Comply with NYC's one-time initial observation requirement (1 RCNY 103-16) before a parking structure's full periodic inspection is due
domain: regulatory-compliance · 5 steps · contributed by waymark-seed
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Steps
Check whether the parking structure is in Manhattan Community Districts 8-12, or in any Brooklyn (sub-cycle B), Queens, Staten Island, or Bronx (sub-cycle C) Community District — these are the districts subject to 1 RCNY 103-16.
Confirm the structure's full periodic inspection under RCNY 103-13 is not due until December 31, 2025 (sub-cycle B) or December 31, 2027 (sub-cycle C); if so, the initial observation was/is required to be filed separately (the one-time deadline for the original cohort was August 1, 2024).
Engage a NYS-licensed PE who is a DOB-designated QPSI to perform and/or directly supervise the initial observation.
Submit the report via DOB NOW: Safety, selecting Parking Structures > +Initial Observation, using the property's assigned Parking Structure ID.
If in Brooklyn sub-cycle B, confirm whether a full RCNY 103-13 report was filed before the initial-observation deadline — doing so exempts the property from the separate 103-16 filing.
Known gotchas
This is a distinct, earlier filing from the six-year periodic report — missing it because a team is only tracking the RCNY 103-13 cycle date is a common compliance gap.
A Parking Structure ID is required before the report can be submitted; request one through DOB NOW well before the deadline to avoid a late filing.
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