From: Gregory Dagget
To: Meredith Matthews; Stacy Atkins-Salazar; Alex Stillman; Kimberley White; Sarah Schaefer; Tabatha Miller; David Loya; Rhea Varley; Merritt Perry; Engineering Dept; Emily Sinkhorn; Jennifer Dart; Delo Freitas Subject: a. Consider Recommendations for Amendments to the Land Use Code Consistent With General Plan 2045 Date: Monday, June 8, 2026 10:49:33 AM
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To: Arcata City Council Re: Amendments to the Land Use Code Consistent with General Plan 2045 – Need to Incorporate NFPA 1710 Standards for Mid‑Rise and High‑Rise Structures Special City Council Meeting – Study Session, June 8, 2026 Honorable Mayor and Council members and City leadership, As you consider amendments to the Land Use Code to bring it into alignment with General Plan 2045, I urge you to explicitly incorporate National Fire Protection Association (NFPA) 1710 standards for all mid‑rise and high‑rise structures. These standards are not aspirational, optional, or discretionary. They are the nationally recognized minimums for safe, timely, and effective fire suppression and rescue operations in multi‑story buildings.
NFPA 1710 Requirements Relevant to Mid‑Rise and High‑Rise Development
For high‑rise structures, NFPA 1710 requires:
First-arriving unit within 4 minutes travel time, and
Full Effective Response Force (ERF) of 43 firefighters within 8 minutes travel time.
These thresholds reflect the operational realities of vertical firefighting: extended hose stretches, stairwell operations, multi‑floor search and rescue, ventilation challenges, and the need for rapid deployment of a full complement of personnel to prevent flashover, structural compromise, and loss of life. NFPA 1710 is designed around the physics of fire growth and the time‑sensitive nature of survivability in enclosed, elevated environments.
Regional Capacity Does Not Meet These Standards
At present, no fire agency in Humboldt County—including the Arcata Fire District—can deliver a 43‑person ERF within 8 minutes to any location in Arcata. The District staffs six firefighters on duty across three stations and does not possess a ladder truck. Mutual aid, while valuable, cannot meet NFPA 1710 time requirements even under ideal conditions.
During a regional emergency, earthquake, or wildfire smoke event, mutual aid may not be available at all.
This is not a theoretical concern. The January 2, 2026 downtown Arcata fire required every available fire agency in Humboldt County, including units from as far away as Weott. That response—while heroic—took far longer than NFPA 1710 allows, and it occurred in a low‑rise environment. A similar incident in a mid‑rise or high‑rise building would exceed local and regional capacity.
Why NFPA 1710 Must Be Embedded in the Land Use Code
General Plan 2045 anticipates increased density, mixed‑use development, and taller structures.
However, land use authority carries a corresponding obligation to ensure that public safety infrastructure is capable of supporting the development it authorizes. Without NFPA 1710 compliance, the City risks:
Approving buildings that cannot be safely protected
Creating unmitigated life‑safety hazards for residents and first responders Violating the General Plan’s Safety Element and CEQA requirements for feasible mitigation
Increasing long‑term liability exposure for the City
Embedding NFPA 1710 into the Land Use Code ensures that fire protection capacity is treated as a hard constraint, not an after‑the‑fact consideration.
Requested Action
I respectfully request that the Council direct staff to:
1. Add explicit NFPA 1710 compliance requirements for all mid‑rise and high‑rise structures in the Land Use Code amendments associated with General Plan 2045.
2. Require that any project exceeding three stories demonstrate—before approval—that the Arcata Fire District can meet NFPA 1710 travel‑time and staffing requirements without reliance on delayed or uncertain mutual aid.
3. Require that any proposed increase in allowable building height be accompanied by a funded, implementable fire‑service capacity plan, including staffing, apparatus, facilities, and sustainable revenue sources.
Until the City and the Arcata Fire District can meet NFPA 1710 standards, it is neither safe nor responsible to authorize development that assumes a level of emergency response capacity that does not exist.
Thank you for your attention to this critical matter and for your continued work to ensure that Arcata’s planning decisions are grounded in real‑world safety conditions.
Sincerely, Gregory Daggett Arcata, California