Good morning, commissioners. Thank you for the invitation. Always happy to speak before the Building Commission and or the Building Department our partners. We see them as our partners. I would just like to say dan lawry laid out a very good process. It makes a lot of sense, and its a very good process. I thought he did a good job laying that out. Id like to just respond to our Planning Department. Were talking about waivers, that may work with the Planning Department. The Fire Department cannot waive fire code requirements. Its basically straight law. We cannot be less restrictive than state law, so id like to put that out there. The other thing id like to mention as i begin, and ill be brief, were all for additional housing, but at some point, when we get started with, its worth taking a pause to remind ourselves why we have building and fire codes. I know we all know this, but its worth mentioning. Its because over the centuries, weve had loss of life and property. We all know thats how thats evolved. Its just worth reminding ourselves that as we move forward. Were all for additional housing. We want that, but we want safe housing. Id like to briefly talk about scope and jurisdiction. So as with you e all know, the on a three year cycle. The government adopts standards from the International Building and fire code. It becomes the California Building and fire code. The local jurisdiction from the Fire Departments perspective asks to or adopts the california code with amendments, local amendments, in San Francisco that meets challenges of San Francisco due to topo graphy, geographic cal challenges, requirements. We can be more restrictive, we cannot be less restrictive, so again, when were talking about waivers, thats outside. When were talking about adus, lets talk about adus. First of all, are we talking about r3, one and two family dwelling units, or are we talking about rus. R3, Planning Department jurisdiction. R2, Fire Department jurisdiction. The onus, when an applicant comes in and has a proposal for an adu, the onus to meet code and the requirement falls on the Design Professional, falls on the architect of record, engineer of record, etcetera. I cannot agree more with my colleagues here about the necessity for a preapplication process. Thats where we sit down, the Design Professional comes forward, lays his or her plans out and says yes, this is my design scope. I meet code from a to z, or no, i cant meet it in certain areas. Its the onus of the Design Professional to bring that forward to our attention. As the authority having jurisdiction, we look at that and say, okay. What is your proposal . How do we meet the intent . Can we meet the intent . Can you give us an enhancement that offsets the deficiency that you cannot comply with . That thats what we ask, and thats where it becomes subjective, and i understand the differing opinions. When the Fire Department looks for an enhancement to offset the deficiency, we look at it through the lens of the Fire Department and our experience with fires. We understand how fires, how buildings perform in fires, how they affect our egress system, how they affect our Fire Department access, etcetera. So when we are looking at an equivalency or some kind of enhancement, were saying okay, from our experience, and our expertise being in a fire, are those occupants of this building, are they going to be as safe as if you meet the letter of the code. And we as the Fire Department when it falls under our jurisdiction has to look at that. We try to apply it consistently and fairly as much as possible. Ultimately, were looking out for the safety of the occupants of the building. Challenging with adus, ill just give you a couple scenarios that ive run into. Its rescue windows, access to rescue windows, and egress. So when the applicant wants to use the single entrance exception, and they do not meet the travel distance requirement, so if they go beyond 75 feet or you go up to 125 i dont want to get in the weeds too much here, theres requirements where you can go beyond is 25 feet if youre fully sprinkleered . We brought up proposals first of all, let me say, weve taken a little criticism on some of our proposals. The onus is not on the Fire Department to design these for the applicant. We partner with Building Department and the applicant to try to work through this to get to where we can all have a good a safe structure. So if the point being, if the applicant meets the code, he can he or she can round file our fire safety sheets, info sheets, abs, etcetera. They can round file it. If they want to find an alternative, we give them a path. Rescue windows, is a rescue window truly a rescue window if the Fire Department cant put a ladder to it . Is a rescue window truly a rescue window if the occupant cannot selfrescue . Is a rescue window truly a rescue window if i cant make it to the public way if im still in the building . These are the questions we have to answer, and these are the challenges that we face, and these are the solutions, and we try to find solutions to that, to our solutions to that. Nfa13 as opposed to 234 fa13, we look the aall these enhancements to ensure that that one point of access or egress will always be there in the event of a fire. And then lastly without digging too much into the code, id like to say this. I think the process is not being followed property, and when i say that is, when an applicant comes forward, and our plan reviewers makes comment makes a comment, a requirement or so, and you, as the applicant, you either disagree with that comment its not required by code, disagree with the interpretation, or want to propose an alternative, the solution is to go to his or her officer in a chain of command, request a meeting to have a discussion, and send it up the chain. And they cant resolve it through the captain, assistant fire marshal, i will get resolved. If i cant resolve it with my team, then, the applicant can go to the state fire marshal and request interpretation. Thats the process, and we would allied by any interpretation of the state fire marshals office. Ive seen a couple emails fly around where the applicant kind of glows arouoes around that pd goes right to the Building Department, can you help with this . Youre unilaterally making these requirements, etcetera. That is not the case, and im not going to speak to details of emails. But the emails that i have seen, i am not aware of those applications. So again, the process is not being followed properly, and i think we could head off a lot of these problems if it was followed properly. And im happy to answer any questions that you may have. Thank you, fire marshal. If if i may, i have a few questions. Absolutely. And i you stress about getting into the weeds. I would never dare get into the weeds with the fire marshal. All right. Im just talking about in the spirit of the conversation, and terminologies you use of less restrictive codes. Yeah. Partnership was a big one that kind of jumped out at me, and im glad you said it, because this is a partnership. With regard to the adus, now that weve kind of i think one thing thats coming out, and the feedback im geding,s getting, as well, is its a very successful program, and its a great option to provide housing in existing structures, and looking at these numbers, please correct me if i am wrong if im wrong, but were looking at well over 1,000 units that could be produced without having to go to the taxpayer. Its an incentive for the existing Property Owner to improve their properties and in many cases bring their properties up to code. As i look at the numbers, like lets just say we had almost 109 that were approved, right . And then right now, weve got, i think lets say 50, round up numbers that are sitting there. The question that i have is and im not saying, fire marshal, that i i think youre right now in fire, theres Something Like 14 or 15. Which is a pretty good number. Yeah. Well, its a pretty good number. The question i have it now that we know what we know, the kind of resistance were getting, just maybe as i was saying, facing our demons, theres certain procedures we can follow as a department, and that could be a mechanical scenario. It could be right down to the exiting issue, but it seems to me that there seems to be a pattern of a type of building that we seem to be putting into the department that probably will never be able to get out of there because of its, you know, for example, lets say the exiting issues for you. And im hearing that the ones that keep coming back a lot are these dual exiting, not going to the 125. Lets say they were the small what we would know as the workmans entrance. Yeah. That seem to be a lot of the issues. And so some of the resolutions that are forwarded there as to solve it for example, lets say, we might have to do double shoot rock for fire exiting, i think its sprinkleer, so on. The corridor might be kind of narrow. We might have to relocate the gas room, and so on. They could be potentially financially so burdensome and time on the property, we probably are we better off telling these people up front that rather than going through the process, chances are unless youre willing to pay a lot of extra money and getting a lot of extra approval, that we shouldnt be approving these applications. Two things. I think it should be a preapp that would include building, planning, and all that at once. You bring everyone on at once and say is this a feasible project . I think that would go a long way. Im hesitant, when we talk about when we refer to the Fire Department making these calls, you need this, you need that. Earlier to my point, when i first got up here, the onus is on the Design Professional. The Design Professional should be thoroughly knowledgeable of the code and understand what he or she should not do. And the trades men, thats a nonrated passage. So if i cant get, by code and again, we cannot be less restrictive, if i cannot get from the most remote area of my adu to the public rightofway within 75 feet, i need a secretary exit or you can give me a rated passage way to an exit, and i can rate the entrance of that. If youre talking feasiblity, i can talk feasiblity. The code doesnt allow it. Lets take it a step further. Trades man, im going to have trash cans in there, gas meters, as well, and thats going to be my only exit for the people that im putting in my building and far deep into the lot . We have to look at that, as well. So i think to sum it up, one size doesnt fit all here, and its a case by case, and we have to look at it case by case. Head off a lot of these problems, Early Intervention, and Early Intervention means preapp, with all involved, would go a long way. So if i may finish, can i ask you something and this kind of talks to the less restrictive, and i think i know the answer to this, but i just wanted to see if i am going down the wrong rabbit hole here on this. If i do have workmans entrance that might make it, right, we can fireproof it, we can make it, out of one to ten in your world, an eight, that was never there before. Where obviously an eight is better than nothing. Right. Where does those type of decisions fall for the department . So theres a process for alltive means and methods. How do we meet the code . Is the intent to have a one who are . Two hour . How can i physically do it . Can i not physically access both sides of the wall. Theres a process Building Code alternative means and methods. Fire can be part of that discussion, and yes, were open to that. Again, with the measurement in our mind, in our mind, with the approach we have to answer, are we do we meet the intent, if the intents for one hour, if the intents for two hour, do i meet the equivalency, and thats the question we have to answer. To just say hey, its close enough, thats the wrong path to go down. The path is what is required, what are you giving us, where is the deficiency, how do i offset the deficiency to makeup for that deficiency, any kind of enhancement is it an alternative design, is it an alternative means or method, and if were confident of that, we move forward. One other thing id like to make, we talked a lot we mentioned a couple times about our fire safety sheet, our bulletins, etcetera, and we standby them. I personally signed that that bulletin and the fire safety sheet does not address exiting, does not address fire safety windows. It addressed sprinkleers. It does not waive requirements for stand pipes, does not waive requirements for exiting. So i think theres a misunderstanding that someone reads that document and take its too far, that reads Something Else in that its not. So i think i technically appreciate your trying to get me there. I mean, where my concern is obviously, were going to have 600 of these coming at you. Yes. So im asking the question, and lets just talk a little bit about the preapp. Yeah. Maybe thats where were at. In your experience, is it all the sf05 and the g23, so theyre the first round of applicants, applications to come in. You sit down with the fire, everybody sits there, and they tick those boxes, right . Correct. That document, is that document good enough to pretty much look that project in the eye and say okay, if you dont change anything, and you present what you have presented here, and what the information you told us today, well stand behind that decision, and you can go forward to all the next you know, go ahead with your design team, go ahead everything with that . It answers the question, how far to what extent do i sprinkleer the building. Im changing the use from r3 to r2. Do i springler the whole building . It answers those type of questions. It does not answer questions on egress and other life safety provisions in the code. So so yes and no. It gets you halfway there. You still you still have require other oth other requirements to meet for code. I think were talking about the same issues here, the exiting and so on, the fireproofing of those corridors and so forth. Is there anything that could be done as a part of that check list that could get us there before we go down that rabbit hole. Thats a difficult one to answer because every the adus that ive looked at personally that come up to my level, theyre all different. I cannot produce a document thats going to cover the four or five that ive looked at. Theyre all unique in themselves and different challenges, depending on the configuration of the building and where its located, etcetera. Again, our goid uide is whats the code, and if were going to did he have yat from that, there is an open equivalency. If you had a preapp meeting it, you would say heres our site plan, my Fire Department access and myegress. At that point, on just a site plan, we could look at that and say okay, give your occupant load, given the number of units, given your building, you need a second exit, or we could talk about the options that you have. That would be the way you do it. So you would have fire, dbi, planning. It would be the big picture stuff. Whether its feasible to move forward with the project. That could be addressed at the preapp phase, the first yes. And fire would be comfortable enough saying if what im saying here, and if this doesnt deviate from what im seeing, based on what im seeing here, these would meet your fire requirements based on a, b, and c. So the way we do our detail, we agree on all the design element details on that project. We sign off on the preapp. Unless information wasnt presented to us that comes to our later, that changes everything, we standby that document. We do. Yeah. Okay. cause that that would be in anticipation of all these permits coming at you. I think eventually well be able to identify pretty much the kind of projects that arent going to work. Great. Great. And we could save ourselves a lot of emails later ongoing around, trying to put a square into a round hole, right . And just information for this group here, for this commission here, were already taking steps towards gathering a team that is dedicated towards these adus, where the process is consistent. We want to give a consistent message, and and consistent interpretation, so when we do make a decision, that whole group knows, and theres a path that follows. And that would be in the plan checking process. So thats in the plan checking process, agreed. Okay. And we are tracking adus separately independently where we didnt before. They were kind of thrown in a spreadsheet with everything else, so we understand this is kind of sensitive, and its difficult at times can be difficult. Thank you, fire marshal. Few more questions, if you dont mind. Sure. Commissioner lee, please. Im just wondering, does the city ever tell an applicant that the project is not feasible. Thats for the owner to decide that. We just we would just explain what are the code requirements as far as we see them. Heres the thing the Fire Department doesnt standup there and say you shall do a, y, and z. Our job is to enforce the code. Here is the code, and this is what it is. If the applicant disputes, that we welcome that. We do not have a problem with that at all. You put it in writing, you go up the chain. So with the understanding of that, the onus is now on the applicant, hey, is this feasible and worth moving forward . We dont get into the dollars of things. We just focus on what is required in the code. Questions . Yeah . Anymore. Thank you, fire marshal, for that. Thank you. Thank you. Is there any Public Comment on item eight . Mr. Boskovich, surprise, surprise. Pat boskovich. Im a San Francisco native. We called these Garden Apartments when i was growing up. I lived in the stone center apartmen