608-01. One further date sits close to the present: LS Energy Solutions’ Schneider Electric BESS 250Q expires November 19, 2026.
One manufacturer holds the small end. SimpliPhi’s 19 kWh A-XPHI-SA is classified Small under certificate 8002. Four AccESS Sol-Ark 12k models at 136.8 kWh each are classified Medium under certificate 8003. Every other entry on the roster is Large or Medium-Large. The entire approved population below the Medium-Large threshold, in other words, consists of five model numbers from one vendor, both of whose certificates are awaiting renewal.
The size classes. Each entry is sorted into a size class defined by 3 RCNY 608-01, the FDNY rule governing stationary storage battery systems. The September 2026 list applies four labels: Small, Medium, Medium-Large and Large. The rule FDNY publishes at its codes address is titled “Outdoor Stationary Storage Battery Systems.”
The same list carries an “Approved Installation Types” column. Its entries span outdoor ground, outdoor rooftop, indoor, and Group R-3 occupancy, which means the roster already contemplates placement inside buildings even though the classification scheme it uses comes from a rule whose title describes outdoor installations.
Who holds the certificate. Equipment approval sits with the manufacturer, under the process set out in FDNY’s ESS equipment approval and installation guide. Installation approval is a separate filing. A building owner therefore depends on a certificate held by someone else, renewed on a calendar the owner does not control, and the roster FDNY publishes is the artifact a plan examiner checks.
What the expiration dates imply. Read as an operating document, the list indicates that New York City market access for a storage manufacturer is a renewable license with an administrative cadence attached. Certificates carry hard expiration dates, and three products on the current roster have already passed theirs. Two more have sat in renewal limbo since May 2025, a gap long enough to suggest that renewal is a cost line manufacturers discover rather than plan for.
The consequence falls on the project rather than the vendor. An owner specifying a product whose certificate lapses between design and permit has a filing problem that no amount of laboratory testing resolves, because the certificate is the document the city publishes and the document the reviewer consults. Certificate maintenance is therefore an operating cost in the five boroughs, carried on a schedule the equipment purchaser cannot influence.
Size is the second reading. The approved population is dominated by equipment sized for yards, rooftops and dedicated outbuildings: every certificate except two falls in the Large or Medium-Large classes. The band that fits a mechanical room or a back-of-house corridor in an existing commercial building holds one manufacturer, five model numbers, and two certificates in renewal limbo.
That matters beyond New York because the city combines the strictest permitting regime for building-sited batteries in the United States with the densest concentration of buildings that would benefit from them. Interest in the question is not confined to the fire service. The Urban Land Institute’s Impact Lab and UL Standards & Engagement spent a year interviewing commercial real estate practitioners across 13 projects about on-site storage, and the resulting research, presented October 28 at ULI’s Fall Meeting, names safety standards and demand charges as the governing variables. A companion Greenbuild session lists the same pair alongside underwriting and investor expectations.
The institutional vocabulary for evaluating on-site batteries is being written by owners and standards bodies at the same moment that the city with the most demanding approval process publishes a list showing how few products have cleared it at small scale. Local policy is moving in parallel and not always in the same direction: North Elba, New York, froze construction, installation and review of any battery storage project town-wide on October 20 with no capacity floor in the text, while Iberville Parish, Louisiana, narrowed its own moratorium on September 22 to exempt systems under 1 MW used for on-site backup. The drafting language, rather than the count of moratoriums, determines whether building-sited equipment is caught.
New York City’s published list of approved energy storage equipment runs twenty lines. The smallest entry on it is 19 kilowatt-hours, and that entry, along with every other approval below the Medium-Large class, belongs to a single manufacturer whose paperwork expired in May 2025.
Sources
- Certificate of Approval List: Energy Storage Systems, September 2026 (FDNY Bureau of Fire Prevention)
- 3 RCNY 608-01, “Outdoor Stationary Storage Battery Systems” (New York City Fire Department)
- ESS Equipment Approval and Installation Guide (FDNY)
- How ULI’s Impact Lab Helps Commercial Real Estate Navigate On-Site Energy Storage (Urban Land Magazine)
- Bytes, Batteries, and Blocks: Three New Reports from ULI’s Impact Lab (ULI Fall Meeting)
- North Elba Freezes Battery Storage Projects for a Year (Hoodline)
- Council Narrows BESS Moratorium to Exempt Small Backup Systems Under 1 MW (Citizen Portal)