Finger Lakes Building Officials, Inc.

An Affiliated Member of the New York State Building Officials Conference

June 17, 2003

RE: "Exterior surfaces"
RCNYS R317.1.1

This is in response to your question regarding Residential Code of New York State (RCNYS) section R317.1.1, requirements for the installation of smoke detectors in existing dwellings, exception 2 which states that repairs to the exterior surfaces of dwellings are exempt from the requirements of this section.
Specifically you ask if the following are considered "exterior surfaces"

replacement and installation of air conditioners
replacement of electrical services
replacement and installation of swimming pools and hot tubs
replacement and installation of exterior lights and plugs

It is our opinion that exterior surfaces refers to work done only to the outside (exterior) of the building, such as reroofing and residing and do not require going into the building. The work items listed above are not exempted by the phrase "exterior surface" because they are not on the exterior surface and they also require interior work such as electrical wiring.

This advisory opinion is rendered based upon the information provided. Administration and enforcement of the code are within the jurisdiction of the local authority. If you have questions regarding this advisory, please call me at (518) 474-4073.

Sincerely,
Cheryl A. Fischer, P.E.
Assistant Director for Code Interpretation
Codes Division
Al03-141

Finger Lakes Building Officials Association, Inc.
3100 Atlantic Ave.
Penfield, NY 14526