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Change in Procedure: Minor Plan Changes Now Require Post-Approval Amendments

How will this affect your projects?

As of March 15, 2021, you will need to submit a Post-Approval Amendment (PAA) for any minor plan change on an approved project.

While this change itself may seem minor, even small filing change-ups can cause issues and delays for the unprepared. This change may affect your project filing timelines and fees, so read ahead and plan wisely.

In BIS/eFiling

After March 15, solo AI-1 forms cannot be submitted post-approval in eFiling for minor changes, unless submitted as part of a PAA. Here’s how to approve minor changes:

  • Submit a Plan/Work Application (PW1) with an AI-1 Additional Information form, marking that the submission is part of a PAA and identifying/describing the plan changes in the “Comments” section.
  • Upload the new plans in eFiling and select “New PAA”.
  • Include the reason for the PAA in the “Comments” section and circle the information that has changed on the plans.

Once the PAA status is marked as “PAA Fee Due” in BISWeb, you can pay the fee in eFiling using the Express Cashier Payments module.

For professional certification jobs, upload a completed PW1 form that indicates “Okay for Approval” in eFiling and select “Approval for PAA”.

For resubmission of a standard plan review job, submit in eFiling as “Minor Plan Change/PAA”.

In DOB NOW

After March 15, DOB NOW’s help form will not accept solo AI-1 forms for jobs after approval. Here’s how to get minor plan changes recognized and approved:

  • Create a Post Approval Amendment (PAA) filing in DOB NOW by selecting the “PAA” action under the job filing in question.
  • Attach a full plan set and the AI-1 form within a single PDF.
    • Make the AI-1 the last page in the document, specifying that the submission is part of a PAA and identifying the plan changes.
  • Describe changes in the “Comments” section of the “Plans/Work” tab (PW1).

Also, keep in mind the following rules apply to PAA filings in DOB NOW: Build:

  • Only one PAA can be in progress at a time.
  • A PAA can only be filed by an Applicant of Record, and must be filed by the same Applicant of Record as the original filing.

Up until now, PAAs were required only for scope of work changes, as well as for Schedule A and certain Schedule B changes in BIS. Where before applicants could get away with simply submitting an AI-1 form in the event of minor post-approval changes that did not change any information on the PW1, they will now have to formally file a PAA.

Overall, your project may be assessed for additional fees, and if there are objections or if the project is non-professionally certified, it will likely require a Plan Examiner meeting.

Because of this, applicants should make sure to build in some extra time into the project schedule in case this comes up.

For more assistance with filing and code concerns, please reach out to us at Outsource Consultants.

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