HomeMy WebLinkAbout1982-004 Memo - AQMA StrategyFebruary 25, 1982
City Council
City Administrator
Ashland's status with respect to the Particulate Strategy for the
Medford-Ashland AQMA
On February 2, 1982, Mr. Merlyn Hough of the Department of Environmental Quality
presented to the ^shland City Council a number of suggested activities aimed at
achieving compliance with State and Federal standards for Total Suspended Par-
'ticulates (TSP). This strategy was developed by the Jackson County Air Quality
Advisory Committee and forwarded to the Board of Commissioners in June of 1981.
~n November of 1981, the Jackson County Commissioners recommended control measures
which ~ere ~$sentially the same as those recommended by the Air Quality Advisory
Committee. I~l order to meet the primary particulate standard by 1984, ambient
particulate levels must be reduced by 30 micrograms per cubic meter (mg/m3).
To achieve this, the Commissioners recommended a total of 22 control measures.
~EQ predicts that these measures, along with the combined continuation of the
i978 strategy, would reduce particulate levels by 32 mg/m3. To implement these
measures, combined action by Federal, State, County, and City governments will
be required, lhe purpose of this memo is to look at each of the measures
separately, and determine if Ashland currently has policies which implement the
measures, or what kind of future activities the City might want to take concerning
each measure.
The following is a breakdown of each measure:
Implementing
Measure Agency
EXD1 anation
l) Trackout controls
City, County,
State
Trackout controls deal with reducing track-
out of soil and mud from construction
sites, orchards and industrial operations.
This does not appear to be a significant
problem in the City because of the lack of
these types of sites. The Ashland Munici-~
pal Code Chapter 9.08.110 states that:
"No person shall deposit uDon public or
private property any kind of rubbish, trash,
debris, refuse or any substance that would
mar the appearance...or would be likely to
injure a person, animal or vehicle
traveling on a public way." This code
does allow some control, but only in a
City Council 2 February 25, 1982
Measure
2) Street sanding
and sweeping
3) Paving unpaved
roads
4) Fugitive Emission
Controls
5) Operation and
~aintenance Program
6) Air conveying
system mass
emission limit
7) Upgrading veneer
dryer controls
8) DEQ enforcement
9) Firewood moisture
control
Implementing
Agency
City, County,
State
City, County
State
State
State
State
State
State,
Federal
Explanation
round-about way. In discussing this with
the Public Works Director, he felt that
there is a definite need for stronger con-
trol and enforcement provisions in this
area. This is a relatively simple thing to
do and the City should move forward in this
area and adopt a trackout control ordinance.
With the City's new vacuum street sweepers
it looks as if we have this problem under
control and no immediate action is re-
quired in this area.
The present City policy on street paving
is necessitated by the financial situation
and costs of paving additional streets.
this policy has evolved over a long period
of time, and changing it could result in
more paving of streets; however, the money
to do this would have to come from some
alternate source before this could be
accomplished. The present budgetary situa-
tion of the City would tend to be in
opposition to an aggressive street paving
program because of a lack of funds to pay
for the projects. Presently the City has
about 23 miles, or 27% of the total street
mileage, in unpaved roads.
DEQ would implement this measure.
DEQ would implement this measure.
DEQ would implement this measure.
DEQ would implement this measure.
DEQ would implement this measure.
There doesn't appear to be much the City
can do in this area short of educating the
public of the advantage of burning dry
wood.
City Council 3 February 25, 1982
Measure
10) Commercial fire-.
wood control
ll) Woodstove design
standards
12) Weatherization
(new woodstoves)
13) Weatherizing
existing homes
Implementing
Agency
State,
Federal
State,
Federal
City, County
City, County
Explanation
The City could not do much in this area.
This is beyond the scope of the City's
authority.
This is an area where the City could pass
a mandatory ordinance requiring weatheri-
zation before issuance of a woodstove per-
mit. This would, no doubt, be a very
controversi~! move which would probably
result in some people ignoring the wood-
stove permit procedure when installing a
new woodstove. Financial programs will be
available for weatherization assistance for
electrically-heated homes in the City through
BPA. Homes which use gas for' heating can
get low-interest financing from CP National,
and oil and wood-burning homes can now
avail themselves of a State-subsidized, low-
interest loan program for weatherization.
So, the financial resources for weather-
ization are now available for all City
residences. Since this is the case, the
major problem with mandatory weatherization,
affordable financing, is available to vir-
tually all homeowners in the City. The
city's draft energy element has suggested
that voluntary controls, stimulated with
financial incentives, are the best routes at
present. We would suggest that vol[ntary
compliance should be pursued until such
time as it is proven that it cannot achieve
these goals. However, we should begin
monitoring of woodstove installations and
disperse information on weatherization
assistance when a permit is picked up.
Here again, the City could pass require-
ments that all homes be weatherized upon
change of ownership or within a specified
time limit (e.g., 5 years). This policy
is even more controversial than requiring
weatherization for new woodstoves. Also,
the mechanism to enforce such a policy
does not now exist. We would suggest in
this instance also that only voluntary
programs should be attempted at the present
time.
City Council 4 February 25, 1982
Measure
14) Woodstove
operation
15) Installation
requirements
(stove, sizing)
16) Alternate
heat source
17) Pollution episodes
curtailment
Impl ementi ng
Agency
State
City, County
City, County
City, County
Expl anati on
We think that education by the City could
help this program and we hope to incl"ude
it as part of the Energy Conservation
Division's education program.
Here again, education seems to be the best
recourse for the City. The Energy Con-
servation Division will develop a simple
woodstove sizing handout which can be
given to the public in conjunction with
building or wo~dstove permits. This handout
will be developed and should be available
to the public by March 15, 1982.
In our experience dealing with the building
industry in Ashland, this does not appear
to be a significant problem, as the vast
majority of homes that have woodstoves also
have some type of back-up heating source.
This situation would tend to indicate that
this is not a problem and requires no City
action at this time.
The City could pass an ordinance requiring
people to use alternatives to wood heat
whan suspended particulates exceed the
health standard of 260 mg/m3. In discuss-
ing this standard with DEQ, they indicated
that, since monitoring began in 1971, this
standard was exceeded in Ashland only one
time and that occurred in conjunction
with a dust storm which did not occur
during the heating season. We feel that,
because of the very rare occurrence of
these types of days, and the fact that
these days, when they occur, could pose
significant health hazards, a curtailment
ordinance should be adopted by the Council.
This .is suggested for two reasons. One,
that it would provide leadership to other'
Jackson County cities, and show Ashland's
strong support for cleaning up the valley's
air. Two, it would allow the mechanism
to alleviate potentially serious health
hazard situations in the future. While
enforcement would be difficult, the number
of days for which the ordinance would need
to be enforced would be very small.
............ ifi~li
City Council 5 February 25, 1982
Measure
18) Open burning
19) Slash burning
20) Energy subsidies
21) Retrofit
woodstove
controls
Implementing
Agency
City, County,
State
State,
Federal
City, State,
Federal
State,
Federal
Explanation
The City presently has an ordinance which
regulates open and barrel burning in the
City. This type of burning is banned out-
right during the period from July 1 to
October 1. Permits are required for burn-
ing during the rest of the year, and they
are issued by the City's Fire Dept. The
Fire Dept. makes a daily check with the
Weather Bureau to ensure that valley
weather conditions are adequate before
allowing the burn. The City's Fire Pre-
vention Officer has indicated that the City
uses the recommended DEQ Ventilation Index
standards in determining whether the
meteorological conditions are satisfactory
to allow burning. Therefore, it appears
that the City already has a program which
implements this measure.
U.S. and State Forestry officials would
implement this measure.
BPA, in their November !981 Draft Conser-
vation and Direct Application~6T~-e]~-e
ResourcZes ~F~gram S~gy, 'fn~t~ ....
~'ha~:-~"B-P-A--~l~-ipates modifications to
its regional weatherization programs in
order to stimulate participation by house-
holds on limited incomes." The City
should aggressively take part and imple-
ment these programs when they become avail-
able to the region. If the programs are
not able to make weatherization activities
available to the majority of low-income and
elderly people within the City, then at
that time the City should look into
developing our in-house programs to solve
this pressing responsibility.
Here again, the City's best course of
action will be in the area of education.
As devices become~available to retrofit
woodstoves to make them cleaner burning,
the City should make people aware of these
devices and their advantages.
City Council 6 February 25, 1982
Measure
22) Solar access
Implementing
Agency
City~ County
Explanation
Ashland was the first city, that we are
aware of, which passed a city-wide Solar
Access Code. This code has been in effect
since September 1980. We also have a Per-
formance Standards Code which gives den-
sity bonuses for building energy--efficient
homes. In addition, the City's Energy
Conservation Coordinator reviews all pre-
application and planning action requests
that are filed with the Planning Dept. with
respect to ~nergy usage. The City needs
to adopt the revised Solar Access Ordinance,
along with the Revised Comprehensive Plan
and Implementing Codes. The major change
in the code will allow people to record
their right to the sun to ensure that
future action of neighbors will not cut
off their solar access. With the adoption
of this revised code, Ashland could be
the foremost City in the United States
with respect to protection of solar access.