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What is Local Law 102 of 2020 in New York City- NYC?

2 engineers sit while flying a drone over solar panels

In 2020, the New York City Council passed Local Law 102 of 2020 (Local Law 102). Local Law 102 requires the New York City Department of Buildings (DOB) to study the use of unmanned aircraft systems, which are commonly referred to as drones, to conduct façade inspections in conjunction with hands on inspections. This report will:

• provide a Façade Inspection Safety Program (FISP) overview, which requires the façades of buildings greater than six stories in height to be inspected periodically

• provide an overview of existing drone technology and use

• provide an overview of existing regulations pertaining to drones

• explore the obstacles in using drones to conduct façade inspections, that include regulatory barriers and privacy concerns

• explore various aspects pertaining to using drones to conduct façade inspections, including whether drone use can improve safety, whether drone use could have an impact on the use of sidewalk sheds and scaffolding, and whether drone use could result in any economic benefits.

Key takeaways from this report include:

• Drones are a useful tool for collecting visual data. Drones are useful tools for collecting significant amounts of visual data such as photographs, videos, thermal images, and similar outputs. Drones can also access angles that are more difficult to achieve using other methods of visual inspection, which is particularly helpful for the inspection of larger buildings.

• Façade inspections require more than just visual images. For façade inspections, visual data collected by drones could include photographs and location information to easily pinpoint where a defect is located on a building. However, visual data, whether collected by drones or other tools, cannot replace the current requirement for physical examinations. Physical examinations by qualified professionals include sounding and probes that are necessary to accurately identify façade defects. Physical examinations also allow qualified professionals to immediately mitigate hazards.

• Façade inspections require more than just data collection to inform building maintenance and repairs. Drones can collect data efficiently, but the data needs to be reviewed and analyzed to inform decisions regarding building maintenance and repairs. In the case of required façade inspections, a qualified professional must review available data and determine how to address deficiencies. Data by itself, whether collected by drones or using other tools, does not translate into actionable façade repairs.

• Current regulations limit drone use in New York City. Current regulations limit drone use in New York City and are outside of DOB’s purview. Such regulations have resulted in limited experience with drone operations in the City, including to conduct façade inspections.

• There is a lack of data and experience with using drones to conduct façade inspections. There is limited experience with the use of drones to conduct façade inspections in New York City and in other jurisdictions, which makes it difficult to determine precisely how drone use might support the existing façade inspection requirement and to assess related issues that may arise, including privacy concerns, whether drones could have an impact on the use of sidewalk sheds and scaffolding, and whether drone use could result in any economic benefits.

DOB recognizes drones may support the existing requirement to conduct façade inspections in a beneficial way and would invite further study on how drone use, and its accompanying technologies, can be employed. Specifically, the following areas may benefit from further study:

• Time and costs. Whether drone operations reduce the time spent on collecting and reviewing façade conditions, and whether this lowers the cost of façade inspections for building owners. Also, whether repairs and remediation occur in a more expedited fashion if the use of drones allows for deficiencies to be more easily identified during required inspections.

• Types of deficiencies. What types of façade deficiencies are more easily identified using drone data. For example, cracks in masonry may be easier to determine than displacement or bulges from photographs or videos captured by drones.

• Additional or more targeted hands-on inspections. Whether additional hands-on inspections would be required because more areas of concerns can be identified by drones. Similarly, whether an inspector can better target which areas require hands-on inspections for more accurate examination of façade conditions.

• Frequency of drone inspections. Whether periodic use of drones can help to identify if movement or degradation has occurred as compared to previous inspections.

• Types of buildings. What type of building or building material would drone inspections be most beneficial for. For example, a building with a glass and steel façade may have readily identifiable deficiencies that can be captured by a drone, whereas a building with an ornate masonry façade would require close-up inspection to ensure that defects are not hidden in images. Also, whether drone use would be better for taller high-rise buildings, which may not have alternate means of access such as permanent window washing rigs, or smaller ones, which may not benefit from drone use due to scale.

• Other applications. Whether drones can be used in other applications: - Drones are sometimes deployed in emergency response and expanded use would be useful in more localized incidents such as building fires or explosions. - Drones could identify open roofs in a structurally compromised building without endangering DOB responders. - Drones equipped with thermal imaging cameras may be beneficial in improving the energy efficiency of façades and assist in retro-commissioning efforts.

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