A map of areas covered by Fire District 1 in central LA. Source.
This weekend I was asked to speak to the Neighborhood Council Sustainability Alliance about the proposal to expand Fire District 1, and I threw together some notes that I’m sharing here for anyone interested in using them for their own advocacy. These are not edited to the degree of a normal blog post, so apologies for any mistakes or excessive brevity. Feel free to comment or send me an email if anything is unclear or if you’d like anything clarified. Thanks!
First, I want to be clear that I'm not an expert on building codes or fire safety. My understanding of these issues is informed by conversations with experts, but my knowledge is of a more general sort, so my comments will mostly be in that vein. What I do know for sure is that the people who write the International Building Code (IBC), on which state and local codes are based... they are not messing around. They take their work very, very seriously. There may be somewhat different benefits to different materials and types of construction, but none of the options in the IBC are unsafe. Fire District 1 prohibits certain types of construction — types approved in the International Building Code — based on location-specific characteristics of denser neighborhoods. I want to emphasize this point that the expansion of Fire District 1 would be limited to the denser and more central parts of the city, which will be important later.
Second, I want to state plainly that this is first and foremost a campaign by the concrete industry. Councilmember Blumenfield picked it up and has defended it on his own, and I'm not here to question the motives of him or any other city official, but there's no question that the main proponent of this proposal is the concrete industry. If certain types of wood construction aren't allowed in the places where most housing is being built, or wood construction is made more expensive, then concrete suppliers are the biggest beneficiaries of that, as well as steel suppliers to a lesser extent. So while I think we shouldn't dismiss the arguments in favor of expanding Fire District 1 simply because of who's backing them, we should keep those motivations in mind.
For those who haven't been following this proposal, Fire District 1 is a regulatory overlay in the city of LA that prohibits type IV and type V construction. There are five construction types, I through V, with one being the most restrictive and expensive and V the least. Types I and II require the use of concrete or steel, while types III through V all involve the use of different types of wood. Fire District 1 currently covers all of Downtown Los Angeles, parts of Hollywood, and a few other areas. It covers a small geographic area but an area that includes a very large share of the housing being built in the city. Type IV and V construction are the least restrictive construction types, but I want to reiterate that this doesn't mean that buildings built with these types are in any way unsafe.
Because the higher number construction types are less restrictive, the buildings you can build using them are not as large or tall. For Type IV it's generally only up to 5 stories, though you can put them on a concrete podium to add a few more stories, and for Type V it's only up to 4 stories. Especially for Type V construction, this is how you can build three- and four-story missing middle housing without breaking the bank. If you have to use Type 1, 2, or 3 construction then your costs are going to go way up, which means fewer homes are financially feasible to build and the ones that are built have to rent or sell for more — or in the case of subsidized housing, we have to spend more public funds to build each unit. In their report to council, city staff estimate that shifting development from Types IV or V to the more expensive types would increase the cost of construction and materials between 10 and 50 percent.
Since I'm talking to the sustainability council, I want to make clear that expanding Fire District 1 would unquestionably have negative environmental impacts. The biggest impact would be fewer homes built overall, including in the most transit-accessible neighborhoods in LA. Since failing to build homes doesn't cause people who would live in them to no longer exist, it means more homes will be built in other parts of the country, almost all of which have higher car-dependency, water and energy consumption, and greenhouse gas emissions than us. The other major impact is more direct: to the extent that some development shifts from wood-frame to concrete or steel for its structural materials, that's going to increase emissions by a lot. By its nature, wood captures carbon in its production, whereas the production of concrete and steel requires immense greenhouse emissions. I'll also note that mass timber, including cross-laminated timber and other materials approved in the 2021 edition of the International Building Code, are a version of Type IV construction and are therefore banned in areas covered by Fire District 1.
While all this sounds pretty bad, I want to acknowledge that it could still all be worthwhile if Fire District 1 were addressing a real fire/life-safety issue. It's not. If we go back to the original motion, the first seven paragraphs are all about wildfires and risks to homes built in the hills and wildland-urban interface. That's a very real concern. But then in the 8th paragraph it starts talking about the need to protect new multifamily housing, without explaining the connection between wildfires and the multifamily development coming online in the city. That omission is really important because the places where wildfires are occurring and the places where dense multifamily housing are being built are essentially mutually exclusive. Throughout this entire process, no one has persuasively articulated what safety problem the expansion of Fire District 1 would address. It's my view that that's because it doesn’t address a real safety problem. They're proposing to expand FD1 to cover a larger share of the city, and they're proposing to do so in exactly the locations where life-threatening fires — especially wildfires — are least likely to occur.
The Da Vinci fire is sometimes referenced as a motivation for these reforms, but that's kind of perplexing because the Da Vinci building is located in Fire District 1. The Da Vinci fire was a big deal and it caused a lot of property damage, but expanding Fire District 1 would do absolutely nothing to prevent it from happening elsewhere. It’s also important to note that the Da Vinci fire occurred in a building that was currently under construction, not a completed building. There's a conversation we could have about whether it makes sense to strengthen our safety protocols and enforcement during construction, but that's not what this proposal has been focused on and certainly not what the concrete lobbyists are interested in.
The report produced by city staff has a few tells that I think are very important. First, they never say anywhere in the report whether this would improve the safety of Angelenos. As I said, I don't think that's accidental — there's not much you can say about the safety benefits of this proposal. Second, when staff researched the history of Fire District 1 they couldn't determine the exact reason it came into being, which is another way of saying that they can't really justify it's current existence either. In any case, it looks like the District is at least 100 years old, from an era where entire neighborhoods and cities burned down on a regular basis. That's not a modern problem and it hasn't been for quite a long time. Third, city staff looked at ten other California cities to compare their practices, and none of them have a fire district like ours. They say "None of the jurisdictions surveyed limit type of construction and maintain consistency with the minimum standards set forth in the California Building Code." We're the only ones doing this, and we don't even really know why. This is a proposal to expand a policy that we can't even justify in its current form.
I think that's just about all I wanted to say on this topic. To summarize, expanding Fire District 1 would increase the cost of new housing, especially less expensive missing middle housing types; it would increase emissions at both the human and the building level; and it wouldn't meaningfully improve safety. Not only should we not expand Fire District 1, we should abolish it entirely. At the very least, we should take this opportunity to reform it so that mass timber construction is explicitly permitted. The concrete industry has been all over this proposal, trying to use it to undermine their competition from wood suppliers, and I think it would be a fitting end to this saga if the result was only to expand the use of safe wood materials in the places where Fire District 1 currently prohibits them.