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Home My WebLink AboutCOUNCIL - AGENDA ITEM - 05/11/2004 - AIR QUALITY PLAN UPDATEDATE: May 11, 2004 STAFF: Lucinda Smith STUDY SESSION ITEM FORT COLLINS CITY COUNCIL SUBJECT FOR DISCUSSION Air Quality Plan Update. GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED A periodic update of the City’s Air Quality Plan is nearing completion. The draft Air Quality Plan (Attachment D) has the following chapters: • Introduction • Prioritizing air pollutants and sources • Air quality policy • Implementation strategies • Measurement and reporting The Council will be asked to adopt only the chapter on air quality policy. Adoption is scheduled for June 15, 2004. The purpose of this study session is to seek Council direction on air quality policies. Most of the policy revisions are relatively minor adjustments that clarify, consolidate, or remove obsolete policies. Major policy additions or changes include: • Reframing the long-term vision to reduce VMT growth to the population growth rate. • Addressing non-road mobile source emissions. • Reducing residential emissions of ozone precursors • Clarifying the City’s role in health protection • Reframing the City’s toolbox of air quality strategies Question one – Is the Council ready to adopt the air quality policy chapter, scheduled for June 15, 2004? Question two – Does the Council have any questions, comments, or suggestions regarding the overall Air Quality Plan document? BACKGROUND The City’s Air Quality Plan currently consists of a 10-year Policy Plan and a 4-year Action Plan, both adopted by City Council. Both documents are due to be updated this year. This will be accomplished by creating a single document, the Air Quality Plan, a five-year policy and strategic planning document. This approach will streamline the planning process, elevate the level and May 11, 2004 Page 2 frequency of air quality policy discussion, and allow more flexibility in annual staff work planning to take advantage of emerging opportunities. The 2004 City Plan update will include only those air quality policies that relate directly to transportation and land use planning (Attachment A). As part of the recent City Plan update process, Council has already reviewed this subset of air quality policies. These polices are labeled ENV, and are reproduced in the draft Air Quality Plan exactly as they appear in the latest City Plan draft. Additional air quality policies relating to residential and industrial sources of air pollution, health, and other operating practices are labeled “AQ” in the draft Air Quality Plan. Council has not reviewed these policies yet, and they will be the focus of today’s meeting (Attachment B). All air quality policies (ENV and AQ) will be contained in the policy chapter of the new Air Quality Plan. Attachment C is the draft Air Quality Plan. It contains information about the process of updating the Plan, including the selection of air pollution and source priorities (Chapter 2), air quality policies (Chapter 3), broad five-year implementation strategies (Chapter 4), and a list of air quality indicators that will be used for measurement and reporting (Chapter 5). Appendix A contains air quality data. The policies and strategies contained in the draft Air Quality Plan reflect input to date from the public, Council Boards, City staff and consultants. Outreach activities and comments are outlined in Attachment D. Air Quality Policy Highlights 1. Reframed air quality principle stating that the City’s long-tem vision remains to reduce VMT growth rate to the population growth rate (Principle AQ-2) Until 2004, City Policy T9.1 stated a City goal to reduce VMT growth rate to the rate of population growth. Recent trends indicate this is not happening nationally or locally. Therefore, in the 2004 City Plan update, Policy T9.1 was revised to say the City will strive to reduce the growth rate of VMT by implementing a VMT reduction program that meets or exceeds the performance of similar programs in comparable cities. However, the staff recommends that the original goal, while seemingly unattainable in the short term, is still important to retain as a long term vision. This would result in multiple community benefits including reduced air pollution and carbon dioxide emissions, reduced road maintenance needs, lower community-wide fuel expenses, etc. 2. New policy to address non-road mobile source emissions (Principle AQ-12 and Policy AQ- 12.1) Emissions from on-road mobile sources are predicted to decline over time as the result of increasing federal controls of emission and fuels. Consequently, the relative contribution of non-road emissions to Fort Collins' air pollution will increase. Non-road sources include construction equipment (heavy equipment, generators, forklifts), gasoline-powered lawn and garden equipment (mowers, trimmers, edgers, etc.), farming and mining equipment, recreational vehicles (dirt bikes, snowmobiles), locomotive and aircraft emissions. EPA is considering tighter controls for diesel non-road engines, but they will not come into effect for several years. May 11, 2004 Page 3 3. New policy calling for actions to reduce residential ozone emissions that contribute to ozone formation (Policy AQ-14.2) Fort Collins is only 18% below the new federal health standards for ozone, which contributes to asthma and other respiratory ailments. Along with Denver, Boulder, and Greeley, Fort Collins has been included in EPA’s deferred ozone non-attainment boundary. New state regulations will address most emissions from commercial sources (gas wells) and mobile sources (by lowering gasoline volatility). Therefore, the City should focus outreach efforts on residential practices that contribute to ozone. City actions could include lawn mower rebate programs, automobile gas cap replacement programs (to remove leaky gas caps), and encouraging mowing and refueling when the sun is low to reduce evaporative emissions. 4. New principle to clarify the City’s role in health protection (Principle AQ-15) The protection of human and environmental health forms the basis for all air quality protection efforts, yet the City is not a human health protection agency. The proposed new principle establishes clearer boundaries around what has long been a gray area; the City’s role in air quality-related health issues. It defines the City as “solution seeker” for issues that may be raised by the public or Council such as radon and second hand smoke, not as “standard setter.” 5. Reframed “toolbox” of air quality strategies (Policy AQ-1.5) Previous policy has been to apply air quality strategies in a certain order of priority: starting with City leadership in its own operations, through education, promotion, and incentive programs, and finally to regulation. In practice, although education is always a first resort, air quality programs have applied the approach most appropriate to the circumstances, rather than follow a strict priority order. The proposed policy simply lists the strategies in the City’s “toolbox:” education, incentives and price mechanisms, and regulation. ATTACHMENTS Attachment A – 2004 City Plan Air Quality Policies Attachment B – Matrix of Non-City Plan Air Quality Policies Attachment C – Draft Air Quality Plan Attachment D – Public Outreach Summary 1 Attachment B – Non-City Plan Air Quality Policies 5/4/04 Policies are presented in the order they appeared in the new draft Air Quality Plan. Original Principle/Policy Proposed Principle/Policy Comments Policy ENV-1.7 Hierarchy of Approaches. The City will minimize air pollution emissions using the following hierarchy of approaches: first, pollution prevention; second, pollution control technology; and third, operating practices. Policy AQ-1.3 Pollution Prevention. The City will minimize air pollution emissions using the following hierarchy of approaches: first, pollution prevention; second, pollution control technology; and third, operating practices. promote preventing air pollution at its source as the highest priority approach in reducing air pollution emissions. The new wording clarifies the intent of promoting pollution prevention as the pri- mary means of reducing air pollution. New Policy AQ-1.4. Priority Pollutants. The City will focus its efforts on reducing high priority air pollutants including ozone, fine particles, mobile source hazardous air pol- lutants, and greenhouse gases, followed by efforts to reduce medium priority pollutants including indoor air pollutants, nitrogen ox- ides, PM10, industrial hazardous air pollut- ants, and carbon monoxide. Instead of repeating the pollutant priorities in each policy, they are stated once in a separate policy. 2 Original Principle/Policy Proposed Principle/Policy Comments Policy ENV-1.12 Voluntary Actions. Action strategies of the City will be implemented in the following order of priority; first, actions the City is required to take; second, actions the City will take voluntarily to reduce emissions in its own opera- tions; third, actions the City will ask others to take voluntarily through education promotion or incen- tives; and fourth, actions the City will require oth- ers to take by ordinance. Policy AQ-1.5 Toolbox of Approaches. The City will seek to achieve local air qual- ity goals through education, incentives and price mechanisms, and regulation. The original Policy ENV 1-12 contained two concepts; 1) what the City will do in- ternally, and 2) how the City will interact with others. The City’s own role is now addressed in Policy Aq-16.1 “Lead by Ex- ample.” The new policy here just ad- dresses City interaction with others. It as- sumes the City will apply the approach most appropriate to the circumstance. As an example, in the case of smoking, the City moved to regulation as a result of public input, without City activities on education or incentives. Policy ENV-1.15 Measurement. The City will measure and review the progress of key air quality indicators at least every two years in order to de- termine whether action strategies are having the desired effect or need to be amended. The City will report air quality information to the public on a fre- quent and regular basis. Policy ENV-1.6 Measurement. The City will measure, review and report the progress of key air quality indicators at least every five two years in advance of the Air Quality Plan update, in order to determine whether action strategies are having the desired ef- fect or need to be amended. Instead of measuring and reporting on the complete list of air quality indicators every two years, the City commits to report on air quality indicators every five years, prior to updating the Plan. Policy ENV-1.25 Access to Information. Policies will be developed to direct the City to assist resi- dents in gaining access to information regarding emissions of air pollution from sources that are of concern to them. Policy AQ-1.7 Air Quality Information. The City will report available air quality in- formation to the public on a frequent and regular basis. The City will assist citizens in finding existing air quality information that is of interest to them. Instead of charging the City with develop- ing policies about access to information, 3 Original Principle/Policy Proposed Principle/Policy Comments Policy ENV-1.19 Local Authority. The City will oppose any action of the State Legislature that re- stricts local government authority to improve air quality beyond minimum State requirements, even as the City recognizes and seeks to strengthen the vital role of the State of Colorado in improving air quality. Policy AQ-1.9 Local Authority. The City will oppose any action of the State Legisla- ture that restricts local government authority to improve air quality beyond minimum State requirements, even as the City recog- nizes and supports seeks to strengthen the vital role of the State of Colorado in improv- ing air quality. In an effort to clarify, this policy substi- tutes “supports” for “seeks to strengthen.” New PRINCIPLE AQ-2. Although VMT – the total number of miles driven in Fort Collins each day – is growing faster than population, the City’s long-term vision remains to re- duce the VMT growth rate to the population growth rate. While it is not realistic to think the Fort Collins will be able reduce VMT growth rate to population growth rate within the next five years, it is an important long-term vision for air quality protection. ENV 1.1 Air Quality Objectives. • Continually reduce the tailpipe emissions per mile of high-priority pollutants, including carbon mon- oxide, fine particulate, air toxins, and volatile or- ganic compounds. (Emissions per mile is calcu- lated using USEPA's MOBILE emissions simula- tion model or equivalent. Units: grams per mile.) PRINCIPLE AQ-12. The City will reduce tailpipe and evaporative emissions from highway and non-road mobile sources. This modification is an important expan- sion of mobile source “tailpipe” policy so that it explicitly includes evaporative emis- sions (that relate to ozone formation) and non-road mobile sources (because non- road emissions are growing in relative im- portance). New Policy AQ 12-1. Non-Road Emissions. The City will employ incentive programs and other strategies to reduce emissions from lawn and garden equipment, small and large construction equipment, and other non- road engines. This supports Principle AQ-2 that expands the City’s focus to include non-road sources such as lawn/garden and construc- tion equipment because non-road emis- sions are predicted to be a growing con- tributor to the City’s air pollution. 4 Original Principle/Policy Proposed Principle/Policy Comments ENV 1.1 Air Quality Objectives. • Continually reduce total emissions of high priority pollutants from commercial and industrial sources in the Fort Collins Urban Growth Area, including carbon monoxide, fine particulate, air toxins, and volatile organic compounds. (The emissions inven- tory is compiled using existing information sources, supplemented by additional data collection if needed. An inventory of pesticide use is included. Units: tons per day. PRINCIPLE AQ-13. The City will reduce commercial and industrial emissions in the Fort Collins Growth Management Area, fo- cusing on priority pollutants. This principle was added to create format consistency. Each air pollution source category (mobile sources, commercial & industrial sources, non-road sources, resi- dential, etc.) is addressed with a principle. New Policy AQ-13.1 Business Assistance. The City will offer programs and assistance to local businesses interested in reducing their environmental impacts such as the voluntary business Climate Wise program. This policy supports Principle AQ-13. New PRINCIPLE AQ-14. The City will reduce residential emissions of priority pollutants in the Fort Collins Growth Management Area. This principle was added to create format consistency. Each pollution source cate- gory (mobile sources, commercial & in- dustrial sources, non-road sources, residen- tial, etc.) is addressed with a principle. ENV 1.1 Air Quality Objectives. • Reduce area-wide wood smoke emissions. (Wood smoke emissions are calculated from surveys of the wood burning practices of area residents.) • Reduce the number of non-certified wood stoves and conventional fireplaces. (The number and type of wood burning units are based on surveys of the wood burning practices of area residents.) Policy AQ-14.1 Residential Wood Smoke. The City will reduce area-wide wood smoke emissions and the number of non-certified wood stoves and fireplaces in the Fort Collins GMA by, for example, insuring compliance with existing regulations, pro- moting alternatives to wood burning, and helping to resolve neighborhood wood smoke conflicts. (Wood Smoke emissions are calculated from surveys of the wood burning practices of area residents. (The number and type of wood burning units are based on surveys of the wood burning prac- tices of area residents.) No substantive change. Since “area-wide” was hard to define, that phrase was cut. This revision also gives 5 Original Principle/Policy Proposed Principle/Policy Comments New Policy AQ-14.2 Ozone Reduction. The City will reduce evaporative emissions asso- ciated with residential activities (lawn mow- ing, fueling, paint selection and storage), by, for example, educating citizens and provid- ing incentives. EPA designated Fort Collins as part of the deferred ozone non-attainment area bound- ary. We will work to reduce ozone precur- sor emissions in hopes of avoiding a viola- tion of the standard in Fort Collins and re- ducing our contribution to regional ozone levels. Currently, commercial and mobile sources are regulated by the state, leaving residential emissions to be addressed lo- cally. New PRINCIPLE AQ-15. Health Protection. Recognizing the strong relationship between air quality and human health, the City will, within the scope of its ability, strive to pro- tect and improve the air so it is healthy to breathe and free of levels of pollutants that harm human health. Clarifies the City’s role in health protec- tion as “a solution seeker, not as a standard setter” and recognizes municipal limita- tions by adding “within the scope of its ability.” New Policy AQ-15.1. Health Partnerships. The City will solicit the cooperation and ac- tive participation of a diverse group of knowledgeable health professionals and members of the environmental health com- munity to guide the development of policies so that they reflect priority health issues. Since the City does not employee its own health experts, this policy emphasizes the role of health professionals in the City’s policy and program development. New Policy AQ-15.2. Seek Solutions. The City will work to protect air quality by seeking solutions to high priority health-related air quality issues using already adopted health standards. 6 Original Principle/Policy Proposed Principle/Policy Comments Policy ENV-1.4 Air Toxics Coordination. The City will work with County, State and Federal health officials to reduce the health risks posed by toxic air pollutants including risk of cancer, muta- tion, developmental disorders, and nervous system poisoning. Policy AQ-15.3 Air Toxics Coordination. The City will work with County, State and Federal health officials to reduce the health risks posed by toxic air pollutants. including risk of cancer, mutation, developmental dis- orders, and nervous system poisoning. Identifying specific risks at the policy level is too much detail. ENV 1.1 Air Quality Objectives. • Increase the percentage of residences and work places taking action to reduce exposure to indoor air pollution. (The percentage taking action is cal- culated from surveys of residences and work places.) Policy AQ-15.4 Indoor Air Quality. Be- cause a majority of air pollution exposure occurs indoors, the City will take actions to reduce residents’ exposure to indoor air pol- lution. “Because a majority of air pollution expo- sure occurs indoors” provides justification for work on indoor air quality. “Taking action” can refer to education, incentive, or regulation, all of which the City currently does to reduce indoor air pollution. Policy ENV-1.16 Leadership. The City shall initi- ate, lead, and cooperate in inter-city, regional, na- tional, and global efforts to improve air quality, recognizing that air quality improvement is not completely within the City's control. PRINCIPLE AQ-16. The City will lead by example in efforts to improve local air qual- ity. This new principle combines and simpli- fies three similar policies. Policy ENV1-12. Voluntary Actions. Action strategies of the City will be implemented in the following order of priority; first, actions the City is required to take; second, actions the City will take voluntarily to reduce emissions in its own opera- tions; third, actions the City will ask others to take voluntarily through education promotion or incen- tives; and fourth, actions the City will require oth- ers to take by ordinance. Policy AQ-16.1 Lead by Example. The City will make efforts to reduce and mitigate its own air pollution emissions before asking or requiring others to reduce and mitigate their emissions. The Original Policy ENV 1-12 contained two concepts; 1) what the City will do in- ternally, and 2) how the City will interact 7 Original Principle/Policy Proposed Principle/Policy Comments Policy ENV-1.18 Partnerships. The City will so- licit the cooperation and active participation of in- dependent community organizations in advancing the implementation of the City's air quality policies and programs, including, for example, Colorado State University, Poudre School District, Chamber of Commerce, and industrial and commercial busi- nesses. AND Policy ENV-1.17 Synergy. The City's air quality efforts shall be coordinated with and supplement the efforts of others, to increase program effec- tiveness and to avoid duplication of effort. "Oth- ers" include, for example, citizen groups, commu- nity organizations (e.g., Colorado State University, Poudre School District), Poudre Fire Authority, and County, State, and Federal government agencies. Such coordination includes research, strategy de- velopment, public outreach campaigns, and en- forcement. Policy AQ-16.2 Cooperation. The City will initiate and cooperate with other efforts to improve air quality, while avoiding un- productive duplication of effort. Others in- clude government entities (other City de- partments, county, regional, state, national, global), the non-profit sector, businesses, and educational institutions. Policy ENV-1.13 Innovations. The City will con- sider adoption of successful air quality improve- ment strategies in effect elsewhere, including mu- nicipal practices, public information campaigns, incentive/promotion programs, and regulations. Policy AQ-16.3 Innovations. The City will consider adoption of successful air quality improvement strategies in effect elsewhere, including municipal practices, public infor- mation campaigns, incentives and price mechanisms, and regulations. No change. Policy ENV-1.2 Definition of Improvement. Im- prove air quality by reducing total area-wide emis- sions into the air from motor vehicles, commerce and industry, and residences, and by reducing per- sonal exposure to indoor air pollution. DELETED Not necessary - A definition of improve- ment is articulated in the air quality indica- tors section of the Air Quality Plan. Policy ENV-1.3 Offset Emissions. More than off- set emissions from new sources by reducing emis- sions from existing sources. DELETED Original purpose was to clarify a means of achieving the overarching goal of “contin- ual air quality improvement.” It has been deemed unnecessary. 8 Original Principle/Policy Proposed Principle/Policy Comments Policy ENV-1.9 Support Regulations. The City will support and encourage enforcement of Federal, State, and County air quality regulations. DELETED This concept is covered in new Policy AQ- 1.8 Enforcement (page 2 of this table). Policy ENV-1.11 City’s Role. City programs, es- pecially the planning and implementation of trans- portation, land use, utility service, and capital im- provement programs, shall address themselves to changing citizen travel behavior to reduce vehicle miles of travel, using strategies that reduce trip generation, reduce trip length, and increase vehicle occupancy. PRINCIPLE T-3: Transportation Demand Management will be a critical component in the city’s overall transportation system. City transportation programs will promote the reduction of vehicle miles traveled through strategies that reduce trip generation and length and increase automobile occupancy. The basic policy was retained, but it was removed from the ENV section, re-worded slightly, and placed in the Transportation section of policies in City Plan. Policy ENV-1.14 Internal Conformance. The City will adopt no transportation or land use plan or program unless there is an affirmative finding that the plan or program has given consideration to the objectives and policies of the Air Quality Policy Plan (1993). DELETED Language has been placed in City Plan (page 86) stating that “other recently adopted plans consistent with the Princi- ples and Policies of City Plan can be con- sidered elements of City Plan, helping to further shape our City’s desired future. Therefore, these next tier of plans need to be considered when making decisions.” Policy ENV-1.20 Regulation by Other Agencies. The City will not directly enforce State regulations on stationary air pollution sources. Rather, the City will continue to rely upon the Colorado and Larimer County Health Departments to assure that local sources comply with Colorado Air Quality Control Commission regulations. DELETED ENV 1.20 was deleted in order to leave room for the City to play an enforcement role in the next five years if further evalua- tion identifies a need for that. Adequate policy direction is provided by the Policy AQ-1.7 on Enforcement (page 2 of this table). Policy ENV-1.21 Land Use. The City shall sup- port proposals for higher density residential devel- opment and mixed land use development in appro- priate neighborhoods and districts, if they are de- signed to enhance the use of alternatives to single- occupant motor vehicle transportation, and if they 9 Original Principle/Policy Proposed Principle/Policy Comments Policy ENV-1.22 Stationary Sources. The City will recognize health risks, especially with respect to air toxics, when considering potential sites for new stationary air pollution sources and receptors. AND Policy ENV-1.24 Site Conditions. The City will recognize the effect of local wind patterns and to- pography on air quality, when considering potential sites for new stationary air pollution sources or re- ceptors. DELETED ENV 1.22 and 1.24 are no longer needed for two reasons. Because the Land Use Code clearly specifies uses (e.g. stationary sources) allowed in each zoning district, there is no debate about potential sites as there was under the LDGS. Second, Natu- ral Resources plans to complete a white paper on localized exposures to criteria pollutants. This will address some of the issues about health risks and sources. DRAFT Fort Collins AIR QUALITY PLAN Draft May 4, 2004 TABLE OF CONTENTS (May 4, 2004) Acknowledgements EXECUTIVE SUMMARY 1.0 INTRODUCTION………………………………………………………………. 1-1 1.1 How to Use This Plan …………………………………………………. 1-1 1.2 Fort Collins Role in Protecting Air Quality…………………………..... 1-1 1.3 Conceptual Planning Approach………………………………………… 1-4 1.4 Plan Development Process……………………………………………… 1-5 1.5 Public Input……………………………………………………………… 1-7 2.0 PRIORITIZING AIR POLLUTANTS AND SOURCES………………………… 2-1 2.1 Priority Air Pollutants…………………………………………………… 2-1 2.2 Priority Air Pollution Sources…………………………………………… 2-2 3.0 AIR QUALITY POLICY……………………………………………………….. 3-1 3.1 Organization………………………………………………………………... 3-1 3.2 Air Quality Vision, Goals, Principles and Policies………………………… 3-2 3.2.1 Air Quality Vision and Goals…………………………………... 3-2 3.2.2 Air Quality Principles and Policies…………………………….. 3-2 3.3 Related Vision, Goals, Principles and Policies…………………………….. 3-6 3.3.1 Related Vision and Goals……………………………………… 3-6 3.3.2 Related Principles and Policies………………………………… 3-7 4.0 IMPLEMENTATION STRATEGIES…………………………………………… 4-1 4.1 Focus of Efforts………………………………………………………….. 4-1 4.2 Implementation Responsibilities………………………………….. 4-1 4.3 Efforts to Reduce Air Pollution from Municipal Sources………………. 4-5 4.4 Other City Programs that Benefit Air Quality………………………….. 4-5 5.0 MEASUREMENT AND REPORTING…………………………………………. 5-1 5.1 Air Quality Indicators……………………………………………………. 5-1 5.2 Air Quality Reporting……………………………………………………. 5-1 5.2.1 Annual Ambient Air Quality Report……………………………. 5-1 5.2.2 Program Evaluation and Reporting……………………………… 5-2 GLOSSARY List of Tables List of Figures List of Appendices APPENDIX A – AIR QUALITY STATUS A.1 Ambient Air Quality A.1.1 Criteria Pollutants A.1.2 Local Monitoring Network A.1.3 Carbon Monoxide A.1.4 Ozone A.1.5 PM10 A.1.6 Fine Particles A.2 Other Air Quality Issues A.2.1 Greenhouse Gases A.2.2 Indoor Air Quality A.2.3 Visibility A.2.4 Wood Smoke A.2.5 Air Toxics A.2.6 Pesticides A.3 Air Quality Indicators A.3.1 VMT Growth A.3.2 Tailpipe grams per mile A.3.3 Total Motor Vehicle Emissions A.3.4 Commercial and Industrial Emissions A.3.5 Area-Wide Wood Smoke A.3.6 Indoor Air Quality A.4 Local Emissions Inventories A.5 Trends and Emerging Issues A.5.1 Ozone A.5.2 Shift in Primary Emissions Sources A.6 Citizen Perspective on Air Quality APPENDIX B – History of Fort Collins Air Quality Plan (to be completed) Fort Collins Air Quality Plan Draft – May 4, 2004 1-1 1.1 HOW TO USE THIS PLAN As an Element of City Plan (Fort Collins’ Comprehensive Plan), the Air Quality Plan (the Plan) sets forth principles and policies that guide the City’s efforts to improve air quality for the next five years. It combines and updates two previous City air quality documents; the 1993 Air Quality Policy Plan and the 2000-2003 Air Quality Action Plan. The policy chapter of the Air Quality Plan is adopted by City Council. The entire Air Quality Plan will be updated every five years in conjunction with updates to City Plan and the Transportation Master Plan. Air quality principles and policies contained in this plan apply across the whole City organization, but primary responsibility for implementation rests in the Natural Resources Department. The Plan will be used to guide the development of annual air quality staff work plans and budget requests. As part of that process, Natural Resources will evaluate progress on implementation of air quality policies each year. Corrections can be made as necessary, within the broad framework of the existing plan. Chapter One identifies the City’s role in air quality protection and summarizes the process used to develop this Plan. Chapter Two identifies air pollutant priorities and air pollution source priorities. Chapter Three contains all of the City’s air quality principles and policies. Some of these air quality policies (dealing with land use and transportation) are also contained in City Plan; some (dealing with commercial and residential sources, indoor air quality, and health) are just contained in this Plan. Chapter Three also restates the other Land Use and Transportation goals and policies contained in City Plan that support air quality improvement. Chapter Four outlines broad implementation strategies that will be used by air quality staff in the Natural Resources Department in working to achieve air quality principles and policies. Additional major initiatives conducted by other City departments that benefit air quality are also mentioned in this chapter. Chapter Five identifies the indicators that will be used to measure progress, and the frequency with which air quality information will be reported. Appendix A provides information about local air pollution sources, the status of air quality indicators identified in the last Air Quality Action Plan, and recent citizen perspectives on air quality. 1.2 FORT COLLINS ROLE IN PROTECTING AIR QUALITY It is worthwhile to ask why the City of Fort Collins needs an air quality plan, since few cities our size have one. There are two reasons, in sum: City residents have high expectations for a clean environment, and certain air quality problems and opportunities are best handled at the local government level. Fort Collins Air Quality Plan Draft – May 4, 2004 1-2 Survey data show that City residents rank air quality concerns among the high-priority issues for our community. Residents have identified the Air Quality Program as being the single most important program for protecting their future quality of life, according to a 2003 citizen survey. They also believe that the City has a responsibility, along with federal, state, and local health agencies, to maintain and improve air quality. Air quality programs at the federal, state, and local levels complement one another. The federal Clean Air Act (CAA) provides the template for air quality control nationally: set outdoor-air standards, monitor air quality, require improvement in non-attainment areas (areas that do not meet the standards), and monitor progress toward attainment. The federal role assures eventual compliance with outdoor-air standards, but it is inflexible and addresses only a handful of pollutants. Colorado state government is the focal point for efforts to attain the federal outdoor- air standards. It adopts and enforces regulations that limit smokestack and tailpipe emissions. It regulates regional haze, the use of prescribed fire, street sanding and acid deposition. Larimer County contracts with the state to provide local enforcement of air pollution permits, and to conduct investigations and monitoring. There is a growing recognition that local communities can play an important role in improving air quality. Federal, state, and county programs may leave gaps that can be filled by city programs. Innovations can be developed through local experimentation, which can then be picked up by other communities and by state and federal agencies. And some air quality concerns can only be addressed at the local level. The following examples illustrate the City’s air quality role. • Wood Smoke. Wood smoke from stoves and fireplaces impacts City residents directly, because the smoke is emitted and has adverse impacts within our residential neighborhoods, i.e., up-close and personal. Federal and State agencies responded by requiring that new wood stoves meet strict emission standards, a strategy to keep the problem from getting worse and to gradually reduce the problem of existing stoves as they wear out and are replaced by lower-emitting ones. To complement this long-term approach, the City assists neighborhoods to resolve wood-smoke complaints, advises stove and fireplace users how to burn wood with the least possible smoke, encourages replacement of older units through zero-interest loans, and has adopted regulations governing solid fuel (clean, dry, untreated wood only), banning new fireplaces, limiting smoke density, and making new stove standards enforceable through the City’s building code. • Ozone-depleting Compounds. The City became concerned about the global impact of ozone-depleting compounds such as refrigerants and about the failure of federal and state agencies to respond. Fort Collins joined with the Cities of Denver and Boulder, each adopting identical, local regulations requiring the capture and recycling of ozone-depleting compounds. Fort Collins’ ordinance was designed to sunset if and when the state regulated Fort Collins Air Quality Plan Draft – May 4, 2004 1-3 such compounds. The state has since adopted such regulations, which are enforced by the County Health Department. • Global Warming. Concerned about the impact that global warming could have on local government and about failure of the federal and state agencies to address global warming, the City partnered with the International Council for Local Environmental Initiatives to curb greenhouse gases locally. The City, along with 578 other local governments to date, adopted a local action plan containing a greenhouse gas reduction target and a detailed implementation plan to achieve it. • Non-Regulatory Efforts to Reduce Tailpipe Emissions. One of the strongest federal/state roles has been in reducing tailpipe emissions. The federal new motor vehicle control program has reduced emissions by over 90% since 1965, and the state’s emissions testing program has helped to curb excess emissions attributable to needed maintenance. The City complemented these efforts by boosting participation of students and commuters in the emissions testing program, helping to train automotive technicians to diagnose and repair emissions problems, and researching ways to encourage vehicle repair through incentives. The City seeks to reduce air pollution caused by its vehicle fleet by purchasing alternative- fuel and low-emission vehicles. • Transportation Demand Management. One set of air pollution strategies is reserved for local government alone – travel demand management and improving traffic flow. The City’s comprehensive plan, called City Plan, creates a vision of a city where travel by transit, walking and cycling are more attractive, and vehicle travel is less necessary, than they are today. The Transportation Master Plan provides for investment in alternative travel modes and the City’s SmartTrips program encourages residents to utilize them. Engineering and traffic operations managers are tireless in their effort to move traffic efficiently, which helps lower tailpipe emissions further. • Radon. Health risk from exposure to indoor radon has engendered a federal-state-local partnership. Based on guidelines and recommendations from the federal level, and with grant support and encouragement from the state, the City has addressed radon in a number of ways. These include research on local radon levels, public education to encourage home testing and remediation, low-cost test-kit sales, assuring that homebuyers are advised about radon, and requiring that new homes be built radon-resistant (ordinance pending). • Secondhand Smoke. Health risk from exposure to tobacco smoke spawned another partnership. Local health authorities and citizen groups targeted tobacco smoking as a priority issue. The City played a role in reducing exposure to second-hand smoke by restricting smoking in public places. Fort Collins Air Quality Plan Draft – May 4, 2004 1-4 In sum, Fort Collins has an air quality plan because there is: • a strong citizen mandate for the City to work towards air quality improvement, • a need and opportunity for City programs to complement federal, state, and county efforts, • a need to provide a long-term planning framework for air quality efforts, and • a need to recognize and coordinate the efforts of several City departments. 1.3 CONCEPTUAL APPROACH TO AIR QUALITY PLANNING The Air Quality Plan emphasizes emission reductions rather than ambient air quality standards and emphasizes key sources rather than key pollutants. This approach will be further detailed below. It is instructive to consider some history about the “traditional” approach to air quality planning. The federal Clean Air Act calls for U.S. EPA to set "National Ambient Air Quality Standards" for six pollutants. The states are required to implement emission reduction strategies tailored to bring ambient air quality in line with the standard throughout the state. Standards are based on available health effects data and are designed to "protect the public health with an adequate margin of safety." The six pollutants that have standards of this kind are carbon monoxide, particulates matter, ozone, nitrogen dioxide, sulfur dioxide, and lead. If air quality in the state is worse than the federal standard, then the state is required to submit a "State Implementation Plan" that specify how it would attain the standards. Today, however, we are confronted with new pollutants for which the old model (ambient standard followed by implementation plan) does not fit. For example: --Air toxics include many compounds that are known to contribute to cancer or respiratory disease but that do not have individual ambient air quality standards. --The Brown Cloud (visibility reduction) is primarily an aesthetic issue, although some components of the Brown Cloud can also affect health. --Carbon dioxide and other greenhouse gasses are important to the global environment but do not directly cause local heath effects. An ambient air quality standard would not be meaningful; rather a limit on total global carbon dioxide emissions is desired. We are also confronted with sources that emit several kinds of air pollution at once. For example, wood burning stoves and fireplaces produce carbon monoxide, particulates, air toxics, and contribute to the Brown Cloud. Similarly, automobiles produce all of these and greenhouse gasses as well. Therefore, if we were to follow the traditional approach and write separate control plans for each pollutant, they would overlap to a high degree. Furthermore, it is important to recognize the strengths and limitations of local government. The City of Fort Collins is not in a good position to monitor air quality for several new pollutants, nor could we credibly adopt our own local ambient air quality standards based on health effects research. Fort Collins Air Quality Plan Draft – May 4, 2004 1-5 What the City can do effectively is adopt policies and programs that reduce emissions from specific sources or source categories. Because of the limitations noted above, the Fort Collins Air Quality Plan was developed using a source reduction approach which is more suited to the City’s role in air quality protection. 1.3.1 Steps in the Planning Process 1. Assess current situation and status of air quality indicators. 2. Identify key pollutants 3. Identify key air pollution sources 4. Adjust policies to reflect pollutant and source priorities. 5. Design action strategies to achieve the air quality policies. 6. Establish air quality indicators to measure progress in achieving air quality policies. This planning approach has several advantages -- it is simple, direct, action-oriented, sets priorities, and takes advantage of the strengths and flexibility of local government. Once the key sources have been identified, the next steps concentrate on reducing their emissions rather than on specific types of pollution or health effects. “Indicators” are specific and measurable. Progress toward meeting them will be identified before the next update to the Air Quality Plan. Generally, indicators are targets the City is working to attain, but the City is not legally obligated to meet them. The exception is compliance with the national ambient air quality standards. Non-compliance with these standards invokes a regulatory process to identify and implement control measures intended to bring an area into compliance. 1.4 PLAN DEVELOPMENT PROCESS When originally created, the City’s Air Quality Plan consisted of a 10-year Policy Plan, adopted in 1993, and a 4-year Action Plan that was updated periodically. (See Appendix B for more detail.) Both documents were due to be updated in 2003-2004. In 2003, The City Manager agreed to a staff proposal to merge the two documents by creating the Air Quality Plan; a single, standalone document, updated every five years in sync with City Plan. The change was proposed to streamline the planning process and seek Council approval for only one document, instead of two. The change also elevates the level and frequency of air quality policy discussion. The change retains the positive aspects of both the Action Plan and the Policy Plan by providing a Council-reviewed outline for a prioritized course of action in a stand-alone document. At the same time, it allows more flexibility in annual staff work planning to take advantage of emerging opportunities to aid in achieving existing policies. More information about the steps in the planning process is presented below. Fort Collins Air Quality Plan Draft – May 4, 2004 1-6 1. Assess current situation and status of air quality indicators. In early 2003, data on the air quality indicators defined in the 2000-2003 Air Quality Action Plan were compiled. This information is presented in Appendix A. 2. Identify key pollutants In mid 2003, staff worked with the Air Quality Advisory Board Sub-Committee to select the list of pollutants to prioritize. One page summarizing current information was compiled for each pollutant. Air quality staff and the Air Quality Advisory Board conducted a forced-choice pairing exercise to identify priority pollutants. Ozone, fine particles, mobile source hazardous air pollutants, and greenhouse gases were identified as high priority pollutants. Indoor air pollutants, nitrogen oxides, PM10, industrial hazardous air pollutants, and carbon monoxide were identified as medium priority pollutants. Section 2.1 of this plan provides more information on this process. 3. Identify key air pollution sources During 2004, staff worked to compile updated emission inventory information, presented in Appendix A4 of this plan. Available emissions inventory data are not comprehensive, and are inconsistent as to area covered and pollutant categories, making it difficult to accurately assign high priority pollutants to sources. However, results generally indicate that local air pollution sources remain as: # 1 – Motor vehicles # 2 - Commerce and Industry # 3 – Residences 4. Adjust policies to reflect pollutant and source priorities. Air quality policies pertaining to transportation and land use were reviewed first, in coordination with updates to City Plan and Transportation Master Plan. Citizen perspectives on air quality issues (identified in recent surveys) were reviewed and considered, as well. Input was received from staff and consultants involved in the updates, as well as various Council advisory boards, especially the Air Quality Advisory Board. Relatively minor adjustments and reformatting occurred for these policies. These policies were advanced for public input and Council feedback through the City Plan outreach effort. Whereas all air quality policies were contained in the 1997 version of City Plan, it was directed that the new update to City Plan contain only those air quality policies having to do with transportation and land use. Next, other air quality policies dealing with commercial and residential sources and indoor air quality were reviewed. Again, relatively minor adjustments occurred to existing policies. A few policies that were outdated or had not previously been implemented were dropped. In a few instances, policy gaps were noted, and new policies were proposed. These included policies on non-road emissions, efforts to reduce ground level ozone precursors, and a policy Fort Collins Air Quality Plan Draft – May 4, 2004 1-7 identifying the City’s approach to addressing air quality -related health issues. Again, input was received from within the City and externally before these policies were revised. 5. Design action strategies to achieve the air quality policies. Broad action strategies for achieving the policies were then identified. The 2000-2003 Air Quality Action Plan was closely scrutinized for appropriate strategies to carry forward. Internet-based research was conducted, and new ideas were gathered from technical experts and from various advisory Boards. 6. Establish air quality indicators to measure progress in achieving air quality policies. Lastly, indicators were identified to help evaluate progress in achieving the policies. Many factors went into the consideration of indicators, including availability of data, cost of collecting new data, and what the data really indicate. One of the “EnLibra Principles”, shown below, was considered in the indictor selection process. (The EnLibra Principles were developed by the Western Governors Association to embrace balance and stewardship in the protection of air, land and water.) Reward Results, Not Programs – Move to a Performance-based System A clean, safe environment will best be achieved when government actions are focused on outcomes, not programs, and when innovative approaches to achieving desired outcomes are rewarded. Federal, state, and local policies should encourage “outside the box” thinking in the development of strategies to achieve desired outcomes. Solving problems rather than just complying with programs should be rewarded. Efforts were made to select indicators that measured true air quality benefits, rather than just program metrics. For example, measures of program performance such as number of brochures distributed or number of homes mitigated for radon do not directly identify whether an air quality benefit has been achieved. At the same time, discretion had to be exercised regarding the cost of collecting indicator data. Consequently, this plan contains a relatively small number of indicators. The plan also calls out the need to continue efforts to identify more meaningful indicators to help the City assess the true effectiveness of its air quality protection efforts. 1.5 PUBLIC INPUT Efforts were made throughout the development of this plan to involve affected interests. Numerous meetings were held with various City staff and consultants to the City Plan and Transportation Master Plan updates. In fact, air quality staff participated in the City Plan and Transportation Master Plan update processes which each had public outreach elements. A City Plan citizen’s advisory committee met to give input about City Plan from August 2002 to October 2003, several open houses were held and citizens were invited to comment on a website. Fort Collins Air Quality Plan Draft – May 4, 2004 1-8 Council advisory boards (Air Quality, Transportation, and Natural Resources) had opportunities to provide input to the Air Quality Plan at various points in the process. A Sub-Committee of the Air Quality Advisory Board was formed in April 2003, and met five times to provide input at various stages of the plan development. General public input was sought via the Internet in March and April 2004. Announcements about the Web-based comment opportunity were published in the May City News, and via a press release. More than 150 direct postcard mailings announcing the Web comment opportunity were sent to the following interest groups: • Interested citizens • Other local governments • Environmental groups • Health experts • Wood Smoke Complaint Line participants • Local air quality consulting firms • Technical experts • Construction firms • Bicycle retailers • Auto repair shops • Lawn and garden equipment retailers • Wood stove retailers • Radon testers and mitigators • Home builders • Board of Realtors Fort Collins Air Quality Plan Draft – May 4, 2004 2-1 2.0 PRIORITIZING AIR POLLUTANTS AND SOURCES Thanks in large part to federally mandated controls of air pollution emissions, air quality has generally been improving in Fort Collins over the past decade. Whereas Fort Collins violated the federal carbon monoxide standard throughout the 1980’s, we are now well in compliance with that standard. We currently do not violate any of the National Ambient Air Quality Standards. However, ground level ozone is one major exception to the improvement trend. Ozone levels have remained flat over the past two decades, with an increasing trend over the past four years. In fact, Fort Collins exceeded (not violated, due to how compliance is calculated) the new 8-hour ozone standard during the summer of 2003. Consequently, the City has joined with regional and state partners in shifting focus to work on reducing precursor emissions that form ground level ozone. Visibility, a measure of how the air looks, has seen minor improvements in Fort Collins in recent years, but we still violate the state’s guideline visibility standard one in four days each year. And residents of Fort Collins are well aware of the presence of the “Brown Cloud” in Fort Collins at certain times of year. Information on Fort Collins’ ambient pollution concentrations, air quality indicators, emission inventories and trends are presented in Appendix A, along with summaries of recent citizen perspectives on air quality. This information was used, in part, to prioritize air pollutants and pollution sources. This process is discussed in further detail in the following sections. 2.1 Priority Air Pollutants In the summer of 2003, air quality staff (6) and Air Quality Advisory Board members (6) undertook an exercise to rank the priority of air pollutants to aid in updating the air quality policies and strategies for Fort Collins. Staff developed the list of pollutants to be ranked, and reviewed it with the Air Quality Board Subcommittee working on the plan. One page of information about each pollutant was compiled and considered in the exercise. The following guidelines were used in the ranking exercise: 1) Health effects have priority over non-health effects (such as aesthetics or crop yield). 2) For pollutants with a standard, current non-compliance has priority over those in compliance. 3) Pollutants widely perceived as a problem in Fort Collins have priority over unknown pollutants. 4) Pollutants with an upward or uncertain emission trend have priority over those with a downward emission trend. Fourteen air pollutant categories were ranked using a “Forced Choice” method that requires selecting the higher priority pollutant of a pair, for every possible set of pairs. The overall priority is determined by the number of times a pollutant was selected as Fort Collins Air Quality Plan Draft – May 4, 2004 2-2 higher priority of a given pair. The division between High, Medium, and Low priority was determined by staff and Air Quality Board consensus using logical breaking points. Table 2.1 shows the final results. Table 2.1 2004 Fort Collins Priority Air Pollutants TOTAL Priority Pollutant SUM Level Ozone 127 High Fine particles (PM2.5) 124 High Mobile Source Hazardous Air Pollutants 122.5 High Greenhouse Gases 103.5 High Indoor Air Pollutants 90 Medium Visibility 88 Medium Nitrogen Oxides 80 Medium PM10 78 Medium Industrial Hazardous Air Pollutants 75 Medium Carbon Monoxide 73 Medium Sulfur Dioxide 35 Low Acid Deposition 33 Low Lead 33 Low Chlorofluorocarbons (CFC’s) 30 Low 2.2 Priority Air Pollution Sources Motor vehicles continue to be the number one source of local air pollution, as illustrated by Table 2.2 below. Within the next ten years, it is possible that non-road mobile sources will take over as the number one contributor to local air pollution, as discussed in Appendix A.5.2 of this plan. Table 2.2 Priority Fort Collins Emissions Sources (table will be improved for clarity) Pollutant Motor Vehicles Non- Road Point, Area, Other (Industry, Homes) Carbon Monoxide 84 % 11 % 5 % Fine Particles 49 % 51 % Volatile Organic Compounds 28 % 15 % 57 % Nitrogen oxides 40 % 24 % 36 % Carbon Dioxide (Greenhouse gas) 35 % ? 65 % Commercial and industrial sources are considered to be the second largest source of air pollution in Fort Collins. The Colorado Air Pollution Control Division evaluates and Fort Collins Air Quality Plan Draft – May 4, 2004 2-3 develops air permits for stationary sources in Colorado. They inspect sources to determine compliance with air regulations and permit conditions, and maintain a computerized inventory of air pollution emissions throughout the state. The City of Fort Collins has 172 permitted commercial air pollution sources. Collectively, residences are considered to be the third largest source of air pollution in Fort Collins. Residences can emit wood smoke into the outdoor air. Other residential activities, such as using and storing paints, cleaners, transferring fuel, using lawn and garden equipment and patio grills can allow harmful VOC’s to escape into the atmosphere. In addition, human exposure to indoor air pollution inside residences can occur. On average, humans spend 90% of their time indoors, and receive the majority of air pollution exposure indoors. Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 3-1 3.0 AIR QUALITY POLICY 3.1 Organization The City of Fort Collins Air Quality Plan is an element of City Plan, the City’s Comprehensive Plan, and as such provides the primary guidance for the City’s air quality protection efforts. A subset of air quality principles and polices that relate to land use and transportation are contained in City Plan, and are reiterated in this Air Quality Plan. Those policies are labeled “ENV”, exactly as they appear in City Plan. The Air Quality Plan also supplements City Plan by identifying additional air quality policies that address commercial and residential sources, indoor air quality and health protection. These air quality policies, not contained in City Plan, are labeled “AQ”. The relationship between air quality policies is illustrated in Figure 3.1 All air quality principles and policies are contained in this Air Quality Plan. City Council adoption of this chapter constitutes Council adoption of all policies contained herein. Figure 3-1. Air Quality Plan is an element of City Plan ENV Air Quality Plan AQ ENV CITY PLAN Policy Labels ENV = Environment AQ = Air Quality Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 3-2 3.2 AIR QUALITY VISION, GOALS, PRINCIPLES AND POLICIES Section 3.2 of the Air Quality Plan states all the air quality visions, goals, principles, and policies, including some repeated in City Plan (labeled ENV) and some only contained in this Air Quality Plan (labeled AQ). A note on definitions: As used in City Plan, a “goal” is both a beginning point for City efforts and an end towards which effort will be directed. Goals guide the community’s decisions about investment, development, and redevelopment, and act as milestones as progress is made towards the community vision. A “principle” is a general or fundamental rule, doctrine, or assumption. A “policy” is a definite course or method of action selected to guide and determine present and future decisions. 3.2.1 Air Quality Vision and Goals Our community will continually improve air quality as the city grows by applying strong, comprehensive policies and strategies to address air quality issues. The City will strive to reduce tailpipe emissions though clean technologies and by reducing the rate of vehicle miles traveled (VMT) by promoting a multi-modal transportation system that offers choices. The City will continue to invest in transit, walking, and cycling capacity and encourage residents to use alternative travel modes, to help shift travel choices toward alternatives that reduce air pollution and traffic congestion. 3.2.2 Air Quality Principles and Policies A note on numbering: Some of the principles and policies below are also contained in City Plan. These have an ENV- prefix and retain the numbering that they have in the City Plan document. The remaining principles and policies have and AQ- prefix. PRINCIPLE ENV-1: Continually improve Fort Collins’ air quality as the city grows. Policy ENV-1.1 Air Quality Plan. The City will adopt and implement a comprehensive Air Quality Plan that addresses the following issues: • Emissions from vehicles • Emissions from commerce and industry • Wood burning • Visual air quality • Certain indoor air pollutants and greenhouse gases Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 3-3 Policy ENV-1.2 City-Wide approach. The City's primary approach to improving air pollution is to reduce total city-wide emissions over the long term. The City’s secondary approach is to assure that localized air pollution exposures conform to adopted health standards. Policy AQ-1.3 Pollution Prevention. The City will promote prevention of air pollution at its source as the highest priority approach in reducing air pollution emissions. Policy AQ-1.4 Priority Pollutants. The City will focus its efforts on reducing high priority air pollutants including ozone, fine particles, mobile source hazardous air pollutants, and greenhouse gases, followed by efforts to reduce medium priority pollutants including indoor air pollutants, nitrogen oxides, PM10, industrial hazardous air pollutants, and carbon monoxide. Policy AQ-1.5 Toolbox of Approaches. The City will seek to achieve local air quality goals through education, incentives and price mechanisms, and regulation. Policy AQ-1.6 Measurement. The City will measure, review, and report the progress of key air quality indicators at least every five years, in advance of the Air Quality Plan update, to determine whether action strategies are having the desired effect or need to be amended. Policy AQ-1.7 Air Quality Information. The City will report available air quality information to the public on a frequent and regular basis. The City will assist citizens in finding existing air quality information that is of interest to them. Policy AQ-1.8 Enforcement. The City will support the provision of adequate responsibility, authority, and resources (funding and personnel) to agencies charged with the enforcement of federal, state, county, and local air quality regulations. Policy AQ-1.9 Local Authority. The City will oppose any action of the State Legislature that restricts local government authority to improve air quality beyond minimum State requirements, even as the City recognizes and supports the vital role of the State of Colorado in improving air quality. PRINCIPLE ENV-2: The City will reduce total motor vehicle emissions of high priority pollutants by focusing on both technology (tailpipe emissions) and behavior (driving patterns). PRINCIPLE AQ-2. Although VMT – the total number of miles driven in Fort Collins each day – is growing faster than population, the City’s long-term vision remains to reduce the VMT growth rate to the population growth rate. Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 3-4 Policy ENV-2.1 Actions on Vehicle Miles Traveled. The City will slow the growth of vehicle-miles of travel by employing strategies that reduce vehicle trip rates, reduce vehicle trip length, and increase vehicle occupancy. Policy ENV-2.3 Price Mechanisms. The City will use price mechanisms of the free market to help shift citizen and business choices toward actions that reduce vehicle miles traveled, including identifying and removing hidden cost subsidies to motor vehicle users, employing economic incentives and disincentives, and other market approaches. PRINCIPLE AQ-12. The City will reduce tailpipe and evaporative emissions from highway and non-road mobile sources. Policy ENV-2.4 Actions on Tailpipe Emissions. The City will employ strategies to reduce per-mile emissions such as promotion of car maintenance, mechanic training, encouraging use of alternative fuels, purchasing clean vehicles, use of clean lawn and garden equipment, prohibition of smoking vehicles, consideration of a local emissions testing and repair program, and reducing traffic delays. Policy AQ 12-1. Non-Road Emissions. The City will employ incentive programs and other strategies to reduce emissions from lawn and garden equipment, small and large construction equipment, and other non-road engines. PRINCIPLE ENV-3. By 2010 the City will reduce greenhouse gas emission 30% below predicted worst-case 2010 levels in order to reduce the impact of the Fort Collins community on global warming. Policy ENV-3.1. Local Action Plan. The City will adopt and implement a local action plan to reduce greenhouse gas emissions. Policy ENV-3.2. Biennial Report. The City Manager will prepare a biennial report outlining the City’s progress on achieving its greenhouse gas reduction goal and recommending future actions. PRINCIPLE AQ-13. The City will reduce commercial and industrial emissions in the Fort Collins Growth Management Area, focusing on priority pollutants. Policy AQ-13.1 Business Assistance. The City will offer programs and assistance to local businesses interested in reducing their environmental impacts such as the voluntary business Climate Wise program. PRINCIPLE AQ-14. The City will reduce residential emissions of priority pollutants in the Fort Collins Growth Management Area. Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 3-5 Policy AQ 14-1. Residential Wood Smoke. The City will reduce wood smoke emissions and the number of non-certified wood stoves and fireplaces in the Fort Collins GMA by, for example, insuring compliance with existing regulations, promoting alternatives to wood burning, and helping to resolve neighborhood wood smoke conflicts. Policy AQ-14.2 Ozone Reduction. The City will reduce evaporative emissions associated with residential activities (lawn mowing, fueling, paint selection and storage) by, for example, educating citizens and providing incentives. PRINCIPLE AQ-15. Recognizing the strong relationship between air quality and human health, the City will, within the scope of its ability, strive to protect and improve the air so it is healthy to breathe and free of levels of pollutants that harm human health. Policy AQ-15.1 Health Partnerships. The City will solicit the cooperation and active participation of a diverse range of knowledgeable health professionals and members of the environmental health community to guide the development of policies so that they reflect priority health issues. Policy AQ-15.2. Seek Solutions. The City will work to protect air quality by seeking solutions to high priority health-related air quality issues using already adopted health standards. Policy AQ-15.3 Air Toxics Coordination. The City will work with County, State and Federal health officials to reduce the health risks posed by toxic air pollutants. Policy AQ-15.4 Indoor Air Quality. Because a majority of air pollution exposure occurs indoors, the City will take actions to reduce residents’ exposure to indoor air pollution. PRINCIPLE AQ-16. The City will lead by example in efforts to improve local air quality. Policy AQ-16.1 Lead by Example. The City will make efforts to reduce and mitigate its own air pollution emissions before asking or requiring others to reduce and mitigate their emissions. Policy ENV-2.2 Actions on VMT. To reduce VMT, the City will encourage its customers to use telephone, Internet, or other methods to register for City offerings and purchase tickets. The City will also minimize the need for driving by organizing offerings with a neighborhood focus, so participants don’t have to travel long distances. Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 3-6 Policy AQ-16.2. Cooperation. The City will initiate and cooperate with other efforts to improve air quality, while avoiding unproductive duplication of effort. Others include government entities (other City departments, county, regional, state, national, global), the non-profit sector, businesses, and educational institutions. Policy AQ-16.3 Innovations. The City will consider adoption of successful air quality improvement strategies in effect elsewhere, including municipal practices, public information campaigns, incentives and price mechanisms, and regulations. 3.3 RELATED VISION, GOALS, PRINCIPLES, AND POLICIES This section restates other City Plan visions, goals, principles, and policies that, while not considered specific “air quality” policies, do support air quality improvement. 3.3.1 Related Vision and Goals Because most air pollution comes from motor vehicles, City Plan recognizes the importance of land use and transportation policies in helping to address air pollution from motor vehicles. These supporting policies are summarized in the following excerpt from the City Plan Community Vision: Fort Collins will confront and mitigate the negative impact of cars on our lives. The vision recognizes the importance of the automobile as a means of transportation, but begins to shift the balance towards a future in which different modes of transportation are also used. Our community will have an overall transportation systems and urban form the supports a wide choice and efficient ways to travel, thereby reducing the rate of growth of total daily vehicle miles of travel (VMT). Our Master Street Plan and Capital Improvement Program will support the land use goals of the City. New development and redevelopment will be organized and woven into a compact pattern that is conducive to pedestrian, bicycle, and public transit travel. All modes of travel will be safe and efficient. And, the importance of our community’s air quality, transportation, and land use goals will be balanced. Air quality is also listed among other issues in the City’s overall vision for the environment: Our community will be a responsible steward of the natural environment, such as improving air quality, water quality, conserving resources, and reducing solid waste. Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 3-7 3.3.2 Related Principles and Policies PRINCIPLE LU-1: Growth within the City will promote a compact development pattern within a well-defined boundary. Policy LU-1.1 Compact Urban Form. The desired urban form will be achieved by directing future development into mixed-use neighborhoods and districts while reducing the potential for dispersed growth not conducive to pedestrian and transit use and cohesive community development. PRINCIPLE LU-3: The City Structure Plan will be used to provide a geographic depiction of how these City Plan Principles and Policies are applied throughout the City. Note: The Structure Plan focuses on the physical form and development pattern of the city. It calls for a compact development pattern, directing urban development into well-defined areas at higher densities. An expanded transit system is incorporated in the Structure Plan, designed to provide high-frequency transit services along major travel corridors, with feeder transit lines providing connections from all major districts within the city. It establishes new activity centers in transit-served areas that serve as focal points and centers of activity, including Downtown and other mixed-use areas. The Structure Plan facilitates multiple means of travel: pedestrians, bicycles, and transit as well as cars and trucks. Street standards and site planning requirements will ensure that neighborhoods and districts throughout the city will be connected and accessible by all travel modes. PRINCIPLE CAD-1: Each addition to the street system will be designed with consideration to the visual character and the experience of the citizens who will use the street system and the adjacent property. Together, the layout of the street network and the streets themselves will contribute to the character, form, and scale of the city. PRINCIPLE CAD-2: Public spaces, such as plazas, civic buildings, outdoor spaces, parks, and gateway landscapes should be designed to be functional, accessible, attractive, safe, and comfortable. PRINCIPLE T-1: The physical organization of the City will be supported by a framework of transportation alternatives that balances access, mobility, safety, and emergency response throughout the City, while working towards reducing the rate of growth of vehicle miles traveled and dependence on the private automobile. Policy T-1.1 Land Use Patterns. The City will implement land use patterns, parking policies, and demand management plans that support effective transit, an efficient street system, and alternative modes. Appropriate residential densities Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 3-8 and non-residential uses should be within walking distance of transit stops, permitting public transit to become a viable alternative to the automobile. Policy T-1.2 Multi-Modal Streets. Street corridors will provide for safe, convenient, and efficient use of all modes of travel, including motor vehicles, transit, bicycles, and pedestrians. Policy T-1.6 Level of Service Standards. The City will prepare and adopt level of service standards for automobiles, bicycles, pedestrians, and transit. PRINCIPLE T-2. Mass transit will be an integral part of the city’s overall transportation system. PRINCIPLE T-3. City transportation programs shall address themselves to reduce vehicle miles of travel through strategies that reduce trip generation, reduce trip length, and increase vehicle occupancy. Policy T-3.1 Demand Management. The City will promote travel demand reduction measures that reduce automobile trips and promote alternative travel modes in which results can be measured – such as telecommuting and in-home businesses, electronic communications, variable work weeks, flextime, transit access, bicycle and pedestrian amenities, parking management, and trip reduction programs for large employers. PRINCIPLE T-4. Bicycling will serve as a practical alternative to automobile use for all trip purposes. PRINCIPLE T-5. The City will acknowledge pedestrian travel as a practical transportation mode and elevate it in importance to be in balance with all other modes. Direct pedestrian connections will be provided from places of residence to transit, schools, activity centers, work and public facilities. PRINCIPLE T-9. Private automobiles will continue to be an important means of transportation. Policy T 9.1 Vehicle Miles Traveled (VMT): The City will continually strive to reduce the growth rate in VMT by implementing a VMT reduction program that strives to meet or exceed the performance of similar programs in comparable cities. PRINCIPLE T-10. The City will participate in a coordinated, regional approach to transportation planning. Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 3-9 PRINCIPLE ENV-5. Energy efficiency and use of renewable energy resources will be encouraged, facilitated, and regulated in both the public and private sector through information and educational services, incentive programs, requirements, and enforcement of regulations such as the Energy Code. PRINCIPLE ENV 9. The City will continue to develop and implement sustainability practices that address long-term social, environmental, and economic considerations of the Fort Collins community. PRINCIPLE ENV-10: The City will apply cost-effective pollution prevention and zero-waste strategies that will help protect all environmental resources, including air, soil, and water and accelerate the community’s ability to meet the City’s adopted goal of diverting 50% of the waste stream from disposal in landfills by 2010. Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 4-1 4.0 IMPLEMENTATION STRATEGIES The Air Quality Plan is a policy and strategic planning document intended to serve as a guide for the City’s efforts to protect air quality over the next five years. The strategies discussed in this section lay a broad framework for the implementation of air quality policies. They provide a basis from which biennial budget recommendations are developed. They are not, however, intended to represent a complete work plan. More detailed annual work plans will be developed and reviewed internally for fit with over- arching air quality objectives. 4.1 Focus of Efforts The City’s Air Quality Plan continues to focus most action strategies on “sources” of air pollution, not individual pollutants. In that way, multiple benefits can be gained from attention to one source. Examples of action strategies that focus on one source and multiple pollutants include VMT reduction, promoting vehicle maintenance, vehicle emissions testing, reducing vehicle idling, reduced wood-burning, pollution prevention and green building efforts. Some efforts may focus on a particular pollutant, but reductions still result in multiple air quality benefits. One example is the voluntary Climate Wise business program. While the focus here is on achieving and documenting greenhouse gas reductions, any actions that reduce fossil fuel combustion also reduce other air pollutants. The Air Quality Plan also contains some strategies that target reductions in specific pollutants. Examples include actions intending to reduce human exposure to radon, and ozone education and incentive programs such as the “Stop at the Click” and the “Lawn Mower Trade Out”, aimed at reducing Volatile Organic Compounds (VOC’s). 4.2 Implementation Responsibilities The City of Fort Collins Natural Resources Department has the primary responsibility for implementing actions to achieve the City’s air quality principles and policies. Table 4.1 identifies broad actions areas to be implemented by Natural Resources Department staff. Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________4-2 Table 4.1 NRD Implementation Strategies Policy / STRATEGY Suggested Time Frame O3 PM2.5 Mobile HAPs GHG Other Policy ENV-1.1 Air Quality Plan. The City will adopt and implement a comprehensive Air Quality Plan • Update the Air Quality plan every five years. 2009 All Policy ENV 1.2 Area-Wide approach. The City's primary approach to improving air pollution is to reduce total area-wide emissions, over the long term. Its secondary approach is to assure that localized air pollution exposures conform to adopted health standards. • Evaluate hotspot potential for violation of air pollution standards. 2004 All Policy AQ-1.3 Pollution Prevention. The City will promote prevention of air pollution at its source as the highest priority approach in reducing air pollution emissions. • Develop and implement a Sustainability Action Plan 2004-2005 All • Explore enhanced pollution prevention opportunities with community partners (such as the Chamber of Commerce). 2005-2006 X Policy AQ-1-6. Measurement. The City will measure, review, and report the progress of key air quality indicators at least every five years, in advance of the Air Quality Plan update, to determine whether action strategies are having the desired effect or need to be amended • Prepare 5-year Air Quality Indicators Report 2007-2008 • Conduct biennial air quality survey to gather data on citizen views, actions, and emissions. ‘04, ‘06, ‘08 • Evaluate performance of peer cities VMT reduction programs and compare with Fort Collins program performance. 2005, 2008 X X X X Policy AQ-1.7 Air Quality Information. The City will report available air quality information to the public on a frequent and regular basis. The City will assist citizens in finding existing air quality information that is of interest to them. • Prepare Annual Ambient Air Quality Report Annually • Maintain air quality City Web pages to inform the public. On-going All Policy AQ-1.9 Local Authority. The City will oppose any action of the State Legislature that restricts local government authority to improve air quality beyond minimum State requirements, even as the City recognizes and supports the vital role of the State of Colorado in improving air quality. • Provide input on relevant bills at the State Legislature On-going Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________4-3 Policy / STRATEGY Suggested Time Frame O3 PM2.5 Mobile HAPs GHG Other Policy ENV-2.1 Actions on Vehicle Miles Traveled. The City will slow the growth of vehicle-miles of travel by employing strategies that reduce vehicle trip rates, reduce vehicle trip length, and increase vehicle occupancy. • Conduct Community Readiness study to identify the community’s readiness to embrace vehicle miles traveled (VMT) reduction efforts, followed by implementation of recommendations. Start 2004 X x X X X • Foster integrated solutions to land use, transportation, and air quality problems. On-going X x X X X • Evaluate whether a car-sharing program (where members have access to a fleet of local vehicles, but do not own the vehicles) would benefit Fort Collins’ air quality. 2005 or later X x X X X • Evaluate an Episodic Controls Program to establish high-pollution episodes based on visibility readings. The public would be informed of episodes and offered incentives to reduce driving (reduced bus fares, promotion of telework, etc.) 2005 or later X x X X X • Participate in regional transportation planning efforts to promote choices that improve air quality (i.e. the North I-25 Corridor Environmental Impact Statement). As needed X x X X X • Promote air quality education at schools; Facilitate teacher training (Clean Air Trunk; Cars, Cures, Cultures curricula) On-going X x X X X • Partner with SmartTrips to promote VMT reduction at schools. On-going X x X X X • Use the results of the peer cities VMT program study to help reduce performance gaps in Fort Collins program, if any exist. 2006 + X x X X X Policy ENV-2.3 Price Mechanisms. The City will use price mechanisms of the free market to help shift citizen and business choices toward actions that reduce vehicle miles traveled, including identifying and removing hidden cost subsidies to motor vehicle users, employing economic incentives and disincentives, and other market approaches. • Explore and implement price mechanisms of the free market to reduce VMT and single occupancy vehicle use. On-going X X X X X Policy ENV-2.4 Actions on tailpipe emissions. The City will employ strategies to reduce per-mile emissions such as promotion of car maintenance, mechanic training, encouraging use of alternative fuels, purchasing clean vehicles, use of clean lawn and garden equipment, prohibition of smoking vehicles, consideration of a local emissions testing and repair program, and reducing traffic delays. Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________4-4 Policy / STRATEGY Suggested Time Frame O3 PM2.5 Mobile HAPs GHG Other • Promote use of alternative fuels that improve air quality. Consider a regional workshop to evaluate the economics, availability of fuels, and feasibility of increasing alternative fueling infrastructure (i.e. BioDiesel and low sulfur fuel). On-going X X X X • Work to retain an emissions testing program that cost-effectively identifies and repairs high polluting vehicles. 2004, 2005 X X X • Conduct public education about the impacts of vehicle emissions, importance of car maintenance, benefit of purchasing of low emission fuel-efficient vehicles, and reduced idling. On-going X X X X X • Promote automotive technician training. On-going X X X X X Policy AQ 12-1. Non-Road Emissions. The City will employ strategies such as incentive programs to reduce emissions from lawn and garden equipment, small and large construction equipment, and other non-road engines. • Conduct incentive-based programs to reduce emissions from non-road sources such as a lawn mower rebate program. On-going X X • Evaluate City procurement guidelines for products and services that would reduce emissions from non-road sources. 2005 - 2006 X X Policy ENV-3.1. Local Action Plan. The City will adopt and implement a local action plan to reduce greenhouse gas emissions. • Work with other City departments to evaluate financing options for municipal energy efficiency. 2004 X X • Assist with adoption of Municipal Sustainable (building) Design Guidelines. 2004-2005 X X • Work with the City’s Energy Management Team to promote energy conservation and other green building practices through a variety of approaches including workshops, demonstration projects, and incentive-based or mandatory green building programs. On-going X X Policy ENV-3.2. Biennial Report. The City Manager will prepare a biennial report outlining the City’s progress on achieving its greenhouse gas reduction goal and recommending future actions. • Prepare biennial report on status of greenhouse gas reduction efforts and recommend future actions. 2005 2007 Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________4-5 Policy / STRATEGY Suggested Time Frame O3 PM2.5 Mobile HAPs GHG Other Policy AQ-13.1 Business Assistance. The City will offer programs and assistance to local businesses interested in reducing their environmental impacts such as the voluntary Climate Wise program. • Expand the City’s Climate Wise Program. (The Climate Wise program encourages greenhouse gas reductions by promoting energy efficiency, pollution prevention, and transportation reduction among Fort Collins businesses on a voluntary basis.) On-going X X Policy AQ 14-1. Residential Wood Smoke. The City will reduce wood smoke emissions and the number of non-certified wood stoves and fireplaces in the Fort Collins GMA by, for example, insuring compliance with existing regulations, promoting alternatives to wood burning, and helping to resolve neighborhood wood smoke conflicts. • Encourage “No Burning”, educate on clean burning practices, conduct Wood Smoke Response program. On-going X X • Offer zero-interest loans for removal or upgrade of non-certified stoves. On-going X X • Consider regulatory action to reduce wood smoke emissions if city-wide wood smoke continues to increase. 2006 + X X Policy AQ-14.2 Ozone Reduction. The City will reduce evaporative emissions associated with residential activities (lawn mowing, fueling, paint selection and storage) by, for example, educating citizens and providing incentives. • Provide public information on how to reduce evaporative emissions associated with residential activities, such as “Stop at the Click”, Mow When the Sun is Low”, etc. 2004-2007 X • Continue to offer incentives such as lawn mower rebate, gas can trade-in, and gas cap replacement as long as they remain cost-effective. On-going X Policy AQ-15.1 Health Partnerships. The City will solicit the cooperation and active participation of a diverse range of knowledgeable health professionals and members of the environmental health community to guide the development of policies so that they reflect priority health issues. • Foster relationships with health professionals. Start 2004 All Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________4-6 Policy / STRATEGY Suggested Time Frame O3 PM2.5 Mobile HAPs GHG Other Policy AQ-15.3 Air Toxics Coordination. The City will work with County, State and Federal health officials to reduce the health risks posed by toxic air pollutants. • Study EPA’s Community Air Toxics Assessment and Risk Reduction Strategies Database for approaches used in other communities (including diesel particulates). Develop and implement solutions if air toxics issues exist. Start 2004 X X X Policy AQ-15.4 Indoor Air Quality. Because a majority of air pollution exposure occurs indoors, the City will educate and encourage its residents to reduce their exposure to indoor air pollution. • Promote ZILCH loans (Zero Interest Loan for Conservation Help) for radon mitigation in existing dwellings (if > 4 pCi/l) On-going Radon • Process Radon Resistant New Construction Ordinance 2004 Radon • Explore radon mitigation for multifamily dwellings 2004 + Radon • Develop appropriate indicators for measuring success in reducing exposure to indoor air pollution, including radon. 2005-2006 Radon, Some, Others Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 4-7 4.3 Efforts to Reduce Air Pollution from Municipal Operations In accordance with Policy AQ-16.1 stating that the City should lead by example in efforts to reduce air pollution, there are a number of City goals and activities that reduce air pollution from municipal activities. A few of these are highlighted below. • Continue periodic pollution prevention audits of City facilities; Implement cost- effective recommendations. • Purchase one turbine of wind energy for City facilities. • Promote use of alternative-fueled original equipment vehicles, and high fuel efficiency vehicles in City fleet. • Strive achieve the goal of 75% of light duty City fleet vehicles meeting Ultra-Low Emission Vehicle standards by 2008. • Strive to achieve 15% reduction in City building energy use (per square foot) by building energy efficient buildings and installing energy efficient retrofits in existing buildings. • Continue best practices in street sanding and sweeping techniques to reduce airborne emissions. • City DriveLess program to encourage employees to reduce their own driving. 4.4 Other City Programs that Benefit Air Quality There are numerous other City programs and activities that support air quality improvement. Some of these other major program areas are discussed below. Electric Energy Supply Policy Fort Collins’ City Council adopted a new Electric Energy Supply Policy in March 2003. One of the primary objectives of the policy is to reduce the environmental impact of electricity generation through conservation, energy efficiency, load management and the increased use of renewable energy. The policy includes the following specific targets for energy conservation and renewable energy: o Reduce per capita electric consumption 10% from the baseline of 2002, by the year 2012. The10% per capita consumption reduction target will reduce overall electric consumption approximately 16% by 2012. o Work with Platte River Power Authority to increase the City's percentage of renewable energy to 2% by the end of 2004 and to 15% by the year 2017. These two strategies will significantly reduce greenhouse gas emission and will reduce power plant emissions associated with electricity generation, as well. City SmartTrips Program The City of Fort Collins has its own transportation demand management program, called SmartTrips. This program, identical in name to the TDM program of the North Front Range MPO, provides programs and services to make it easier for commuters to use other modes of travel rather than driving alone. The SmartTrips program goal is “to ease congestion on Fort Collins streets and improve air quality”. Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 4-8 This is accomplished through individual programs that focus on reducing VMT and increasing mode share of trips made by alternatives to the single occupant vehicle. The SmartTrips program conducts business and community outreach, transit promotion, bicycle and pedestrian outreach, and youth outreach. Advanced Traffic Management System During the past three years, the City has been installing an Advanced Traffic Management System, built a new Traffic Management Center to house the system and department, and upgraded nearly 16 miles of arterial roadway and the associated traffic signals to a fiber optic communication network. The total cost of designing, acquiring and installing/constructing the system was estimated to be just under 6 million dollars. The City had provided nearly 5 million dollars and the City was also awarded a Federal Highways Administration Intelligent Transportation System (ITS) grant for $994,205. The City has also partnered with CDOT to install 10 video monitoring cameras on 4 of the City arterials. The video images are monitored on an 8 screen video display system funded by Congestion Mitigation and Air Quality (CMAQ) funding. The video capabilities allows traffic staff to monitor traffic activity on the City arterials. Following equipment upgrades, signal timings of each street are revised and fine tuned. Signal timing work has been completed on College and Harmony in early 2003. As a result, accident numbers between 2002 and 2003 have decreased 9%. Recent studies also indicate that there is less motorist delay, fewer stops at red lights, and a reduction in vehicle emissions due to improved signal coordination. The City expects the same positive results as the other streets installed on the new system and are fine tuned. Building Energy Codes (To be completed) Hydrogen (To be completed) Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 5-1 5.0 MEASUREMENT AND REPORTING When measuring progress in protecting air quality, indicators are often used. One indicator can reflect trends in multiple pollutants. Indicators can provide an assessment of the current situation and, in some cases, provide a measurement of parts of the problem that are within our control. This section identifies air quality indicators that will be used to assess air quality status, evaluate progress, and guide the direction of future actions when the Air Quality Plan is next updated. Additional indicators may be added to this list if appropriate, such as indicators of mobility, radon risk, air toxics risk, and City investment in alternative modes. 5.1 Air Quality Indicators Table 5.1 Air Quality Indicators Indicator Unit Desired Direction Compliance with National Ambient Air Quality Standards Specific to each pollutant No violations Ambient Air Pollution Levels Trend over time Declining concentrations Visibility Standard Trend over time Improving compliance VMT growth rate Annual growth rate (%) Decreasing VMT growth rate compared to population growth rate Annual growth rate (%) Decreasing gap between the growth rates VMT reduction program performance NA Meet or exceed performance of comparable cities VMT reduction program Fleet average tailpipe emissions Grams per mile as estimated by EPA’s Mobile Model Reductions over previous years Commercial and Industrial Emissions Tons Per Year Reductions over previous years Greenhouse Gas Emissions Citywide emissions of CO2e (tons per year) Reductions over previous years Wood smoke emissions City-wide emissions (tons per year) Reductions over previous years Non-certified wood stoves Number of non-certified units in the City, based on local survey data Decrease in number of non- certified wood stoves Fort Collins Air Quality Plan Draft – May 4, 2004 ________________________________________________________________________ 5-2 5.2 Air Quality Reporting 5.2.1 Annual Ambient Air Quality Report On an annual basis, City staff will produce a brief report showing the status of ambient air quality measurements from Fort Collins monitors, including ozone, carbon monoxide, PM10, PM2.5, and visibility. This report will be sent to City Council and posted on the City’s Web site. The City will also prepare a brief annual summary of activities undertaken to protect air quality and submit this to City Council. 5.2.2 Program Evaluation and Reporting The Air Quality Plan will be updated every five years, in conjunction with updates of City Plan and the Transportation Master Plan. One year prior to the next update of the Air Quality Plan, the status of all air quality indicators will be evaluated and reported. This data will be used to determine whether modifications to policies and implementation strategies are warranted in the next update of the Air Quality Plan. Fort Collins Air Quality Plan Draft – May 4, 2004 A-1 A.1 AMBIENT AIR QUALITY This appendix provides comprehensive information about the status of local air quality. Air quality can be evaluated in several different ways. Often, air pollution levels in the outside air (ambient concentrations) are measured and reported. Ambient air measurements are a function of the amount of pollution emitted, the chemistry of the pollutants, the weather, and the location of the monitoring site. In the absence of ambient air quality data, emissions inventories are sometimes used to make an estimate of how much pollution is emitted into the air. These estimates are based on many factors, including actual monitored readings from emissions stacks, levels of industrial activity, fuel consumption, vehicles miles traveled, and other activities that cause pollution. When measuring progress in protecting air quality, indicators are often used. Indicators are a useful measure because they typically focus on parts of the problem that are within our control. One indicator can reflect trends in multiple pollutants. A.1.1 Criteria Pollutants The U.S. EPA has established National Ambient Air Quality Standards (NAAQS) for six pollutants, known as “criteria” pollutants. They are carbon monoxide, ozone, nitrogen dioxide, sulfur dioxide, particulate matter, and lead. Primary standards are designed to protect human health and secondary standards to protect human welfare. The NAAQS are listed in Table A-1 on the next page. A.1.1 Local Monitoring Network In Fort Collins, compliance monitoring is conducted for four of the criteria pollutants; carbon monoxide, ozone, PM10 and PM2.5. In addition, monitoring for compliance with the Colorado visibility standard is also conducted. The monitoring sites are operated and maintained by the Colorado Department Public Health and Environment (CDPHE) and the Larimer County Health Department. Monitoring for carbon monoxide, ozone, and meteorology conditions occurs on CSU’s campus, at the intersection of Laurel and Mason Streets. Monitoring for PM10 and PM2.5 is conducted on the roof of the CSU Facilities Building. These sites are intended to represent “neighborhood” scale exposure. A second carbon monoxide monitoring site was installed on South College avenue, adjacent to Target, in November 2002. This site is intended to represent worst case (micro-scale) conditions. Visibility monitoring records optical properties of the atmosphere between the monitoring sites located at Holiday Inn on Prospect and the DMA Tower at Olive and Remington. Figure A-1 shows the locations of monitoring sites in Fort Collins. Fort Collins Air Quality Plan Draft – May 4, 2004 A-2 Table A.1 National Ambient Air Quality Standards Pollutant Primary Stds. Averaging Times Secondary Stds. 9 ppm (10 mg/m3) Carbon Monoxide 8-hour1 None 35 ppm (40 mg/m3) 1-hour1 None Lead 1.5 µg/m3 Quarterly Average Same as Primary Nitrogen Dioxide 0.053 ppm (100 µg/m3) Annual (Arithmetic Mean) Same as Primary Particulate Matter 50 µg/m3 Annual2 (Arith. Mean) Same as Primary (PM10) 150 ug/m3 24-hour1 Particulate Matter 15 µg/m3 Annual3 (Arith. Mean) Same as Primary (PM2.5) 65 ug/m3 24-hour4 Ozone 0.08 ppm 8-hour5 Same as Primary 0.12 ppm 1-hour6 Same as Primary 0.03 ppm Annual (Arith. Mean) ------- 0.14 ppm 24-hour1 ------- Sulfur Oxides ------- 3-hour1 0.5 ppm (1300 ug/m3) 1 Not to be exceeded more than once per year. 2 To attain this standard, the expected annual arithmetic mean PM10 concentration at each monitor within an area must not exceed 50 ug/m3. 3 To attain this standard, the 3-year average of the annual arithmetic mean PM2.5 concentrations from single or multiple community-oriented monitors must not exceed 15 ug/m3. 4 To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor within an area must not exceed 65 ug/m3. 5 To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.085 ppm. 6 (a) The standard is attained when the expected number of days per calendar year with maximum hourly average concentrations above 0.12 ppm is <= 1, as determined by appendix H. (b) The 1-hour standard is applicable to all areas notwithstanding the promulgation of 8-hour ozone standards under Sec. 50.10. On June 2, 2003, (68 FR 32802) EPA proposed several options for when the 1-hour standard would no longer apply to an area. Fort Collins Air Quality Plan Draft – May 4, 2004 A-3 Figure A.1 Location of state-run monitoring sites in Fort Collins (coming soon) Fort Collins Air Quality Plan Draft – May 4, 2004 A-4 Figure A.2 Fort Collins CO, O3 and Meteorology Monitoring Site; Laurel & Mason Figure A.3 Fort Collins CO Monitoring Site, South College at Target A.1.3 Carbon Monoxide Carbon monoxide (CO) is a tasteless, odorless, colorless, poisonous gas produced by incomplete combustion. Carbon monoxide affects the central nervous system by depriving the body of oxygen, especially persons with cardiac or respiratory problems, the elderly and pregnant women. Fort Collins Air Quality Plan Draft – May 4, 2004 A-5 The primary source of CO is incomplete combustion of fossil fuels used for transportation and heating. In Fort Collins, approximately 85% of the CO comes from motor vehicles and 10% comes from woodburning. Other sources include refuse and agricultural burning, natural forest fires, and by-products from some industrial sources. CO tends to build up when shallow cold air masses are trapped close to the ground by warmer air masses above and by the mountains to the west. These temperature inversions occur most commonly during fall and winter months. The primary National Ambient Air Quality Standard (NAAQS) for CO is 9 ppm (parts per million) averaged over an eight hour period and 35 ppm averaged over a one hour period. There are no secondary CO standards. The EPA allows no more than one exceedance of the standard per year for any given location. Subsequent exceedances constitute violations of the NAAQS. Exceedances of the 8-hour standard are the target of control efforts, as 1-hour values are highly dependent upon meteorological variations. Throughout the 1980’s, Fort Collins violated the carbon monoxide standard numerous times. The City was designated a “non-attainment area” by the U.S. EPA, and a State Implementation Plan was developed to help bring carbon monoxide levels down. Federal new car emissions standards played a major role in reducing carbon monoxide levels, assisted by the emissions testing program. The carbon monoxide standard was last violated in 1991, as illustrated in Figure A4. In 2002, the EPA approved a Carbon Monoxide Maintenance Plan for Fort Collins. Through air quality modeling, the Maintenance Plan proves that the city is not expected to violate the carbon monoxide standard for at least the next 15 years. Figure A.4 Carbon Monoxide Levels in Fort Collins, Laurel & Mason CO data show downward trend 6 3 77 33 1 0 3 000000000000 11 10 5 2.2 3.5 3.0 3.8 5.1 4.1 14 13 11 12 16 10 13 14 11 8 7 9.8 6.9 6.6 6.0 5.2 5.1 5.2 Fort Collins Air Quality Plan Draft – May 4, 2004 A-6 Figure A.5 Carbon Monoxide Levels; 4417 South College Figure A.6 Comparison of North and South Carbon Monoxide Levels Scatter Plot (Old vs. new site) Carbon Monoxide Concentrations Winter Months: Dec '02 thru Nov '03 0 0.5 1 1.5 2 2.5 3 3.5 00.511.522.533.5 S. College (new) Daily 8 hr Max ppm CSU (Old) Daily 8 hr. max ppm Fort Collins CO Measurements Winter Months: Dec'02-Mar '03, Nov '03 0 0.5 1 1.5 2 2.5 3 3.5 PPM South site (Target) North Site (CSU) South Site Avg = 1.22 ppm North Site Avg = 0.82 ppm South max = 2.3 North max = 2.9 Fort Collins Air Quality Plan Draft – May 4, 2004 A-7 Figures A.4 and A.5 show that the long-term “neighborhood scale” monitoring site at Laurel and Mason continues to represent the maximum concentrations, despite not being the highest traffic volume intersection. This finding was also corroborated in 1987/1988, when a second CO monitor was placed at the intersection of College and Drake, then the highest traffic intersection. Data from that study, funded by CDPHE, also showed that the Mason and Laurel location had the higher values during the critical CO period (between 4 p.m. and midnight). A.1.4 Ozone (O3) Ozone (O3) is a highly reactive form of oxygen. At normal concentrations, ozone is colorless and odorless. At high concentrations, it is an unstable bluish gas with a pungent odor. Ground level ozone at high concentrations is considered an air pollutant, and is a major component of photochemical smog. Ground level ozone should not be confused with stratospheric ozone in the upper atmosphere (12 - 30 miles above the ground), which is positive and critical for absorbing cancer-causing ultraviolet radiation. Ozone is a secondary pollutant formed when nitrogen oxides and hydrocarbons react in the presence of sunlight. Hydrocarbons come from automobile exhaust (and also some vegetation) and nitrogen oxides come from high temperature fuel combustion. The reactivity of ozone causes health problems because it damages lung tissue, reduces lung function, and increases the sensitivity of the lungs to other irritants. Ozone can also act as an irritant to the mucous membranes of the eyes and throat and can reduce immune system capacity. Scientific evidence suggests that ozone affects not only individuals with respiratory problems, but also affects healthy adults and children. In high concentrations, ozone causes damage to plants and deteriorates materials such as rubber and nylon. In July 1997, EPA promulgated a new standard for ozone. EPA has replaced the previous 1-hour primary ozone standard with a new 8-hour standard to protect against longer exposure periods. The new, more stringent 8-hour ozone standard is 0.80 ppm. Compliance with the standard is determined if the three-year average of the fourth highest annual value does not exceed 0.085. Fort Collins is approaching violation of the new eight-hour ozone standard, as illustrated in Figure A.7. As of 2003, Fort Collins is at 82 percent of the eight-hour standard. Other locations in the North Front Range, particularly Greeley and Rocky Mountain National Park are even closer to violating the standard, as shown in Figure A.8. Ozone has become the pollutant of top concern along the Front Range in the past few years. More discussion of the ozone issue can be found in the Issues and Trends section of this appendix. Fort Collins Air Quality Plan Draft – May 4, 2004 A-8 Figure A.7 Fort Collins Eight Hour Ozone Levels Figure A.8 Northern Colorado Eight Hour Ozone Levels A.1.5 PM10 Particulate matter refers to tiny particles of solid or semi-solid material suspended in the atmosphere. This includes particles between 0.1 micron and 50 microns in diameter. Particles larger than 50 microns tend to settle out quickly due to gravity. Fort Collins 8-Hour Ozone 0.000 0.010 0.020 0.030 0.040 0.050 0.060 0.070 0.080 0.090 1996 1997 1998 1999 2000 2001 2002 2003 PPM 4th Max 3 yr Avg. NAAQS (ytd) .085 ppm 8-hour Ozone --- 4th Max. Northern Colorado 0.040 0.060 0.080 0.100 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 Year ppm RMNP Ft. Collins Greeley Weld Co. Twr. thru 8/3 8-hr. standard = 0.08 ppm Fort Collins Air Quality Plan Draft – May 4, 2004 A-9 Particulates with diameters less than 10 microns or less (PM10) are considered inhalable and are associated with respiratory health impairment. Other impacts of particulates include visibility degradation, vegetation damage and climate change. Elevated particulate levels can occur in urban and rural areas, mountain valleys, and high wind areas. Sources include roadways, fields, construction, automobile exhaust and wood burning. PM10 has been monitored in Fort Collins since 1986, where levels have decreased steadily and remain well below the standards of 150 ug/m3 24 hour average and 50 ug/m3 annual. However, concentrations could rise with increased traffic. Figure A.9 PM10 Levels in Fort Collins A.1.6 Fine Particles (PM2.5) PM2.5 refers to particulate matter that is 2.5 microns or less (approximately 1/20 the diameter of a human hair), also called "fine" particles. Fine particles are typically secondary aerosols that form when chemical reactions occur between sulfate (from power plants) or nitrate (from industry and motor vehicles) and ammonia (from feedlots) and carbon. The health risk from particulates is a function of the size and concentration of the dose inhaled. PM2.5 can be respired deeply into the alveoli of the lungs, where they remain for a long time and can cause the greatest amount of damage. Particulate matter can reduce lung functioning and can cause or aggravate respiratory conditions, and increase the long term risk of lung cancer or other lung disease such as emphysema, bronchiectasis, pulmonary fibrosis, and cystic lungs. PM10 data show downward trend 67 47 53 29 43 23 25 22 22 22 22 20 16 16 16 16.819.99419.8 110 88 84 60 52 59 62 51 57 61 40 34 41 46 36 30 29 0 20 40 60 80 100 120 140 160 86 87 88 89 90 91 Fort Collins Air Quality Plan Draft – May 4, 2004 A-10 Fine particles also cause visibility impairment, thus affecting human welfare. PM2.5 have the greatest impact on visibility reduction because of their ability to scatter light. Much of Denver's infamous "brown cloud" is caused by fine particles. In July 1997, EPA established two primary PM2.5 standards set at 15 µg/m3 (annual arithmetic mean) and 65 µg/m3 (24-hour average), to provide increased protection against the PM-related health effects found in the community studies. EPA's scientific review concluded that fine particles are a better surrogate for those components of PM most likely linked to mortality and morbidity effects at levels below the previous standards, while high concentrations of coarse fraction particles are linked to effects such as aggravation of asthma. PM2.5 monitoring, which began in Fort Collins in the spring of 1999, shows that levels are well below the 24 hour and annual standard. Figure A.10 Fort Collins PM2.5 Levels The North Front Range Air Quality Study sampled fine particles (PM2.5) on select winter high pollution days in 1996/1997 in Fort Collins. A source apportionment study found that ammonium nitrate (a secondary aerosol) is the largest contributor to fine particles. The study attributes the ammonium nitrate to nitrogen oxides produced primarily by mobile sources. The second largest source of fine particles comes directly from mobile source exhaust, which accounts for 29% of PM2.5, as shown in Figure A.11. Fort Collins PM2.5 24 Hour max 0 10 20 30 40 50 60 70 '99 '00 '01 '02 '03 ug / m3 Fort Collins Air Quality Plan Draft – May 4, 2004 A-11 Figure A.11 NFRAQS Data A.2 OTHER AIR QUALITY ISSUES A.2.1 Greenhouse Gases Human activities have altered the chemical composition of the atmosphere through the buildup of greenhouse gases – primarily carbon dioxide, methane, and nitrous oxide. The heat-trapping property of these gases is undisputed although some uncertainties exist about exactly how earth's climate responds to them. According to the National Academy of Sciences, the Earth's surface temperature has risen by about 1 degree Fahrenheit in the past century, with accelerated warming during the past two decades. There is new and stronger evidence that most of the warming over the last 50 years is attributable to human activities. The Intergovernmental Panel on Climate Change (IPCC), a group of over 2,500 of the world's climate scientists, is predicting that these impacts may include: • elevated global average temperatures with a resulting disruption of natural systems • changes in precipitation rates in many regions impacting on water supply and food production • increase in the incidence and intensity of extreme weather events, such as floods, blizzards, tornadoes, and droughts • rise in sea level impacting on coastal areas and low-lying regions Scientists also anticipate climate change will detrimentally affect cities and urban areas. Regional temperature rises will foster more smog. Changes in precipitation will adversely affect urban water supplies. An increase in extreme weather events will cause damage to urban infrastructure; and sea level rise will eventually inundate infrastructure and Fort Collins PM2.5 Source Apportionment NFRAQS, 1998 Gasoline Exhaust 18% Diesel 11% Ammonium Nitrate 30% Dust, Debris 19% 0% Meat/Wood 8% Ammonum Sulfate 8% Power Plant 2% Other 4% Fort Collins Air Quality Plan Draft – May 4, 2004 A-12 settlements in many coastal cities. Local governments, therefore, have plenty of reason to act to avoid the long-term local risks of climate change. Recognizing that local government actions to reduce greenhouse gases such as energy conservation, trip reduction, and waste reduction can provide multiple local benefits such as decreased air pollution, increasing landfill life, and saving money, in 1999, the City adopted a target to reduce citywide greenhouse gas emissions 30% below worst case 2010 levels. As of 2001, citywide reductions equaled 10% of total emissions. Figure A.12 Fort Collins Greenhouse Gas Reductions in 2001 The City’s Energy Management Team, tasked with implementing the City’s Local Action Plan to Reduce Greenhouse Gases, prepares a biennial report on progress to date and recommend future actions. A.2.2 Indoor Air Quality Indoor air quality is of concern because indoor air is often more polluted than outdoor air and ninety percent (90%) or more of each day is spent in our home, school, workplace, or car. Sources include asbestos from insulation, biological pollutants including molds, carbon monoxide from appliances and heaters, formaldehyde from pressed wood products and building materials, household cleaning products, personal care products, hobby products, lead from old paint and pipes, pesticides, radon gas escaping from basement soils, and smoking cigarettes. The likelihood of immediate reactions to indoor air pollutants depends on several factors including age and preexisting medical conditions, and can include irritation of the eyes, nose, and throat, headaches, dizziness, and fatigue. Other health effects may show up either years after exposure has occurred or only after long or repeated periods of exposure. These effects, which include some respiratory diseases, heart disease, and GHG Reductions (Actual and Target) 0 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 2001 2010 1,000 tons CO2e Reductions Emissions 10% reduction 30 % reduction Target Actual Fort Collins Air Quality Plan Draft – May 4, 2004 A-13 cancer, can be severely debilitating or fatal. There is considerable uncertainty about what concentrations or periods of exposure are necessary to produce specific health problems. Radon is a naturally occurring gas that is produced in the soil when uranium decays. Radon is the second leading cause of lung cancer. EPA has designated Fort Collins a ”high” radon zone. Short-term radon test results in homes indicated that 70% of Fort Collins’ homes have levels above 4 pCi/l. This is the level at which EPA recommends taking action. For years, the City of Fort Collins has offered low cost radon test kits and provided home buyers with radon information. Currently City Council is considering requiring radon mitigation systems to be installed in new homes. Regarding secondhand smoke, numerous studies have found that tobacco smoke is a major contributor to indoor air pollution, and that breathing secondhand smoke is a cause of disease, including lung cancer, in non-smokers. The City of Fort Collins’ role in indoor air quality involves education, incentive, and regulation. General indoor air quality information is provided to the public through brochures, the Web, and community events. The City sells reduced price short-term radon test kits, and offers workshops for radon mitigators. Zero-interest loans are available to low income residents for radon mitigation systems. Starting October 2003, the City has prohibited smoking in all public places with a few minor exceptions. A.2.3 Visibility “Visibility" is a measure of how the air looks. It can be described as the maximum distance that an object can be perceived against a background sky. Visibility also can refer to the clarity of objects in the distance, middle or foreground. Visibility is unique among air pollution effects because it involves human perception and judgment. Along the Front Range, visibility impairment is caused primarily by fine particles (0.1 - 2.5 microns in diameter). Particles this size either scatter or absorb light. Fine particles typically include secondary aerosols and carbon. Secondary aerosols are tiny gas and/or liquid droplets that are formed by chemical reactions between sulfate or nitrate and ammonia. Sulfates are formed when sulfur dioxide (from electric power generation) oxidizes, and nitrates are formed when nitrogen oxides (from vehicle emissions and other high temperature combustion processes) oxidizes. Elemental and organic carbon are most effective at absorbing light. Human-caused sources of fine carbon particles include woodburning, emissions from cars, trucks, and buses, and soot from burning fields. Visibility is also degraded by ground level ozone, a photochemical oxidant which contributes to haziness in high concentrations. Ozone is formed when nitrogen oxides and volatile organic compounds (from motor vehicles and industry) combine with sunlight. In 1986, the Colorado Air Quality Control Commission established a visibility standard for Fort Collins and other Front Range cities. The visibility standard is .076 per kilometer of atmospheric extinction, which means that 7.6% of light in a kilometer of air Fort Collins Air Quality Plan Draft – May 4, 2004 A-14 is blocked. The standard equates to a visual range of 32 miles. The standard applies between the hours of 8:00 a.m. and 4:00 p.m., and only when the relative humidity is less than 70 percent. Monitoring for the state visibility standard is not required and there is no penalty for non-compliance. As of October 1998, only two urban areas in the state (Denver and Fort Collins) measure compliance with the State’s visibility standard. Figure A.13 Fort Collins Compliance with Visibility Standard Based on available data, Fort Collins complies with the visibility standard just over half the time. On average, Fort Collins violates the guideline visibility standard twenty-four percent of the time, or roughly one in four days. On average, twenty-four percent of the data are missing, due largely to days with relative humidity greater than 70%, or occasionally due to calibration or malfunction of the monitoring equipment. A.2.4 Wood Smoke Wood smoke is a complex mixture of substances produced during the burning of wood. The major emissions from wood stoves are carbon monoxide, organic gases (containing carbon or derived from living organisms), particulate matter, and nitrogen oxides. Wood smoke contains many organic compounds known to cause cancer (such as benzopyrenes, dibenzanthracenes, and dibenzocarbazoles), and other toxic compounds (such as aldehydes, phenols, or cresols). The particulate fraction is composed of solid or liquid organic compounds, carbon char (elemental or soot carbon – similar to charcoal), and inorganic ash. Fort Collins Visibility 0 10 20 30 40 50 60 70 80 90 100 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 Percent In Compliance Not in Compliance Average 52% In Compliance Average 24% not in compliance Fort Collins Air Quality Plan Draft – May 4, 2004 A-15 The particles in wood smoke are too small to be filtered by the nose and upper respiratory systems, so they wind up deep in the lungs. Wood smoke exposure causes a decrease in lung function and an increase in the severity of existing lung disease with increases in smoke concentrations or exposure time. Although wood smoke potentially affects everyone, children, people with respiratory diseases and the elderly are more likely to be affected. On average, wood smoke emissions have been declining in Fort Collins based on citizen survey data. Figure A.14 Fort Collins Carbon Monoxide Emission from Wood Smoke A.2.5 Air Toxics The 1990 CAAA address a large number of air pollutants that are known to cause or may reasonably be anticipated to cause adverse effects to human health or adverse environmental effects. 188 specific pollutants and chemical groups were initially identified as hazardous air pollutants (HAPs), and the list has been modified over time. CDPHE’s “2001 Report of Urban Air Toxics in Denver” states that the majority of urban air toxics detected in Denver’s air can be attributed to auto emissions. Of the few compounds measured that have EPA toxicity benchmarks, formaldehyde, acetaldehyde, 1,3 butadiene, benzene, and carbon tetrachloride are present in Denver’s air at levels that may pose health problems. Fort Collins’ mobile source toxic emissions may be similar in composition, although perhaps lower in concentration. HAPS are also emitted by major industrial facilities and power plants as well as from small sources like dry cleaning, gas stations, and auto body painting shops. According to CDPHE’s database on permitted sources, local HAPs emissions have declined drastically since 2000. This may be due to new control technology standards or due to increased awareness of HAPs emissions because of the Title V permitting program. Fort Collins Wood Smoke CO Emissions 2975 1367 1247 1135 691 915 0 500 1000 1500 2000 2500 3000 3500 1984 1990 1994 1996 1998 2002 CO TPY Fort Collins Air Quality Plan Draft – May 4, 2004 A-16 Figure A.15 Fort Collins HAP Emissions The Toxics Release Inventory (TRI) is a publicly available EPA database that contains information on toxic chemical releases and other waste management activities reported annually by certain covered industry groups as well as federal facilities. Information is based on monitor data or estimates, and reflect emissions levels, not public exposure levels. Table A.2 shows 2000 TRI data for Fort Collins. Table A.2 2000 TRI Data for Fort Collins Zip Code # of reporting sources On- and Off-site emissions in 2000 (lbs) 80521 0 NA 80524 2 0 80525 1 Ethylene glycol = 306 lbs Hydrogen Fluoride = 166 lbs 80526 0 NA According to Environmental Defense’s “ScoreCard” Web page evaluating HAPS, diesel emissions are the HAPS that pose the greatest cancer risk in Larimer County. The Web site states that mobile source HAPS contribute 93% of all “contribution to added cancer risk” in Larimer County. Table A.3 HAP Risk in Larimer County Contribution to added cancer risk Contribution to cumulative hazard index “Industrial” (Point & area sources) 7 % 46% Mobile Sources 93 % 54% Source:Environmental Defense’s “ScoreCard” (http://www.scorecard.org/envreleases/hap/county.tcl?fips_county_code=08069#hazards) Fort Collins HAPS Emissions 21.6 3.7 3 32.7 33.3 6.2 4.9 0 5 10 15 20 25 30 35 1996 1997 1998 1999 2000 2001 2002 TPY 6 8 11 7 5 58 The # in each bar represents the # of sources reporting that year Fort Collins Air Quality Plan Draft – May 4, 2004 A-17 A.2.5 Pesticides All pesticides are regulated under the Federal Insecticide and Rodenticide Act (FIFRA) of 1972. Pesticides include herbicides, biocides, slimicides, etc. FIFRA requires that before selling or distributing a pesticide in the Unites States, a person or company must obtain a registration or license from the EPA. Before registering a new pesticide or new use for a registered pesticide, EPA must first ensure that the pesticide, when used according to label directions, can be used with a reasonable certainty of no harm to human health and without posing unreasonable risks to the environment. To make such determinations, EPA requires more than 100 different scientific studies and tests from applicants. If pesticides are to be used on food or feed crops, EPA also sets tolerances (maximum pesticide residue levels) for the amount of the pesticide that can legally remain in or on foods. EPA also has the authority to suspend or cancel registrations of a pesticide if subsequent information shows that continued use would pose unreasonable risks. Pesticides are usually suspended in water when applied. The droplet size is large enough that particles settle quickly and they do not remain airborne. Over 34 Hazardous Air Pollutants (under the Clean Air Act) are also registered as pesticides under FIFRA. As HAPS, these chemicals must be permitted if released to the air over certain amounts (varies by chemical). In some cases there are National Emissions Standards for Hazardous Air Pollutants (NESHAPS), but these only apply to manufacturing facilities. In Colorado, the state Department of Agriculture has full regulatory authority for FIFRA requirements. The State has promulgated the Pesticide Act and the Pesticide Application Act. Table A.4 shows pesticides most commonly used by commercial applicators in Larimer County in 1997. Table A.4 Top Ten Actives in Larimer County (1997)* Agricultural Use Turf & Ornamental TOTAL oz. applied carbaryl 5,334 144,832 150,166 sulfur 132,855 132,855 glyphosate 16,705 70,936 87,641 propargite 78,988 78,988 pendimethalin 4,269 57,014 61,283 2,4-D 56,787 2,201 58,988 cyanazine 49,296 49,296 petroleum distillate 47,754 47,754 EPTC 39,078 39,078 chlorpyrifos 2,411 34,128 36,539 * Structural application excluded from these numbers. Data were collected from commercial applicators. The State of Colorado also operates a Pesticide Sensitivity Registery, where sensitive individuals can receive 24 hours advance notice of pesticide application by turf and ornamental applicators. Fort Collins Air Quality Plan Draft – May 4, 2004 A-18 According to a recent survey, 75% of households used at least one pesticide product indoors during the past year. Products used most often are insecticides and disinfectants. Another study suggests that 80% of most human exposure to pesticides occurs indoors, and that measurable levels of up to a dozen pesticides have been found in the air inside homes. Fort Collins Air Quality Plan Draft – May 4, 2004 A-19 A.3 AIR QUALITY INDICATORS When measuring progress toward achieving goals, air quality indicators are often used. Indicators are indirect measurements of air quality that focus on parts of the problem within human control, whereas ambient data include issues outside our control, such as the effects of weather. The 2000-2003 Air Quality Action Plan contained several policy- based air quality objectives, and associated indicators. Progress in achieving those indicators is discussed in this section. A.3.1 VMT Growth Policy Basis: Reduce rate of growth of total vehicle-miles of travel in the Fort Collins Objective: Reduce Growth Rate of VMT Indicator: Miles per day Status: The rate of VMT growth has been increasing nearly twice as fast as the population growth rate, as illustrated by Figure A.17. The VMT growth rate used in the 2025 NFR Regional Transportation Plan was 2.9 percent/year. The VMT growth rate estimated by the City’s LUTRAQ Team for the period 1990-1998 is 4.9% per year; indicating a significant increase in the rate of VMT growth. Figure A.16 VMT Growth Trend in Fort Collins Source: Estimation of VMT and VMT growth rate; City of Fort Collins LUTRAQ Team; June 22, 2001 Daily Vehicle Miles Traveled 1,914 2,399 2,800 2,930 3,080 3,230 3,390 0 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 1990 1995 1996 1997 1998 1999 2000 2001 2002 1000 miles Fort Collins Air Quality Plan Draft – May 4, 2004 A-20 Figure A.17 Fort Collins VMT Growth vs. Population Growth Source: City of Fort Collins 2002 Trends Report, Advanced Planning Department A.3.2 Tailpipe Emissions Policy basis: Continually reduce tailpipe emissions of high –priority pollutants, including CO, fine particulates, air toxins, and VOC’s (gm/mi) Objective: Reduce Per-Mile Motor Vehicle Emissions Indicator: g/mi as determined with EPA’s Mobile Model Status: Fort Collins per-mile emissions of carbon monoxide are decreasing. Per- mile trend data for hydrocarbons,. Nitrogen oxides, and particulates are not available. Figure A.18 Fort Collins Per-mile Carbon Monoxide Emissions Modeling was done using EPA’s Mobile 6. Emissions inventories for the years 2004 thru 2015 incorporate no control strategies. (i.e. Auto Inspection and Maintenance and Oxy-fuels programs are removed). The reduction in CO is largely attributable to federal new car emission standards. The Inspection and Maintenance program also played a role. Source: CO Redesignation Request and Maintenance Plan for Fort Collins Area. CDPHE, July 18, 2002 Fleet Average CO 29.17 18.34 15.49 46.11 27.67 25.58 0 5 10 15 20 25 30 35 40 45 50 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 gm/mi Fort Collins Growth Rates 0.90 1.00 Fort Collins Air Quality Plan Draft – May 4, 2004 A-21 A.3.3 Total Motor Vehicle Emissions Policy basis: Continually prevent total motor vehicle emissions of high priority pollutants from rising above the low point, projected to occur in 2000 Objective: Prevent Total Motor Vehicle Emissions from Increasing After Year 2000 Indicator: Emissions level not increase after 2000 Status: Multiplying the daily VMT by the fleet average grams per mile projected by EPA’s Mobile model, it appears carbon monoxide levels will increase in 2004. Figure A.19 Total Carbon Monoxide Emissions in Fort Collins Source: Multiplication of daily VMT (Figure A.16) times gm/mile (Figure A.18) Total CO Emissions 81,676 103,209 91,150 94,802 99,762 97,742 0 20,000 40,000 60,000 80,000 100,000 120,000 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 gm/day Fort Collins Air Quality Plan Draft – May 4, 2004 A-22 A.3.4 Commercial and Industrial Emissions Policy basis: Continually reduce total emissions of high priority pollutants from commercial and industrial sources in the Fort Collins UGA, including CO, fine PM, air toxins, and VOC. Objective: Reduce total emissions from Commerce and Industry Indicator: Tons/day of CO, PM2.5, air toxics, and VOC’s. Status: Figure A.20 shows emissions from selected Fort Collins businesses (CSU, Anheuser Busch, Hewlett Packard, Poudre Valley Hospital, City Wastewater Treatment, Symbios Logic (LSI)). Carbon monoxide emissions have been steady over time, while emission of volatile organic compounds have increased. Figure A.20 Fort Collins Commercial and Industrial Emissions Source: AIRS (EPA’s Aerometric Information Retrieval System) Emissions From Selected Fort Collins Businesses 259 50 8 52 9 128 52 9 55 9 289 156 51 7 127 337 126 337 337 134 0 50 100 150 200 250 300 350 400 NOx VOC CO PM10 1993 1994 1995 1996 1999 Fort Collins Air Quality Plan Draft – May 4, 2004 A-23 A.3.5 Area-wide Wood Smoke Policy basis: Reduce area-wide wood smoke emissions. Objective: Reduce Area-wide Wood Smoke Emissions and the Number of Non- certified Wood stove and Conventional Fireplaces. Indicator: Area-wide wood smoke emissions declining Number of non-certified stoves declining Status: Figure A.21shows that carbon monoxide emissions associated with woodburning have declined over time. Carbon monoxide is a reasonable surrogate for other wood smoke emissions such as fine particles because they are both a function of the amount of wood burned. Figure A.22 shows that use of wood-burning devices has been declining over time, although it does not directly quantify the number of non-certified stoves. Figure A.21 Fort Collins Wood Smoke Carbon Monoxide Emissions Source: Fort Collins Outdoor Air Quality Survey Data Figure A.22 Use of Wood-burning Devices in Fort Collins Source: Fort Collins Outdoor Air Quality Survey Data Fort Collins Wood Smoke CO Emissions 2975 1367 1247 1135 691 915 0 500 1000 1500 2000 2500 3000 3500 1984 1990 1994 1996 1998 2002 CO TPY Type of Unit 49 5 39 47 50 37 0 10 20 30 40 50 60 Wood Gas Percent 1990 1998 2002 Fort Collins Air Quality Plan Draft – May 4, 2004 A-24 A.2.6 Indoor Air Quality Policy basis: Increase the percentage of residences taking action to reduce exposure to indoor air pollution. Objective: Increase Actions by Residences and Workplaces to Reduce Exposure to Indoor Air Pollution Indicator: Radon Reduction Actions Status: According to Figures A.23 and A.24, the number of radon mitigations is slightly increasing, and the number of known homes testing is slightly increasing. More current data are needed to accurately access trends in radon-related actions. Figure A.23 Radon Mitigations in Fort Collins Source: Radon Program Review, City of Fort Collins NRD, March 2001 Figure A.24 Radon Testing in Fort Collins Source: Indoor Air Quality Survey 2000 Report: City of Fort Collins (12/01) Fort Colins Rn Mitigations 355 313 387 0 50 100 150 200 250 300 350 400 450 1998 1999 2000 Number Has your current home been tested for radon? 0 10 20 30 40 50 60 Yes No Don't Know Has System percent 1994 1995 1997 1998 2000 Fort Collins Air Quality Plan Draft – May 4, 2004 A-25 A.4 EMISSION INVENTORIES Emissions inventories can be used to estimate how much pollution is emitted into the air. These estimates are based on many factors, including actual monitored readings at emission stacks, levels of industrial activity, fuel consumption, vehicles miles traveled, and other activities that cause pollution. Table A.5 below shows emission sources for air pollution in Larimer County in 2001. Table A.5 2001 LARIMER County Emission Inventory (Tons per Year) CATEGORY CO NOX PM10 SO2 VOC Benzene Agriculture 0 0 1,279 0 0 0 Aircraft 249 1 0 0 8 1 Aviation Gasoline Distribution 0 0 0 0 0 3 Construction 0 0 5,635 0 0 0 Forest & Structure Fires 2,734 78 255 2 375 22 Fuel Combustion 86 409 99 53 2 0 Prescribed Fire 142 2 11 0 4 1 Railroads 6 66 1 1 2 7 Solvent Utilization 0 0 0 0 1,725 5 Surface Coating 0 0 0 0 641 1 Unpaved Airstrips 0 0 8 0 0 0 Woodburning 2,524 40 377 6 2,037 23 Area TOTAL 5,741 596 7,665 62 4,794 63 Highway Vehicles 47,840 5,292 141 212 3,217 103 RoadDust 0 0 3,087 0 0 0 On-Road TOTAL 47,840 5,292 3,228 212 3,217 103 Lawn and Garden (comm) 9911 207 35 6 867 19.63 Lawn and Garden (res) 2917 37 4 1 221 6.54 Other Non-road 7193 1,325 118 29 992 23 Non-Road TOTAL 20,021 1,569 157 36 2,080 49 Stationary TOTAL 601 4,937 1,067 1,543 1,556 15 Biogenics 0 974 0 0 53,778 0 TOTAL 74,203 13,368 12,117 1,853 65,425 230 Source: http://emaps.dphe.state.co.us/APInv/viewer.htm Table A.6 on the next page shows the sources of greenhouse gas emissions (carbon dioxide and methane) in Fort Collins in 2002. Fort Collins Air Quality Plan Draft – May 4, 2004 A-26 Table A.6 Fort Collins 2002 Greenhouse Gas Emission Sources Sector Tons GHG Percent Residential 508,535 23% Commercial 419,362 19% Industrial 484,655 22% Transportation 754,706 34% Solid Waste 20,554 1% TOTAL 2,187,812 1 Source: City of Fort Collins 2001/2002 Climate Protection Status Report Table A.7 below summarizes the highest and second highest source of high priority air pollution emission in Fort Collins. Table A.7 Sources of High Priority Air Pollutants Pollutant Pollutant Rank Largest Source Second Largest Source VOC (Ozone precursor) High On-road vehicles Non-road engines PM2.5 High Mobile sources Mobile Haps High Mobile sources Greenhouse Gases High Transportation Comm / Industrial Indoor Air Quality Medium Residences Visibility Medium Mobile Sources Nitrogen Oxides Medium On-road vehicles Stationary sources PM10 Medium Construction Road dust Industrial Haps Medium Industrial Sources Carbon monoxide Medium On-Road vehicles Non-Road engines A.5 TRENDS AND EMERGING ISSUES A.5.1 Ozone National air quality levels measured at thousands of monitoring stations across the country have shown improvements over the past 20 years. However, of all six principal pollutants tracked, progress has been slowest for ground-level ozone. According to EPA’s “2002 Air Trends Report”, the national average ozone (8-hour) levels have been fairly constant in many metropolitan areas. An analysis to adjust 8-hour ozone levels in metropolitan areas to account for the influence of meteorological conditions shows the 10-year trend to be relatively unchanged. At the same time, for many national parks, the 8-hour ozone levels have increased slightly. This national trend for ozone is mirrored in Colorado. During the summer of 1998, a heat wave cased ozone levels to rise along the Front Range. Again during the summer of 2003, especially high temperatures caused exceendances of the 8-hour ozone standard at numerous monitoring sites along the Front Range, including Fort Collins. Three Fort Collins Air Quality Plan Draft – May 4, 2004 A-27 monitoring locations in Denver actually recorded violations of the ozone standard. Greeley and Rocky Mountain National Park are extremely close to violating the standard. In December 2002, state and regional agencies entered into an “Early Action Compact” with EPA. Under this agreement, a non-attainment designation for ozone is deferred until 2007, as long as several milestone are met. These include: • Developing an emission inventory and modeling • Identifying strategies that will bring the area into attainment by 2005 • Implementation of these measures no later then December 31, 2005 • Additional modeling ensuring the area will remain in attainment of the 8-hour standard for 2008-2012. In December 2003, EPA proposed that Larimer, Weld, Morgan and Elbert counties also be included in the ozone non-attainment boundary. This is because emissions from these areas contribute to the ozone problem. In early 2004, all four counties joined the Ozone Early Action Compact. The EPA decision on the ozone non-attainment area boundary will be finalized in April 2004. It is extremely likely Fort Collins will be included within the deferred 8-hour ozone non-attainment area. Responsibility for bringing the area into attainment lies at the state level. Strategies to achieve attainment will be promulgated into state regulation by the Air Quality Control Commission and later approved EPA. The role of local government will be to participate in the development of the enforceable ozone action plan at the state level and to encourage voluntary reductions of ozone precursors by citizens and businesses through education and incentive programs. A.2.5 Shift in Primary Emissions Sources With the exception of the greenhouse gas carbon dioxide, tailpipe emissions from individual vehicles have been declining as a result of federal new car emission standards. Indeed, by 2025, modeling shows motor vehicle emissions collectively will have declined significantly, as illustrated in Figure A.25. Consequently, the relative contribution of non-road emissions to Fort Collins’ air pollution will increase, as illustrated by Figure A.26. Non-road sources include construction equipment (heavy equipment, generators, forklifts), lawn and garden equipment, farming and mining equipment, recreational vehicles (dirt bikes, etc.), and locomotive and aircraft emissions. EPA is considering tighter controls for diesel non- road engine, but they will not come into effect for several years. This means that over the next decade, Fort Collins will need to shift some of the focus of air quality protection efforts onto non-road sources of pollution. Fort Collins Air Quality Plan Draft – May 4, 2004 A-28 Figure A.25 Fort Collins On-Road Emission Trends Source: Fort Collins Transportation Master Plan, Appendix C (January 2004 draft) Figure A.26 Relative Contribution of Sources Source: ENVIRON Analysis for Western Regional Air Partnership, 2002 A.6 Citizen Perspectives on Air Quality Citizen surveys are periodically conducted to learn citizen views regarding air pollution, what citizens’ feel should be done about air pollution, their willingness to participate in solutions, and effectiveness of City outreach efforts. The last air quality survey was conducted in 2002. Of 1500 surveys sent to randomly selected households in Fort Collins, 818 completed the surveys, for a 55% response rate. Survey results are highlighted below: - Residents perceive that the major sources of air pollution in Fort Collins are gasoline and diesel vehicles. Fort Collins On-Road Emissions Projections 0 2 4 6 8 10 12 CO * 0.1 NOx VOC PM2.5 Tons Per Day 1998 2025 (fiscally constrained) Fort Collins Urban Area Emissions 0 10 20 30 40 50 60 2003 2018 Tons per day Highway Non-Road (VOC, NOx, PM10, SO2) 53 tpd 28 tpd Fort Collins Air Quality Plan Draft – May 4, 2004 A-29 - Most respondents felt the current air quality in Fort Collins is good, yet 62% state that air pollution affects them in a negative way. - The top two negative impacts (as in the past several surveys) were the brown cloud (76%) and obscuring mountain views (70%). Health based impacts such as allergies, respiratory ailments, and burning eyes, have increased as well, as illustrated in Table A.8 below. Table A.8 Fort Collins Citizen Survey Data Adverse Affects of Air Pollution 1997 1999 2002 Obscures mountain views 69 % 50 % 70 % Creates a Brown Cloud 22 % 68 % 76 % Causes burning itchy eyes, nose 41 % 39 % 76 % Trigger allergies, respiratory problems 45 % 49 % 57 % Causes long term respiratory problems 28 % 33% 55 % - Interestingly, most citizens (62%) believe air quality will get worse in the next five years, that something can be done about air quality (70%), yet few believe something will be done (21%). - Respondents believed that the City should focus air quality efforts on improving traffic light timing to reduce vehicle idling, increasing enforcement of exhaust regulations, and prohibiting woodburning on high pollution days. - Most residents would be willing to do something to help reduce air pollution (55%). Preferred actions included keeping their vehicle tuned up (94%), taking the bus if it was more convenient (65%), and reducing the number of miles driven (64%) - Several factors impact citizen decisions to reduce the daily miles driven. Results show that tax breaks incentives, being able to ride a bike for work or errands, and taking the bus for errands or work if it was more convenient are good predictors of whether a respondent would reduce the number of miles they drive. - More people believe that Fort Collins is impacting and being impacted by global warming that those who do not believe this. - Overall, residents agreed (97% - 60%) with current or planned programs. The responses that best predicted whether residents believe the City should be doing more to control air pollution were reduce the brown cloud, reduce local greenhouse gas emissions, increase enforcement of exhaust regulations and the emission law, and decrease wood burning. D-1 Attachment D – Public Outreach Summary Efforts were made throughout the development of the draft Air Quality Plan to involve affected interests. General public input was sought via the Internet using postcard mailings to a range of stakeholders. Numerous meetings were held with various City staff and consultants to the City Plan and Transportation Master Plan updates, as well as City Council advisory boards. EDAW was hired to review the draft air quality policies and strategies I. Council Advisory Board Input A Sub-Committee of the Air Quality Advisory Board was formed in April 2003, and met five times to provide input at various stages of the plan development. In addition to that, Council advisory boards had opportunities to provide input to the Air Quality Plan at various points in the process. • Air Quality Advisory Board - 6/19/03, 7/17/03, 9/18/03, 12/18/03, 1/15/04, 3/18/04, 4/22/04 • Transportation Advisory Board - January 14, 2004 • Natural Resources Advisory Board – February 18, 2004 Various Board comments can be found in copies of the minutes posted to the Web at http://fcgov.com/cityclerk/bc-gen-info.php. On April 22, 2004, the AQAB moved “that with incorporation of AQAB board comments made to date, the AQAB is generally supportive of the Air Quality Plan.” The motion passed 5-0-0. Final recommendations on the draft Air Quality Plan are expected as follows, Air Quality Advisory Board – May 20, 2004 Transportation Advisory Board – May 19, 2004 Natural Resources Advisory Board – June 2, 2004 II. General Public Input General public input was sought via the Internet in March and April 2004. Announcements about the Web-based comment opportunity were published in the May City News, and via a press release. More than 150 direct postcard mailings announcing the Web comment opportunity were sent to the following interest groups: • Interested citizens • Other local governments • Environmental groups • Health experts • Wood Smoke Complaint Line participants • Local air quality consulting firms • Technical experts • Construction firms D-2 • Bicycle retailers • Auto repair shops • Lawn and garden equipment retailers • Wood stove retailers • Radon testers and mitigators • Home Builders • Board of Realtors Additional input was solicited by broader e-mail announcements about the Web-based comment opportunity. In addition, public input on the air quality City Plan policies was sought from the City Plan citizen’s advisory committee, at several public open houses, and via City Plan website comment opportunities. Air Quality Plan Public Comments (through 4/28/04) E-mail Comments: I am not impressed with this plan. The 5 years that I lived in Riverside Ca. was a nightmare of smog. I used to work in the orange groves and could see from the hillside the black cloud coming up the valley! We do not have anything close to the land structure that CA does. The wind kicks out all possible problems. I am not infavor of all vehicles being tested. I want the emmission test removed. Please keep me updated on your findings from the emmision control tests over the years that you have done it VS. the years not in place. I wager there is little change or none at all. City Action: Provided information about the benefits of the emissions testing program reported by CDPHE. E-Mail Comments: The FTC Air Quality Plan does not specificly address the issue that overwhelmingly dominates the human health risk from citizen exposure to air pollutants. That is the inhalation pathway of diesel particulate matter and associated PAH's. It is now well known that this is the single most significant air pollution health risk to the general urban population. I am confident that there is likely a >1 ug/m3 DPM exposure on the streets of Fort Collins which would translate to a chronic cancer risk well in excess of the 1E-5 threshold. Coupled with the toxicity of formaldhyde emissions from motor vehicles, I am confident the exposure on the corner of College and Harmony is a significant health threat and absolutely must be specifically addressed in the Plan. Citizens should be warned. Additionally, to continue to allow semi trucks to use Fort Collins as a bypass to I80 (without a discouraging access fee) is irresponsible because those trucks also make a significant contribution to ! the DPM load, particularly in Old Town. If the citizens of Fort Collins knew the dangers from this exposure, you'd have your hands full. I suggest you address this serious issue. It make all others pale by comparision. You need to recognize the issue and address it with some action items. Please call to discuss as needed. Good luck... City Action: Add formation of a diesel task force to the list of air quality strategies. D-3 Comments by Phone, 3/24/04 (Wood Street Neighborhood Resident) Concerned about diesel (and gasoline) emissions in the vicinity of City Wood Street facilities. The number of trips has increased since parking lot expansion. She suffers health effects from these fumes. She feels the location of these City activities in such close proximity to residential neighborhoods is poor, notes the emission levels are not monitored, has talked with City employees who are made sick by fumes, and fears more expansions of City facilities in this neighborhood may happen. She has concerns about the proposed vehicle storage facility increasing emissions, or least not reducing emissions. She doesn’t perceive wood smoke as a problem in the neighborhood. A horticulturalist has noted air pollution damage to grape leaves on her property. She fears she may have to move if air pollution is not reduced. She calls for monitoring of diesel exposure levels in her neighborhood. City Action: Forwarded this comment to Utilities and Operations Services. E-Mail Comments: Questions: 1) Have IAQ studies been conducted in schools, homes, or businesses where evaporative coolers are used? 2) If so, where can the results be found? 3) If not, who could conduct such a survey? City Action: Compiled references and replied. E-mail Comments: I like the updated version of the air quality plan, and am pleased the City has one. I particularly like the connection of VMT with land use planning, and hope that this group can promote community development that encourages walking, or public transportation from new or existing housing to shops. City Action: Thank you for your comment. Phone Comments 3/24/04 Diesel emissions are the # 1 air quality human health hazard. He just completed overseeing a study by Lawrence Berkley Lab on human health assessment of diesel particulate matter (DPM). They found that 98% of human health risk from diesels comes from shuttle busses and back-up generators for electricity. This risk is at levels of 0.4 ug/m3 DPM, using B20 (20% BioDiesel fuel). (He didn’t say what the risk is, and the study is not published yet.) If human health protection really is the main goal, we should use as risk analysis to prioritize city actions. Actions we should consider include: • Identify DPM risk levels (using standard models) at Harmony and College (McDonald’s), Riverside and College, and in Old Town. (Work w/ CSU grad student to complete the study.) • Routing diesel trucks away from the urban center (true truck bypass; and restrict HDDV access in urban corridor. • Reduce idling • Promote BioDiesel • Strategically assess ways to tap into outside funding City Action: Add formation of a diesel task force to the list of air quality strategies. D-4 E-Mail Comments: Your discussion of policy in one big chart says that your mobile source emissions "will bottom out in the year 2000." I dont believe you want to use the future tense about a past event, and anyway I believe your calculations are almost certainly wrong. Look for instance at your mean or better yet median CO trend. I bet it continues to go down to this day. If the MOBILE6 model is what you are using to do this calculation you might put in a caveat that you know that it is the legally required model, but also that it is very likely not to represent the real world. This is not the place to do so, but I have an electronic copy of a presentation at the 2002 NCVECS conference which I can sent to you which shows that MOBILE6 horribly overestimates the HC and NO emissions of relatively new cars and underestimates the older vehicles. The total is not far off, but it is right for the wrong reason and thus is likely to massively overpredict future emissions. Addendum to my previous comment: I see upon rereading that the "future in 2000" text has been deleted and replaced so that is not important. It might be worthwhile nevertheless to note in the Mobile source section that the model used is just that, a model lacking much verification. City Action: Thank you for your comment. Comments received by e-mail 4/15/04 I just skimmed the Climate Protection Plan update from 2001/2002, which I hadn't done before, and thought it looks really good. I feel very good about Fort Collins' actions to address greenhouse gas emissions. Here are some other thoughts that came from reading through this - SolarBound (MSR) objectives could be included in the plan, unless they become incorporated in the electric energy supply policy targets. Either of those two things would be good. Are you aware of the "Green Building Certificate Program" that Brian Dunbar has put together for CSU extension in Denver? If the City moves toward a Green Building program, or Green Builder certification, that program could be adapted easily to train builders here. I am teaching the solar energy section. City Action: Thank you for your comment. Comment received by e-mail 4/20/04 Its helpful to see the game plan for commercial and industrial emissions, both in terms of Climate Wise strategies as well as linking with the Chamber. With 172 permitted facilities in Fort Collins, I would think the chamber would be a great conduit for educating local businesses on HAPs, VOCs, etc. The section on how the pollutants were prioritized was fascinating both in terms of process and outcomes. I'm glad to see that GHGs remain a high priority. My only confusion though is how to cross reference the priority pollutants with the Web subtopics. I read the pdf link explaining the sources and issues for each pollutant, but found myself wanting to add a column to the table showing prioritization results with which chapters in the AQP addressed reduction of those pollutants. I'm assuming that the chapter titles are an artifact of past air quality plans, but its hard to see how they match up against the latest determination of priorities. The plan seemed to lack quantitative perspective. As a citizen reader, its hard to tell whether the D-5 lists of strategies within each topic will have a significant benefit towards improving air quality or are just 'bailing out the titanic with a teaspoon'. I know this is really hard to do, but I think the ghg report is a good model where different strategies are at least roughly quantified in terms of their expected benefits. I'm really pleased to see the plan includes a section on health and call for partnerships with health professionals. I understand the quandary about the scope of the City's role, but I think its very important to recognize the linkage and I like the proposed approach very much. Overall an awesome plan. As a citizen, I'm thrilled that the City is addressing air quality in such a proactive and progressive manner. City Action: Added a column to the table of air quality strategies that identifies which pollutants the strategy addresses. E-mail Comments 4/28/04: I have chosen to comment on one specific area that you could easily eliminate immediately-wood burning. The policy is that you not burn unless it is an emergency. Well my neighborhood must be having a crisis. And what about all of these wood burning patio fireplaces? Although the homes in many neighborhoods have gas fireplaces indoors, the residents use these outdoor wood burning fireplaces. How can using those qualify as an emergency? My neighbors on both sides of me have one of those, and they have presented me with some terrible experiences. I am allergic to wood smoke. It affects my breathing. Last summer I had all of the windows open in my house and ran to the grocery store. When I returned, my house was filled with the smell of smoke which remained in the house for over a week. I was on triple the amount of medication that I normally am for over a month. Last Saturday, they had a party. About 11:30 p.m., I woke up gasping for air to the smell of smoke. They had started their outdoor fireplace, and I had my bedroom window open. About 12:30 p.m., the wind started blowing. I looked out of the window to see flames shooting in the air and sparks flying everywhere and no one outside on the patio. About an hour later they finally became aware of the situation. Thank God our neighborhood was not front page news Sunday morning. You were brave enough to take away people's right to smoke in public places. When I was asked, "Smoking or non-smoking?", I said, "Neither, thank you " and left. But now I can't go home, that's where the problem is. Could you be equally as brave to protect our environment? Home should be my haven not a health hazard. A law would take the guesswork out of whether burning wood contributes to or contaminates my quality of aire. If you need citizen participation, please let me know. City Action: Data show that Fort Collins wood smoke emissions have declined over time, but a slight increase occurred in the last year for which we have data (2002). We added an air quality strategy to “Consider regulatory action to reduce wood smoke emissions if area-wide wood smoke emissions continue to increase.” Regulatory action considered but not implemented in the past was mandatory removal of non-certified wood stoves when homes are sold. 1.10 1.20 1.30 1.40 1.50 1.60 1.70 1990 1995 1998 2000 Normalized Percent VMT= 61% Pop = 35% Street Mi = 29% Area (SqMi) = 14% 92 93 94 95 96 97 98 99 00 01 02 03 micrograms/meter cubed 24Hour Std (150) 24 Hr Max Annual Std (50) Annual Mean Monitor location: 1986 - 2001: Larimer County Courthouse 2002 - present:(2001 from CSU) 0 2 4 6 8 10 12 14 16 18 80 82 84 86 88 90 92 94 96 98 00 02 Parts per million Number of violation days Standard (9) Annual 2nd highest Number of violation days Standard=9 ppm No violation of air quality standard since 1991 comply with all other criteria necessary for ap- proval of such proposals. DELETED This policy was needed before City Plan was adopted, but is now well covered by other City Plan policies. with others. The new policy here just ad- dresses the City’s own role. The remain- der is addressed in new Policy AQ-1.5 on page 1 of this table. examples of specific actions that could be taken to reduce wood smoke. These ac- tions are already part of the current wood smoke program. the new policy directs the City to help citi- zens find available information that is of interest to them. Policy ENV-1.8 Enforcement. It is in the best in- terest of the City that State and County Health De- partments have adequate responsibility, authority, and resources (funding and personnel) to enforce regulations adopted by the Colorado Air Quality Control Commission. Policy AQ-1.8 Enforcement. The City will support the provision of adequate responsi- bility, authority, and resources (funding and personnel) to agencies charged with the en- forcement of federal, state, and local air quality regulations. More clearly affirms the City’s support for agencies charged with enforcing air quality regulations.