On September 9th, NYSEIA submitted comments in response to the New York City Department of Buildings (DOB) proposed rulemaking on penalties for incomplete inspections. 

NYSEIA understands the concerns that led to this proposal, as contractors who miss inspection appointments repeatedly or unready job sites create unnecessary burdens on Department staff and delay inspections for other applicants. At the same time, NYSEIA members have experienced inspections that could not be completed due to various issues, especially due to circumstances outside the contractor’s control. We believe the proposal could be strengthened with several targeted revisions that improve fairness, transparency, and consistency while preserving DOB’s ability to discourage avoidable incomplete inspections. 

NYSEIA recommends the following revisions to DOB for the proposed rule:

• Distinguish between contractor-caused and non-contractor-caused incomplete inspections: where the permit holder is not responsible for the inspection’s failure to proceed

• Explore a scheduling process that provides greater opportunity for applicants to confirm availability before inspection dates are set

• Reconsider the proposed treatment of cancellations made fewer than three business days before a scheduled inspections, and allow cancellations up to 24 hours before scheduled inspections

• Establish clear and consistent standards for incomplete inspections

• Strengthen the transparency and challenge process by documenting the basis for any incomplete inspection determination and establishing a timeframe for resolving challenges

• Inspections subject to timely filed challenges should remain eligible for rescheduling while the challenge is under review

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