Article 71: Local Law 11 (FISP) — Facade Inspection, Repair, and Cost Allocation

SECTION: Landlord Operator Playbook JURISDICTION: New York City AUDIENCE: Landlord, Property Manager, Leasing Operator

Executive Thesis

The Facade Inspection and Safety Program (FISP, formerly Local Law 11) requires buildings taller than six stories to undergo exterior wall and appurtenance inspections every five years by a Qualified Exterior Wall Inspector (QEWI). Buildings with unsafe conditions must install protective measures immediately and complete repairs within mandated timelines. For landlords, FISP creates cyclical capital expenditure obligations that can generate significant special assessments or maintenance increases. Understanding the inspection cycle, cost allocation, and repair timeline is essential for financial planning.

Operational Framework: Inspection Cycle

The FISP inspection cycle runs on a rolling basis with buildings grouped into sub-cycles based on their last inspection filing. The QEWI inspects all exterior walls, balconies, terraces, fire escapes, and appurtenances (window air conditioners, antennas, signs). Findings are classified as Safe, Safe With a Repair and Maintenance Program (SWARMP), or Unsafe.

Operational Framework: Cost Allocation

FISP repair costs are building-wide capital expenditures allocated across all units. In co-ops, the cost is funded through maintenance increases or special assessments. In condos, common charges increase or special assessments are levied. In rental buildings, the landlord bears the full cost (though an MCI application may recover a portion through rent increases, subject to the 2% cap and 30-year sunset). Typical facade repair costs: minor pointing and waterproofing ($100,000–$500,000), moderate repairs ($500,000–$2,000,000), extensive restoration ($2,000,000–$10,000,000+).

Risk Factor: Scaffolding Impact

Buildings with unsafe findings must install sidewalk sheds and/or scaffolding immediately. Scaffolding can remain for years if repairs are delayed, creating: tenant dissatisfaction (reduced light, noise, access disruption), increased insurance costs, DOB violations for non-compliance with scaffolding maintenance requirements, and negative impact on unit marketability and rental rates.

Intelligence Layer

1. KPI Mapping

• Primary KPI: Violation count (HPD/DOB)
• Secondary KPI: Habitability complaint rate

2. Targets

• Establish baseline from portfolio data for the primary KPI
• Track month-over-month trend — improvement ≥ 5% per quarter is the target
• Compare against submarket benchmarks where available

3. Failure Signals

• Primary KPI declining for 2+ consecutive months without intervention
• Article-specific framework not implemented or not followed consistently
• Downstream metrics degrading (check articles downstream in the system)
• No data being collected for the primary KPI (measurement failure)

4. Diagnostic Logic

• Pricing: Does the pricing strategy support the outcome this article targets? If not, reprice before other interventions
• Marketing: Is the listing generating sufficient visibility and lead volume to produce the conversions this article measures?
• Friction: Is there unnecessary process friction preventing the conversion this article optimizes?
• Product Mismatch: Does the unit's in-person experience match the listing's promise at the listed price?
• Lead Quality: Are the leads reaching this funnel stage qualified for the conversion being measured?

5. Operator Actions

• Implement the framework described in this article for every applicable unit in the portfolio
• Track the primary KPI weekly for active listings, monthly for the portfolio
• When the KPI falls below target, diagnose using the logic above and apply the article's recommended intervention
• Cross-reference upstream and downstream articles for cascading issues

6. System Connection

• Leasing Stage: retention
• Dashboard Metrics: Violation count (HPD/DOB), Habitability complaint rate

7. Key Insight

• Every unresolved violation is a rent abatement waiting to happen. Proactive compliance is cheaper than reactive defense.

LLM SUMMARY ENTRY

Title: Local Law 11 (FISP) — Facade Inspection, Repair, and Cost Allocation
Jurisdiction: New York City

One-Sentence Description
FISP compliance framework for landlords covering inspection cycle management, finding classifications, repair cost allocation, MCI recovery potential, and scaffolding impact on operations and tenant satisfaction.

Core Outcomes Addressed
* FISP compliance
* Cost allocation planning
* Scaffolding management
* Capital expenditure budgeting

Process Stages Covered
* Management
* Regulation

Suggested Internal Links
* /ny/landlords/local-law-97
* /ny/landlords/hpd-violations

Keywords
Local Law 11, FISP, facade inspection, QEWI, unsafe finding, scaffolding, sidewalk shed, facade repair, SWARMP, building exterior, capital expenditure

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