DBI to Reinstate EG02 With Clarifications After Fire Department Review; Architects, Tenants Press for Prescriptive Guidance

Angus McCarthy, president of the Building Inspection Commission, moved agenda item 6 forward and the commission heard a detailed presentation on Information Sheet EG02, which covers emergency escape and rescue openings (EEROs) for R-3 residential sleeping rooms.

Neville Perera, deputy director for Permit Services at the Department of Building Inspection (DBI), said EG02 was designed to adapt the California and San Francisco building codes to the city27s narrow 25-by-100-foot lots by allowing an area of refuge in a rear yard in place of direct access to the public way. Perera said EG02 "modifies that 50-foot requirement down to 25 feet" and that projects using the exception have historically documented the deviation with a local code-modification form (AB005).

The bulletin was removed after a State Fire Marshal interpretation concluded emergency escape and rescue openings must be accessible to fire department ground ladders. Assistant Fire Marshal Rich Brown said the State27s response was "yes" to the question of ground-ladder accessibility, and he described operational limits rescuers face when a rear yard cannot be reached by a straight ladder deployment. Brown told the commission the fire department is open to alternatives "like stairs out the back, fire escapes, access openings" that provide reliable rescue access.

A stream of architects, permit consultants and residents urged a fast, transparent fix. Architect Ross Levy and permit consultant Jeremy Paul warned that eliminating administrative bulletins would constrain renovation and ADU work and could reduce housing production. Lehi Weissbach and other callers said the rescission appeared to be made without adequate public engagement. Several callers described real projects where rear-facing sleeping spaces would be affected.

Commissioners pressed staff and the fire department for detail on how the rule would be applied. DBI and SFFD officials clarified that existing, already-approved nonconforming units would not be made illegal by the change; the requirement applies to new buildings and renovations that create new sleeping rooms or reconfigure interior layouts so bedrooms face the rear and thereby trigger the local-equivalency review.

DBI said it and the fire department have "consensus" to reinstate EG02 with an explicit clarification that the project sponsor must demonstrate rescue access for second- and third-floor openings and that AB005 documentation will still be required for exceptions. DBI staff committed to developing prescriptive, implementable alternatives (for example, decks with stairs, cantilevers that preserve a clear passage, or other approved access solutions) and to return to the commission with those proposals on a roughly 90-day timeline.

Commissioners asked DBI to engage tenant representatives as well as the design community while drafting the prescriptive guidance. Several commissioners emphasized enforceability and durability of the approved alternatives, asking that approvals be clear and repeatable so designers and owners know which solutions are likely to be accepted.

No formal vote by the commission was recorded to change the bulletin; DBI described the reinstatement and the next-step schedule as an interagency, staff-level agreement pending the prescriptive guidance and public outreach. The commission asked staff to report back with the proposed prescriptive options and a timeline for finalizing the updated EG02 information sheet.