Testimony: One Front Door Act of 2025

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[DC Council Committee of the Whole testimony]

**Gladstone & Hawarden Cooperative**
Gladstone Cooperative, Washington DC

Thank you for providing the opportunity to testify regarding Bill 26-227, the One Front Door Act of 2025. My name is Payton Chung; I am a Ward 6 resident, an infill residential developer, and a longtime contributor to, and now acting chair of, Greater Greater Washington Commons. I have written twice in GGWash about how single-stair buildings can improve overall life safety and about how single-stair buildings are already found throughout DC’s historic neighborhoods.

First, single-stair apartment reforms could actually improve fire safety rather than compromise it. Fire deaths have declined dramatically—by 90% over the past century and 60% in recent decades—and that is primarily because new buildings are far safer than older buildings, as referenced in previous testimony from Seva Rodnyansky and Eric Mayl.

Building codes, like all regulations, necessarily balance public safety with cost. Today, homebuyers in our high-cost region often turn to existing buildings, or to residential code structures such as townhouses. These lack many of the fire protections found in the more stringent commercial code, such as sprinklers and fire-rated walls and doors. The One Front Door Act offers a path forward to moderate the cost of safer commercial-code structures on smaller infill sites.

Current double-egress rules force most apartments above three stories into double-loaded corridor layouts with units facing interior hallways and windows on only one side, preventing natural ventilation. Single-stair reforms would enable better-ventilated apartments with windows on multiple sides, particularly beneficial for family-friendly units, while maintaining modern fire safety standards through sprinklers and other protections.

Second, I’ve written about how single-stair buildings have served Washingtonians well over the past century. Historical examples include the Gladstone Cooperative in Ward 1, which fits on a lot the width of three rowhouses, showing that single-stair designs enable efficient middle-class housing on narrow parcels.

McLean Gardens in Ward 3, built during World War II to house war workers, received a temporary Fire Escape Act waiver allowing four-story wood-framed buildings with single exit staircases. The development features narrow buildings wrapped around landscaped courtyards with 31 entrances, each serving just a few apartments.

Harbour Square in Ward 6 uses “scissor stairs”—combining two stairs in the space of one—enabling slender tower designs with cross-ventilated units. Unlike today’s double-loaded corridor buildings, these historical examples offered diverse unit types including family-sized three-bedroom apartments, with single-stair layouts allowing windows on multiple sides and units facing the outdoors rather than hallways.

Air pollution used to be bad. How bad?

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Circa 1907. "Pittsburgh by Night."

Seeing a photograph of streetlights on during the day in Pittsburgh prompted me to investigate how bad air pollution really was back then. Voila: a 1979 journal article by Cliff Davidson notes that typical Total Suspended Particulates (a now-deprecated measure) in Chicago in 1913 were 0.3-2.0 mg/m3, with a maximum of 9.3. Cleveland in 1915 reported an average of 14.3 mg/m3, and Pittsburgh was estimated at <7 mg/m3. All of those are many, many times higher than the current EU limit, which is 0.15 mg/m3 – about 99% lower than Cleveland a century ago.

BMA air quality exhibit

The Baltimore Museum of Art currently has an interesting exhibit of art from the turn of the last century, with a bit of added context: how gosh-darn smoke-filled the skies were back then. “Smog was visually stimulating and helped Monet see his urban environment in new ways.” It translates hazy scenes of London and Paris into air quality scores that would be nightmarish for present-day Americans, or challenging even for current residents of developing-world cities.

Old tweets & new posts

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*Population density of land uses
Apartment buildings have lower population densities than other land uses, so office to residential conversion could reduce overall population density.

Tiny Japanese fire trucks, explained

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Wee Japanese fire trucks, as some Stateside auto enthusiasts have discovered, are adorably, I-wanna-pinch-your-cheeks tiny. Here’s one on the streets of Onomichi:

Japanese fire trucks: streets of Onomichi

Of course, something this different doesn’t exist in isolation; there are systemic differences between Japanese and American fire response that allow and even require smaller trucks.

There are more, but smaller, trucks. Japan has smaller, specialized fire and rescue trucks, whereas America chooses to have larger, generalist trucks. Nagata Shozo, a disaster mitigation administration professor at Kansai University, says in a recent NHK documentary (see ~5m in): “In other countries, you may see a single vehicle that combines firefighting and rescue equipment… in Japan, we have a tradition of specialization… We improve the vehicles’ specific uses and capabilities, and when it comes to dealing with emergency, vehicles with different special features are used in combination to tackle the situation.”

At many fire stations I saw vehicles parked nose-to-tail, with garage doors on both sides of the building. A peek inside the Mukojima Fire Station in eastern Tokyo shows a second set of doors behind perhaps a dozen vehicles, including conventional trucks and van-sized ambulances. That is much larger than my brand-new local fire station (Engine #13, Truck #10, Ambulance #13), which has just five bays.

Japanese fire trucks: Mukojima Fire Station

Equally capable equipment is smaller. A ladder truck inside the Shiba Fire Station is about the size of a typical US fire truck. This station is surrounded by new high-rises along the waterfront just south of the Imperial Palace.

Japanese fire trucks: Shiba Fire Station vehicles at night

Compare that to a ladder truck in DC, whose service area only has buildings up to 130′ tall (40m). [Or, check out this short video of a Japanese truck visiting a downtown DC fire station.]

US fire trucks: DCFD Truck 16, SE DC

A NACTO/Volpe report from 2018 calls out ladder trucks in particular as being peculiarly over-sized: “Aerial ladder fire trucks used in major European and Asian cities can reach just as high, despite being only two-thirds as long and having only half of the turn radius as common American models.”

By the way, the Shiba station was huge, with eight ranks of vehicles and garage doors in front and back.

Japanese fire trucks: Shiba Fire Station

There are even smaller vehicles. Note the rescue motorcycle at the right edge of the garage at the Arakawa Fire Department, Otonashigawa Branch. There were even cargo bicycles parked behind it. These can reach medical situations quickly even in pedestrian zones, or after earthquakes when roads may not be clear. (Mukojima above also had motorcycles.)

Japanese fire trucks: Arakawa Fire Department, Otonashigawa Branch

Fire stations are more numerous, and often mixed-use. Shinjuku-gyoen and Shiba are 3 miles apart, and there are five other fire stations in between them – meaning about one station every half-mile. Central Tokyo is dense, but not absurdly so; these areas have the population density of Brooklyn or the Bronx, not Manhattan.

A downside of having so many fire stations is that the land footprint is extensive, but that’s mitigated by combining fire stations into mixed-use buildings. None of the urban fire stations I saw were single-story structures.

Japanese fire trucks: Shinjuku-gyoen and Shiba are 3 miles apart, with five stations between

This isn’t just in urban areas; it also means putting fire trucks in remote areas, like this one stationed at the Enryaku-ji temple complex atop Mount Hiei east of Kyoto:

Japanese fire trucks: Mount Hiei (Enryaku-ji)

The small trucks respond to historically narrow streets – and enable narrow streets into the future. These tiny fire trucks can fight fires and respond to medical emergencies even though Japanese streets are famously narrow (often 4m, sometimes narrower), and just as importantly they allow new streets to be narrow as well. Contrast that with the absolute narrowest street I can build in Raleigh, which is 6.7m wide (34% wider) and requires a 40′ long fire truck turnaround.

Whatever they’re doing, it works. Japan’s fire death rate is substantially below America’s, which is notable given that its cities have historically been even more fire-prone than US cities. America’s “era of great urban fires” was over a century ago; by then, Tokyo alone had seen 49 large-scale urban fires in the preceding two centuries.

More importantly, given that the death rate for car crashes in the US (128 per million) is about ten times higher than the fire death rate (13 per million), the narrow streets and slower speeds found in Japan contribute to a traffic death rate that’s 3/4 lower per capita and 2/3 lower per vehicle.

Further reading:

High rises’ high cost, part 4: ecological cost, and the superiority of low-rise courtyard apartments

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Earlier, I’ve written about how high-rise residential buildings have higher construction costs, land costs, floorplan efficiency, and maintenance costs than low-rise buildings. But leave it to some supertall skyscraper architects to make the ecological case for low-rise multifamily, with the book Residensity. The Chicago-based architects ran analyses on nine different arrangements for 2,000 residential units, from detached suburban houses to 215-story skyscrapers, and found that the optimal type was the humble courtyard apartment.

Park Castle panorama

This housing type, typical of medium-density lakefront neighborhoods in Chicago (see Moss Design), is a low-rise version of a European perimeter block. Multiple apartment entrances are arrayed around a courtyard, each reaching up to six flats (one on either side, for three floors). The deep courtyard evolved (see Ultra Local Geography) from the practice of putting apartment entrances along both streets on corner lots, and a clever response to Chicago’s relatively deep lots. They’re not quite single stair point-access blocks, though: each apartment technically also accesses a second stair — an exterior fire escape, usually built as a sociable rear porch. (21st-century building codes do not count this as a legal egress.) Courtyard apartments also allow for shallower, more usable interior floor plans; unlike mid-century “garden apartments” they structure open space into urbane settings.

The Smith/Gill team found that courtyard apartments had:

  • lowest embodied CO2 for buildings and infrastructure combined
  • lowest operating energy demand
  • 94% land savings vs. suburban houses
  • density that enables energy-efficient transportation modes

In some sense, this shouldn’t be surprising: the high construction costs and operating costs for high-rises are, in large part, paying for large quantities of carbon-intensive materials and energy to go into their construction and operation. The high operating energy demand reflects the large building surface areas that tall buildings have, as well as inefficient floor plans with extensive interior spaces. In a skyscraper, everyone on floor 150 has to travel indoors past everyone on floors 1-149 to get to anything outside the building; in a courtyard apartment building, most of that travel is outdoors.

Most striking to me is the density effect: high-rises aren’t incredibly more land efficient (shown by the green bars) than low-rise multifamily. For the same population, three-story apartments use 87.1% less land than suburban houses, courtyard apartments use 94.2% less, and high-rises uses 97-99% less land. Thus, low-rise apartments offer 90-97% of the land savings that high-rises do.

This paper also didn’t consider CO2 emissions from transportation: almost 1/3 of all US CO2. (The US accounts for 45% of the whole world’s transport CO2!) The greatest potential for transport CO2 reductions is to raise low densities to moderate, not high to higher: “the relationship between density and emissions is nonlinear,” says Grist about a PNAS journal article by Conor Gately — echoing Newman & Kenworthy’s finding from 1999.

Two Japanese new-house ads, explained

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New Price

Here’s a Google-translated ad for new houses for sale in suburban Hiroshima; just this one small advertisement for new houses required a lot of research and explaining to make sense!

  • Housing is indeed inexpensive: the prices are around ¥30M (=3,130 x ¥10,000), or about US$200K at the current, extremely favorable, exchange rates.
  • Mortgage terms are unbelievable. Note the monthly payment of ¥60K, or US$400 given a 50-year (!) mortgage at 0.45% (!). No wonder the carry trade is so huge!
  • As a result, these new houses are broadly affordable; the monthly payment is just 13.6% of the 2019 median household income in Hiroshima prefecture (Japanese household income/expense survey link).
    • Then again, housing is less than 10% of household expenditures in Japan. About 43% of Japanese households are unmortgaged homeowners, which appears to be a fairly typical percentage among OECD countries.
    • Contrast that with American consumers, who spend US$2,120 per month on housing – more than Japanese consumers spend on everything in a typical month.
  • The houses are small, but space-efficient and land-efficient. They’re ~1100 square feet, but fit 3-4 bedrooms, and sit on lots about as large – small even by “small lot” US standards. I’m guessing that zoning limits the site to a 1.0 floor-to-area ratio, which would be typical of an urban neighborhood in the US.
  • At lower right is a tiny subdivision plot plan. Small “mini-kaihatsu” subdivisions like this (<1000 m2, or ~11K sq ft) are exempt from site-permit review, reducing the “soft costs” of building housing. Besides, semi-private residential alleys have long been where workers have lived in East Asian cities, whether Beijing’s hutongs or Osaka’s nagaya.
  • The street widths would be considered unconscionably narrow by US standards that frequently require 50′ rights-of-way. Yet at 5-6m (16-19.6′), they comfortably exceed the 4m (13′) national minimum; this is meant for car access, after all.
  • The location that matters most: “8 minute walk to train station” is in the upper right corner (cropped out in this view). The “two car parking” probably assumes two tiny kei cars, and is more likely enough for one normal car plus some bikes. After all, you can’t register a car without having an off-street parking space.

Building and zoning codes reference link: www.iibh.org/kijun/japan.htm
Brookings Institute overview www.brookings.edu/articles/japan-rental-housing-markets/
English blog on Japanese housing: catforehead.com/

Redevelopment condo ad

If those are the prices for suburbia, how about infill? Here’s an ad for new high-rise condos in the downtown area of Yokosuka, a seaside southern suburb of Yokohama that’s home to a large US Navy base. It’s half an hour to Yokohama by train and one hour to southern Tokyo, and one-bedroom units begin at ¥27M, or US$177K today.

This ad was for a Keikyu condo, near a Keikyu station, and seen on a Keikyu train. Land development is how American streetcar systems made their fortunes, and it’s still a legitimate business model across Asia today.