October 7, 2025

Dear State Building Inspector Vasquez,

My name is Peter Harrison, and I am the Connecticut Director of the Regional Plan Association, which is a hundred-year-old tri-state civic organization that conducts research, planning, and advocacy concerning the built environment. While I am writing in support of effective single-stair reform in Connecticut, I would like to respectfully note opposition to some of the particular draft language released by the Codes and Standards Committee in August 2025. I believe there is a strong compromise available, which I have outlined below.

The draft released by the Codes and Standards Committee does not meet the intent laid out in the 2024 single-stair reform legislation passed in House Bill 5524. The intent of the legislation is to modernize the state’s fire and building codes to allow for a greater number of safe single-stair buildings to be constructed using modern fire suppression technology and tactics that have become best practice in other parts of the country. The goal of encouraging this ​“missing middle” housing reform is to address the significant lack of housing supply in Connecticut, revitalize our city and town centers, and re-energize the building trades in our state.

This testimony details a path to enacting a more effective reform. While the August 2025 proposal nominally raises the allowable height of single-stair buildings in Connecticut to five stories, it imposes fire department staffing and equipment requirements so restrictive that, in practice, very few (if any) Connecticut municipalities will be able to adopt the reform. For example, regulation 1A of the self-certification process, which states that the ​“initial full alarm assignment [must] include a minimum [of] 28 staff,” is well beyond the capacity of nearly every fire department in the state, including mid-sized cities with professional departments that could otherwise construct denser housing, such as Meriden and Danbury.

While these restrictions appear to be well-meaning, they are ultimately misguided, stemming from outdated and unnecessary fire-safety myths. In reality, building new housing that includes modern regulations, which new single-stair buildings would include, is the best path to fire safety. A newly released report from Pew Charitable Trusts found that the age of residential buildings is the primary factor in fire fatality risk. Nationwide, multifamily homes built since 2010 have one-fifteenth the death rate of single-family homes or apartments built pre-2000. This is because new multifamily homes are built with stringent requirements, including proven life-saving technology like fire-rated materials, sprinklers, and self-closing doors. Between 2022 and 2024, Connecticut saw zero fire deaths in modern multifamily buildings (those built since 2000), which is significantly lower than the fire death rate in both older multifamily and all single-family housing. Yet, these safer, modern homes only comprise 5% of the state’s housing stock. If Connecticut wants to improve fire safety, the answer is to create, not block, opportunities to build more modern, multifamily housing. Effective single-stair reform, coupled with other reforms like removing parking mandates, does just that. By making it easier to construct new multi-family homes, Connecticut would be improving affordability while bolstering fire safety.

International and domestic precedent for more sensible single-stair reform is strong. States and local jurisdictions from Virginia to Seattle to Minneapolis have enacted single-stair reforms that are not burdened by the unnecessary regulations proposed in this language, all while maintaining fire safety. Effective reforms can also have a hugely positive impact on housing supply. A study of the Boston area estimated that similar single-stair reform would create 130,000 new homes simply by developing the vacant parcels within walking distance of transit. In light of the proposed reform’s shortcomings, I urge the Commission to take a different approach.

Instead of moving forward with this five-story reform that is burdened by unworkable fire department regulations, the maximum single-stair building height should be lowered to four stories in accordance with the 2027 International Building Code, but without any additional restrictive fire department service regulations.

Currently, Connecticut fire departments can effectively fight fires in modern three-story single-stair buildings, and the same would be true of such four-story buildings, especially considering the safety standards for new constructions. Other places that have enacted similar four-story reforms have not seen worse fire safety. For example, after New York City passed single-stair reform in 2012, the rate of fire deaths in its 4,440 modern single-stair buildings remained the same as in other new residential buildings, which is to say, extremely low. By avoiding layering on additional local fire department staffing and capacity thresholds, this modest reform tweak could mirror other states and cities around the country, and help Connecticut unlock more housing built with today’s safer practices. To be clear, I believe five and six-story buildings are just as safe, but recognize that more incremental change may be necessary.

Ultimately, Connecticut needs a single-stair code update that can be implemented widely. The current draft is not that; left alone, it will fail to unlock the housing growth envisioned by the legislature. A four-story single-stair option, aligned with existing modern fire-safety standards and consistent with other jurisdictions, would represent a practical, safe, and effective path forward.

Thank you for your consideration of this testimony.

Sincerely and respectfully,

Peter Harrison
CT Director of Regional Plan Association
[email protected]