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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.