City Council
Report
City Council Meeting: September 9, 2025
Agenda Item: 11.C
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To: Mayor and City Council
From: Matthew Hallock, Fire Chief, Fire Department
Subject: Approval of Proposed Regulatory Updates to High-Rise Building Definitions and Single Stairway Multi-Family Building Provisions
Recommended Action
Staff recommends that the City Council:
1. Direct that as part of the City’s next regular building and fire code update process, staff align the City’s building and fire code definitions for high-rise buildings to be consistent with the Statewide high-rise definition as set forth in Health & Safety Code 13210(b).
2. Authorize staff to implement an updated Alternate Materials and Methods Request (AMMR) process for single-exit stairway multi-family residential buildings of up to six stories in height pursuant to the attached Information Bulletin (Attachment A).
Executive Summary
At our March 25, 2025 meeting, the City Council directed that staff assess and develop ways in which Santa Monica could adopt new building and fire code policies to modernize local regulations across the following two areas:
1. High-Rise Building Height Definition – Update the City’s definition of a highrise building to align with the Statewide definition as set forth in Health & Safety Code 13210(b).
2. Single Stairway Exit Regulations – Develop a new Alternate Materials & Methods Request (AMMR) in Satna Monica to facilitate the construction of single-stairwell multifamily unit residential buildings of up to six stories. 2 of 7
Since the 1970s, the City has adopted building code regulations that identify high-rise buildings as any structure that exceeds 55 feet in height. That local regulation exceeds the standards established by the State, which defines high-rise buildings as structures that exceed 75 feet in height. As staff has reviewed the proposed adjustment from a life-safety perspective, given enhancements that have been instituted in firefighting equipment, staffing levels, and a requirement Statewide for more robust building lifesafety systems – coupled with current plans being developed for an expansion of Fire Department facilities, apparatus, equipment, and personnel – staff believes that a transition of our local high-rise height regulations to be consistent with State standards is both reasonable and justified.
With regard to single stair buildings, the California Building Code generally restricts multifamily residential buildings with a single exit stairway to three stories. However, Section 104.2.3 of the California Building Code does allow local jurisdictions to facilitate an Alternate Materials and Methods Request (AMMR) to institute different building standards, provided that the proposed design meets the intent of the building code, and provides an equivalent level of life safety.
Based on City Council direction, staff has conducted an extensive review related to the issue of single exit stairway provisions for multifamily residential buildings of up to six stories, drawing on expertise from our building staff, fire prevention personnel, and industry best practices. Through those efforts, staff has developed a proposed Single Exit Stairway Informational Bulletin (Attachment A), which establishes local guidance, criteria, and review procedures for those seeking to develop single stair multifamily residential buildings of up to six stories. In particular, the proposed regulations outline enhanced safety related design requirements for single stair multi-family buildings of up to 6 stories – including enhanced sprinkler systems, limited travel distances from stairwell, stairway pressurization, direct discharge to public streets, enhanced stair widths, and mandatory peer review for taller projects – to ensure fire / life safety equivalency.
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Discussion
Update to High-Rise Definition
Based on the assessment conducted by staff, it would be viable to transition the City’s local building code regulations regarding high-rise height definitions to align with State standards. Such an adjustment would revise the local definition of high-rise buildings from 55 feet to 75 feet, which is aligning with the California Building Code and National Fire Protection Association (NFPA) standards.
Considerations analyzed by staff related to this proposed adjustment related to high-rise building definitions included the following key factors:
• Modern Firefighting Capacity: The Santa Monica Fire Department now has enhanced apparatus, equipment, and staffing compared to the 1970s, when the more restrictive high-rise definition was first instituted locally. Having assessed our current emergency response capacities, staff is confident in our ability to respond to buildings of less than 75 feet that are built with non-high-rise standards.
• Planned Fire Department Enhancements: In addition to our current emergency response capacities, there are current plans being developed to expand existing Fire Department facilities, apparatus, equipment, and personnel in a manner that addresses local Santa Monica risk factors to provide further ability to respond to buildings of less than 75 feet built to non-high-rise standards. • Improved Life Safety Standards: Buildings today are required to have enhanced life safety systems, beyond what was required back in the 1970s.
Modern code requirements now mandate taller buildings be equipped with enhanced sprinkler systems, smoke detection, and fire-resistant materials that significantly reduce risk.
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• Consistency with State Code: Aligning with the CBC definition ensures consistency and reduces regulatory conflicts for applicants and staff. • Appropriate Threshold: A 75-foot standard reflects contemporary high-rise operational definitions, focusing resources on truly tall buildings requiring specialized response.
Single Stairway Exit Regulations
After extensive review, staff has also developed a series of new regulations that attempt to create a clear regulatory framework for evaluating AMMRs for single-exit multifamily residential projects of up to six-stories. Key provisions identified in the City’s proposed regulations include:
• Buildings of up to 4 Stories: Enhanced building requirements include full NFPA 13 sprinklers, direct exit discharge, limited maximum floor areas, and required bedroom rescue openings.
• Buildings of 5–6 Stories: Additional requirements beyond those for a 4-story facility include limited units / floor, maximum floor areas, pressurized stairwells, reduced exit travel distances (20 feet), enhanced stair widths, a required peer review, and a prohibition of occupied roofs.
• Review Process: Any project seeking to construct a single stair multifamily building will have their applications subject to review and approval by the City’s Building & Safety Division and Fire Department, to confirm that the proposed building enhancements meet code equivalency requirements as outlined in the Information Bulletin developed.
• Statewide Consistency: The proposed Information Bulletin also facilitates future updates to our single stair regulations, based on anticipated State code amendments being analyzed by the California Legislature, along with the Office of the State Fire Marshal.
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Assuming adoption of the proposed enhanced building measures outlined in the Informational Bulletin, staff believes that the implementation of the single-stair regulation would be feasible and justifiable from a fire / safety perspective.
Also, if the proposed high-rise and single stair regulations are advanced by the City Council, staff has developed an implementation plan, which involves the following actions:
• When the next building and fire code updates are brought back for City Council approval (anticipated to take place in late September / early October 2025), staff will align our definition of high-rise buildings with State code standards. • The Single Stairway Exit Informational Bulletin will be finalized and issued to applicants, design professionals, and the development community. • Staff will continue to monitor State Fire Marshal activities and update local provisions to remain consistent with industry norms and standards.
Additional Life Safety Review
As an added layer of our analysis, Fire Department personnel performed an assessment of related fire activity during the past 10-year period. Per that assessment, staff reviewed the number of fires that have occurred in multi-level buildings on the 3rd floor and above, analyzed by floor and by fire spread.
Per that assessment, we had only ~5 total fires per year. Also of note, ~58% of the identified incidents occurred on the 3rd floor of the multi-story building. The full data set analysis is outlined in the table below.
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Environmental Review
The proposed policy updates are categorically exempt from the California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3) of the CEQA guidelines, which states that CEQA applies only to projects that have the potential for causing a significant effect on the environment. The proposed updates provide policy discussion on potential future building code updates that would establish an alternate process for single exist stairway multifamily residential buildings. Therefore, it can be seen with certainty that the proposed updates would not result in adverse physical impacts on the environment, and as such, is exempt from CEQA.
Financial Impacts and Budget Actions
There is no immediate financial impact associated with these updates. Implementation of high-rise and single stair regulations will be coordinated within existing staff resources in the Building & Safety Division of the Community Development Department and the Fire Department.
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Prepared By: Jonathan Tang, Principal Administrative Analyst Approved Forwarded to Council
Attachments:
A. Single Exit Informational Bulletin (September 1, 2025) B. Written Comments
C. PowerPoint Presentation