Colin Fiske – January 9, 2023

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    Editor’s Note:  I typically do not comment on letters. But Colin Fiske, in his letters, often plays loose with the facts, and it is not fair to the people of Arcata to not point this out. In this case, he has presented his letter prior to the actual presentation that he is referring to. The PowerPoint slides for the presentation are in the meeting agenda packet. What was said at the presentation explained many of Mr. Fiske’s points in his letter.
     
    The Arcata Fire District does not propose a ban on buildings higher than 40 feet — only that such buildings should not be approved or constructed until such time as the AFD is capable of providing fire protection for them.
     
    Mr. Fiske writes: “First, the presentation admits that there are no legal or professional firefighting standards for 4‐8 story “mid‐rise” buildings, only for taller high‐rises, but despite this says that AFD will “treat the Gateway mid‐rise buildings equivalent to high‐rise buildings for response staffing.” It is unclear to us why Arcata should treat its mid‐rise buildings differently than the rest of the state or the country for fire‐fighting purposes.”
     
    Why do they choose to treat mid-rise buildings as equivalent to high-rise buildings? Because of their many years of experience as professional firefighters. And unless Mr. Fiske can claim to have equal firefighting experience, I suggest he stay out of this argument. As to what other cities in the state do — Yes, what do they do? It takes a lot of firefighting staff to fight a fire on a building taller than 40 feet. Maybe the minimum number of firefighters should be 35; maybe it should be 38, or 42. Whatever number it is, it is far more than the AFD and its mutual-aid firefighters can provide on a practical basis, in a timely manner.
     
    But how about this: The requirements for response time to a fire. The National Fire Protection Association is looking for an eight to ten minute response time, to have all personnel there. This is what the AFD Director, Eric Loudenslager, spoke to as his point. His slide shows 25 staff needed for a 3-story building, and 38 for a 7- or 8-story building. And it shows:  “AFD cannot meet these fire response deployment even with Mutual-aid.”
     
    Anything over 8 minutes is going to be a problem. That is Eric’s point. The ladder truck would be coming from Eureka. Firefighters would be coming from Eureka, McKinleyville, Blue Lake, Westhaven, Fieldbrook, Samoa, Fortuna, and Rio Dell.  Eric’s presentation also brought up the potential issue: If there is another emergency in those localities, those firefighters will not be available to come to Arcata. If there is a slowdown or accident on Highway 101, that will be a problem. Currently there is only one ladder truck in the County — if that were to be in use, it would be a problem. If a Westhaven FD firefighter is in Arcata or Eureka, he or she has to drive back to Westhaven for the equipment and truck. That takes time. If the emergency in Arcata were to be the result of an earthquake or other area-wide disaster, it would be a big problem.
     
    The National Fire Protection Association has requirements for staffing for buildings over 75 feet — 42 firefighters present — and that would be a 7- or 8-story building.  It has requirements for staffing for a “garden-style apartment” of three stories. That would be 27 or 28 firefighters present. So Colin is correct, on that one small point:  There is no nationally recognized staffing requirement for a four to six story building.
     
    We can also note that this need for an eight-to-ten minute response time is not so that the building can be saved. It is so that the building can be evacuated.  We are talking about saving people’s lives.
     
    Colin wrote:  “In other words, AFD’s presentation seems to imply that it could not currently respond effectively to a fire at the Jacoby Storehouse, or Sorrel Place, or the university’s BSS building. If that’s true, we’ve got to solve this problem now, not in the future.
     
    Yes. This means that we do need to solve this problem immediately. As was said, we’re pretty much relying on good fortune for those buildings. “We’ve basically been lucky,” Eric said.
     
    And: “Which means it won’t be a limitation by the time any new development could take place in the Gateway Area.”
     
    That is what we hope. But as Eric said, we cannot approve any construction above 40 feet until this is in place. The current lack of adequate fire protection doesn’t mean that we cannot plan for taller buildings in the Gateway Plan. It only means that they cannot be approved until the AFD can provide fire and emergency services.
     
    Colin wrote: “In fact, Gateway development would help pay for the increased service needed to protect Arcata’s existing mid‐rise buildings.”
     
    To which I say:  View the presentation, and do the math. There is no way that the development will pay for very much at all. The increase in property taxes — even with a large build-out — will amount to less than 5% of what the AFD will need. There could be a special assessment district for specific funding, but, again, they would amount to a just one percent or so of what is needed. The AFD needs permanent funding for annual expenses — expenses that would add to the rental cost that the tenant would pay. Funding for the level of fire protection that the AFD would require would need to come from another source. My hope is that the funds will come from the State, as to raise this money from the community would be a burden on rent prices and prohibitive to development.
     
     Colin, you likely watched the AFD presentation at the Planning Commission meeting, after you wrote your letter. You may have new information that would have you modify the views you’ve expressed. 
     
    Colin, or anyone: We all have opinions, and they are welcome. But to make assertions, it’s good to be backed up by reality and facts.
     
     

     
     

     

    Note:  What is shown below is a copy of the original letter, made for this website.  It is included here only so that the contents of the original letter can be searchable.  (The PDF received from the City is in the form of an image, and so is not a searchable document.)

    What is below is not the letter sent by the letter-writer. It will contain typographical errors and other departures from the original.  The PDF displayed above is accurate.  The text below is not accurate.  It is printed here for indexing purposes, so that each word can be indexed and included in the search.


    Commissioners,
    I am writing on behalf of CRTP to provide comments on several items on tomorrow’s agenda.
    Arcata Fire District Presentation
    In the presentation included in your agenda packet, the Arcata Fire District argues that it does not have the capacity to serve future 4‐8 story buildings in the Gateway area, and that building heights should therefore be limited to less than 40 feet -‐ which in most cases will mean 3 stories or less. This is problematic for multiple reasons.

    First, the presentation admits that there are no legal or professional firefighting standards for 4‐8 story “mid‐rise” buildings, only for taller high‐rises, but despite this says that AFD will “treat the Gateway mid‐rise buildings equivalent to high‐rise buildings for response staffing.” It is unclear to us why Arcata should treat its mid‐rise buildings differently than
    the rest of the state or the country for fire‐fighting purposes.
    Second, and of greater concern, mid‐rise buildings are not just a future possibility ‐ Arcata already has a number of buildings which are 4 stories or taller, and will soon have 7‐story buildings developed by Cal Poly Humboldt at the Craftsman Mall site. If AFD can’t serve buildings which are 4 or more stories tall, that is an urgent problem. In other
    words, AFD’s presentation seems to imply that it could not currently respond effectively to a fire at the Jacoby Storehouse, or Sorrel Place, or the university’s BSS building. If that’s true, we’ve got to solve this problem now, not in the future. Which means it won’t be a limitation by the time any new development could take place in the Gateway Area. In
    fact, Gateway development would help pay for the increased service needed to protect Arcata’s existing mid‐rise buildings.
    Gateway Community Benefits
    We appreciate and agree with most of the types of community benefits being considered by the Commission for
    inclusion in the Gateway Area Plan’s community benefits program. We particularly appreciate the fact that almost every
    Commissioner has ranked transportation and mobility benefits high on their lists of priorities.
    We also agree with most of the specific benefits being considered under the transportation category, with one
    significant exception: Underground parking should not be considered a community benefit. Parking of any kind benefits
    only the user, not the broader community, and in fact incentivizes excess driving with all of its safety, health and
    environmental impacts. Underground parking is also extremely expensive to build, and a landowner or developer with a
    limited community benefits budget could likely provide a complete package of every other transportation benefit for
    less than it would cost to build a single sub‐surface parking structure. Please remove underground parking from your list
    of eligible community benefits.
    2
    We also encourage you to rank bike parking/storage and showers for bike commuters higher on your list of priorities.
    Both are proven methods to increase biking, and also increase equity by providing needed support for those who bike
    out of economic necessity.
    Draft General Plan Land Use Element
    We appreciate and support the increased focus of the draft Growth Management and Land Use Elements on walkable,
    transit‐oriented infill development. We submit the following specific comments:
     Policy LU‐1c calls for reducing or eliminating parking mandates in walkable areas near transit. We appreciate this direction, but we call on you to go further and eliminate all parking mandates citywide. Parking may still be provided by developers, but there is no reason for the city to require it. As this map shows, cities large and small across the country are acknowledging the high costs of parking mandates and eliminating or severely restricting them. Now is Arcata’s chance to follow suit.
     Policy LU‐1e calls for “maintaining an appropriate balance” among housing types. It is unclear to us what this means, but it is clear that the current housing stock is out of balance. Most of the city’s land is zoned for single‐family homes only; “maintaining” this current balance would limit much‐needed alternative and multifamily housing development.
     The objective stated in Policy LU‐2 calls for new housing to be “compatible with established neighborhood character.” This creates a major obstacle to change, and change is needed if we are to provide sufficient housing in walkable, transit‐oriented neighborhoods. It also may run afoul of the state’s requirement that local rules
    about housing follow clear and objective standards.
     Policy LU‐4h prohibits petroleum production in Arcata, which is great, but includes some old language in support of petroleum extraction generally. This strikes the wrong note in our modern understanding of impending climate chaos.

    Thank you for your consideration of our comments.
    ‐‐
    Colin Fiske (he/him)
    Executive Director
    Coalition for Responsible Transportation Priorities
    www.transportationpriorities.org