HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 02/09/2016 - DUST PREVENTION AND CONTROLDATE:
STAFF:
February 9, 2016
Lindsay Ex, Environmental Program Manager
Jackie Kozak-Thiel, Chief Sustainabillity Officer
Lucinda Smith, Environmental Sustainability Director
WORK SESSION ITEM
City Council
SUBJECT FOR DISCUSSION
Dust Prevention and Control.
EXECUTIVE SUMMARY
The purpose of this item is to receive feedback from Council on options for addressing fugitive dust prevention
and control within the City. Each of the three options that will be presented are designed to fill gaps in existing
regulations related to fugitive dust and to reduce health impacts from dust generating activities. The three options
for Council consideration are as follows:
1. Adopt Code Changes and the Dust Prevention and Control Manual, but delay enforcement until
approximately November 1 to allow time for training and education;
2. Adopt Code Changes and the Manual, but begin enforcement immediately to ensure regulations are in
place during the 2016 construction season; or
3. Adopt Code Changes that require operators to take reasonable measures to prevent and control fugitive
dust, and if problems occur, then require a plan and use the Manual as guidance for the development of
the plan.
GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED
1) What feedback does Council have regarding the proposed options?
1. Adopt Code Changes and Manual, delay enforcement
2. Adopt Code Changes and Manual, begin enforcement immediately
3. Adopt Code Changes only, use Manual as guidance
4. Status Quo
2) Does Council suggest any additional outreach before First Reading?
BACKGROUND / DISCUSSION
“Fugitive dust” consists primarily of soil particles in the air caused by wind and human activities such as
excavating, demolition, abrasive blasting, and other activities. Dust causes health impacts; safety, visibility, and
aesthetic issues; and is a nuisance that can cause expensive damage to property and machinery. While there
are existing state and county regulations that address dust, these regulations are not sufficient at controlling dust
emissions in many cases because:
Some sources of dust emissions, e.g., sweet sweeping, saw cutting, development projects less than
5 acres in size, etc. that affect Fort Collins citizens are not covered by state or county regulations.
State and county compliance and enforcement resources are limited.
City code compliance officers cannot enforce state and county dust control requirements.
Initial Approach: As directed by Council in its 2014 Work Plan, staff initially constructed an approach to address
fugitive dust issues that included proposed code changes, a guidance manual (entitled Dust Prevention and
Control Manual, Attachment 2) to describe how to comply with the code changes, and a training and
enforcement plan. Each of these components is described further below.
February 9, 2016 Page 2
Code Changes. Changes are proposed to both City Code and Land Use Code. City Code amendments
outline that generators of fugitive dust shall comply with the provisions of the Dust Prevention and Control
Manual with the primary purpose of preventing fugitive dust, and when dust cannot be prevented, to
provide specific solutions for minimize dust transport. Land Use Code changes reference the manual and
align with the Municipal Code changes.
Guidance Manual for Dust Prevention and Control: The DRAFT Dust Prevention and Control Manual
includes the following chapters:
• Chapter 1: Introduction
• Chapter 2: Fugitive Dust and the Problems it Causes
• Chapter 3: Dust Control Measures
• Chapter 4: Dust Control Plan for Land Development Greater than Five Acres
• Chapter 5: Resources
Each of these chapters is briefly described below, and the full manual is attached as item 2.
Chapter 1: Introduction
The purpose of this chapter is to set the context for the manual, including the purpose of the
manual, applicability of the standards outlined in the document, and definitions associated with
the various terms used in the manual.
Chapter 2: Fugitive Dust and the Problems it Causes
This chapter discusses the various effects of fugitive dust, including health and environmental
effects, nuisance and aesthetic effects, and safety hazards and visibility issues that arise when
fugitive dust is in the environment.
Chapter 3: Dust Control Measures
This section of the manual includes specific descriptions of each of the 12 dust generating
activities and a series of best management practices designed to prevent and minimize off-
property transport of dust. For each activity, required measures are described, and if these
required measures are ineffective at preventing off-property transport, then additional measures
are identified and at least one of these measures must be incorporated into the project.
Chapter 4: Dust Control Plan for Land Development Greater than Five Acres
Currently, dust control plans are required by the state for land development that is greater than 25
acres or exceeds 6 months in duration. Dust control plans are also required by Larimer County for
construction sites greater than five areas. The manual now requires that land development
greater than 5 acres provide a dust control plan to the City, either at the time of development
construction plan (DCP) submittal or if a DCP is not required, then the plan needs to be available
on site at all times.
Chapter 5: Resources
This chapter includes numerous references to various codes, standards, regulations and other
policies that apply to each of the dust generating activities outlined in the manual.
Training and Outreach: Pending adoption, staff has developed a training and outreach program
(Attachment 7). Training will focus on City staff enforcing the regulations, contractors and City staff
affected by the regulations, and general outreach regarding the program. In this approach, staff has
proposed that enforcement of these regulations be delayed until November 1, 2016 in order to allow for
training and outreach to occur prior to enforcement.
Pilot Project: Originally scheduled to be adopted in the spring of 2015, the project was delayed to allow for a pilot
project to collect additional data related to the costs, air quality impacts, water use, and overall time required
should the regulations and best practices be implemented. The pilot project also includes the formation of a
Fugitive Dust Working Group (FDWG) to review the field study, the proposed Ordinance, and the guidance
February 9, 2016 Page 3
manual. The FDWG consists of stakeholder representatives from the construction industry, environmental firms,
and City staff affected by the proposed regulations (including Engineering, Utilities and Code Compliance Staff).
Costs. Staff has worked with the Fugitive Dust Working Group and AECOM (a private consulting firm) at
three FDWG meetings to assess the cost of the required dust mitigation measures for each dust generating
activity. The full assessment is attached as Item 6, and a summary of the analysis is as follows:
Costs were defined into initial, upfront costs, and ongoing operations and maintenance costs (O&M);
Costs can generally be broken into five categories:
1. Measures that result in negligible or no additional initial or O&M costs to the operator (less
than $100):
Negligible costs include lowering drop height, covering loads, leaf blowing
techniques, reducing vehicle speeds, and restricting access (in small projects).
2. Measures that result in minor O&M or initial upfront costs (hundreds of dollars):
Minor cost measures include minimizing the disturbed areas, reducing vehicle
speeds (on unpaved or haul roads), and restricting access (on larger projects)
3. Measures that have little to no initial cost (<$100s) but have high O&M costs (ranging in the
thousands to tens of thousands of dollars):
These measures include the high winds restriction (over 30 mph, which is consistent
with state regulations) and cleaning up work areas
4. Measures that have high initial costs (ranging in the thousands to tens of thousands of
dollars), but negligible or low O&M costs:
These measures include chemical stabilization (on parking lots), vegetating open
areas, cleaning up the slurry after saw cutting/grinding or abrasive blasting, and
erecting wind barriers.
5. Measures that have both high initial costs and high O&M costs (ranging in the thousands to
tens of thousands of dollars):
Measures include soil retention, surface improvements (paving roads), sweeping,
synthetic or natural cover, prohibited uncontrolled sweeping, vegetating areas, and
wet suppression on unpaved parking lots.
Note that all of these assessments are estimates. While the staff team, AECOM, and the FDWG
worked hard to develop meaningful estimates, there are many variables that affect these costs that
cannot be precisely quantified.
In addition to assessing individual BMPs, staff also worked with AECOM and members of the Fugitive Dust
Working Group to assess the potential for cumulative impact on projects, e.g., how does applying the required
measures in the Manual affect individual projects as a whole? Staff either obtained real data or estimates for
the following four projects:
Project Dust
Mitigation
Cost
Total Project
Cost
Dust Cost as %
of Overall Cost
Notes
Horsetooth and
Timberline Intersection
$35,740 $3,304,501 1.1% Actual costs
Utilities Administration
Building
$50,000 $10,000,000 0.5% Actual costs
Single Family Home -
estimate 1
$700 $353,620 0.2% Estimated costs,
minimal dust control
Single Family Home -
estimate 2
$12,170 $365,090 3.3% Estimated costs,
maximum dust
control
February 9, 2016 Page 4
Additional Impacts Examined: A full summary of the results related to air quality impacts, water use, and
overall time are presented in Attachment 5, and these results are briefly summarized below:
Air Quality Impacts: Staff conducted 8 controlled observations by sampling a dust generating activity
without any mitigation measures and then conducting the same activity with mitigation measures in
place. In these observations, controlled field measurements of dust mitigating activities showed an
average of 50% dust mitigation capability, with the maximum mitigation of up to 99%.
Water Use: Water use is generally expected to be minimal, e.g., wetting a saw during concrete
cutting. The two exceptions to this are wet suppression on large sites or in street maintenance, where
water use could be higher.
Time Requirements: Specific data on time were difficult to collect. However, staff’s observation during
the field project indicate that while time to implement these requirements would increase, overall time
varies significantly based on the dust generating activity.
Proposed Options: The following options will be presented at the Work Session for Council feedback:
1. Adopt the Code Changes and Manual with delayed implementation (this is the approach outlined above);
2. Adopt the Code Changes and Manual and begin implementation (enforcement) immediately; or
3. Adopt Code Changes that prevents off-property transport of dust, and then if problems occur, require that
operators use the Manual to come into compliance (with the one exception of covered loads, see below)
Overall Summary of the Options. Each of the three options creates an enforceable Ordinance that will allow
staff to enforce the issue of fugitive dust when it is generated and leaves a property. However, Options 1 and 2
require that the Manual be utilized to address fugitive dust proactively, whereas Option 3 requires operators to
take reasonable measures to control dust instead of the prescriptive approach outlined in the Manual. In each of
the options, staff is proposing that loads be covered during material transport because this is a significant concern
for citizens.
Each of these options is further described in detail below and the benefits, challenges, and compliance
implications are summarized in Attachment 1.
1. Adopt the Code Changes and Manual with delayed implementation (enforcement)
Option Summary: As mentioned above, this is the option that staff has developed since 2014 and has
reviewed with City Boards and with the Fugitive Dust Working Group. This option provides a prescriptive
approach to address fugitive dust in that each of the 12 dust generating activities outlined in the Manual
must first apply the required best management practices, and then if these required measures are
unsuccessful at preventing off-property transport of dust, then at least one additional best manage
practice must also be implemented. Operators or site owners are in compliance with the Ordinance if they
are in compliance with the Manual.
Why this option? This option has been developed for two reasons:
(1) in response to the concerns expressed by citizens and
(2) is based on the field data collected that indicates applying best management practices to a dust
generating activity is effective at reducing dust (up to a 90-95% reduction in dust generated from a
particular activity).
This option proposes that implementation of the Ordinance be delayed until approximately November 1,
2016 to allow time for training and outreach as well as to allow operators to budget for and purchase any
capital equipment they would need to comply with the standards.
2. Adopt the Code Changes and Manual and begin enforcement immediately
Option Summary: The only difference between Option 1 and this Option is that enforcement would begin
immediately after Council adoption.
Why this option? This option has been developed to respond to citizen concerns about Option 1 in that
enforcement would not occur during the 2016 construction season.
February 9, 2016 Page 5
3. Adopt Code Changes that prevents off-property transport of dust, and then if problems occur,
require that operators use the Manual to come into compliance (with the one exception of covered
loads, see below)
Option Summary: In contrast to Options 1 and 2, Option 3 is a less prescriptive approach to enforcing
fugitive dust. As with Options 1 and 2, this option still allows staff to enforce on fugitive dust, but it does
not require operators and site owners to use the best management practices outlined in the Manual
upfront. Instead, the Code Changes would be designed to require operators to take reasonable measures
to prevent and control fugitive dust. If they are unsuccessfully in controlling dust, then a plan would be
required to control dust, and the Manual could be used as a guidance document to develop the plan. The
one exception to this approach is covered loads - staff would propose covered loads be required as
outlined in the Manual on all operations.
Why this option? This option has been developed to respond to the fact that many dust generating
activities already control dust, and this approach rewards those who are already controlling dust without
adding additional requirements (and cost). The challenge with this approach is that it is more reactive.
The reactive approach has at least two implications:
(1) Impacts on residents could be greater than if operators are addressing dust prevention and control up
front, as provided with Options 1 and 2; and
(2) If off-site transport of dust occurs, then operators will have to reactively respond to these issues and
they wouldn’t have necessarily budgeted up front for the additional costs associated with coming into
compliance.
In addition, this option is most consistent with how other Colorado communities approach fugitive dust. 50
communities and 23 counties have fugitive dust regulations, and while staff has not reviewed every
regulation, all of the other communities take a less prescriptive approach to addressing dust.
Feedback on the Options. As staff has only developed the options being presented to City Council over the past
month, outreach on the options has been limited to the Air Quality Advisory Board and the Fugitive Dust Working
Group. Feedback from the groups on the options is as follows:
Air Quality Advisory Board (AQAB) - The AQAB recommends that Council direct staff to bring Option 1 to
First Reading with City Council, scheduled for April 5. The Board discussed how this option is the most
proactive option to protect residents’ health. They also discussed how Option 3 puts the burden on staff to
react to dust that is not properly managed, whereas Options 1 require operators to address dust upfront
and is the most cost-certain option. The Board agreed that delayed implementation was important to
allow time for training and education on the standards.
Fugitive Dust Working Group (FDWG) - The Fugitive Dust Working Group did not have a chance to meet
and discuss the options as a group and instead weighed in via email on an individual basis. The majority
of respondents supported Option 3, as this option addresses public concerns by provided an enforceable
Ordinance on the issue. This option, they felt, also acknowledges that many operators already address
dust and instead focuses staff time (enforcement) on the problems.
Staff Recommendation on the Options: Staff would recommend that Council consider either Option 1 or Option
3 to bring forward to First Reading scheduled for April 5, 2016. Staff initially developed Option 1 as it most
proactively addresses citizen concerns, it represents a precedent-setting approach to managing dust within the
community, and it reflects the recommendations of the Air Quality Advisory Board and the community at large.
However, based on the field data collected this summer (which show that many operators are already addressing
dust control on some level), feedback from the business community and the Fugitive Dust Working Group, staff
would also be comfortable with Option 3, as this option also addresses citizen concerns by providing a clear,
enforceable change to the Code to address fugitive dust.
Overall Public Engagement. Staff has conducted extensive public engagement on this issue since its inception
in 2014, including the following:
Met with 6 City Boards on numerous occasions:
February 9, 2016 Page 6
o Air Quality Advisory Board
o Building Review Board
o Land Conservation and Stewardship Board
o Natural Resources Advisory Board
o Parks and Recreation Board
o Planning and Zoning Board
An Online Survey was conducted in early 2015 (not statistically valid) with 163 respondents (see
attachment 13);
o 65% of respondents supported the implementation of dust control measures
o 53% of respondents had been negatively impacted by fugitive dust
o 52% of respondents felt the implementation of dust control requirements would positively impact
them
o 67% of respondents felt the regulations would have a negative impact on businesses
An Open House was held in February 2015 with 14 attendees;
Staff has met with 8 City Departments to discuss the proposed regulations;
Staff has also conducted specific outreach to the business community including:
o Chamber of Commerce Local Legislative Affairs Committee
o Business meetings,
o A stakeholder meeting with 23 attendees in 2014
o Northern Colorado Homebuilders Association.
Next Steps: First Reading of the Dust Control and Prevention Ordinance is scheduled for April 5, 2016. After
direction from City Council at the February 9 Work Session, staff plans to review Council’s direction with the Air
Quality Advisory Board and the Fugitive Dust Working Group. If Council directs staff to pursue Option 2 or Option
3, staff will reach out to the other Boards that have provided feedback on this issue to see if they would like to
amend their recommendation to City Council (which is based on only seeing Option 1).
ATTACHMENTS
1. Fugitive Dust - Summary of Options (PDF)
2. DRAFT Dust Prevention and Control Manual (PDF)
3. Public Engagement Plan (PDF)
4. Fugitive Dust - SAT (PDF)
5. Field Data Summary (DOC)
6. Cost Assessment (AECOM) (DOCX)
7. DRAFT Training, Outreach, and Enforcement Plan (PDF)
8. Air Quality Advisory Board Meeting Minutes - Draft (DOCX)
9. Land Conservation and Stewardship Board Minutes (DOCX)
10. Parks and Recreation Advisory Board Minutes (PDF)
11. Planning and Zoning Board Minutes (PDF)
12. Natural Resources Advisory Board Memo (DOC)
13. Survey Results (PDF)
14. Powerpoint Presentation (PDF)
Fugitive Dust – Summary Description of Options
Option Benefits Challenges Violations and Remedies
Status Quo - Existing regulations are
difficult to enforce
- Inefficient use of staff
resources
- Only state can enforce
1. Adopt the Ordinance and
Manual with delayed
implementation (enforcement)
- Creates enforceable regulations
- Proactively protects residents
from dust
- Adopting the Manual upfront
allows for contractors to budget for
controlling dust alongside other
project elements
- Delayed implementation provides
time for training and education on
the manual and time for any capital
purchases to be budgeted for
- Would not have a strong
enforcement mechanism in
2016 construction season for
preventing and controlling dust
- Prescriptive requirements
does not recognize some
operators already address
dust
- Could add up to 0.5 to 2.2%
to project costs through the
best management practices
Violation: if you are not complying
with the manual
Remedy: (1) apply at least one
additional best management
practice (BMP). (2) If operator is
not in compliance with the above,
a citation is issued.
2. Adopt the Ordinance and
Manual and begin
implementation immediately
- Creates enforceable regulations
- Proactively protects residents
from dust
- Adopting the Manual upfront
allows for contractors to budget for
controlling dust alongside other
project elements
- Immediate implementation allows
for fugitive dust to be addressed
from construction sites immediately
- Prescriptive requirements do
not recognize some operators
already address dust
- Could add up to 0.5 to 2.2%
to project costs through the
best management practices
- Would not allow for
companies to budget for
January 2016
DRAFT
Dust Prevention and Control Manual
DRAFT Dust Prevention and Control Manual
Do not cite or quote – Legal Review Pending Page i
CONTENTS
1.0 Introduction 1
1.1 Title 1
1.2 Purpose of Manual 1
1.3 Applicability 1
1.4 Definitions 2
2.0 Fugitive Dust and the Problems it Causes 5
2.1 What is Fugitive Dust, Generally? 5
2.2 Why is the City Addressing Fugitive Dust? 5
2.3 Health and Environmental Effects 6
2.4 Nuisance and Aesthetics 6
2.5 Safety Hazard and Visibility 6
3.0 Best Management Practices 7
3.1 Earthmoving Activities 8
3.2 Demolition and Renovation 10
3.3 Stockpiles 12
3.4 Street Sweeping 14
3.5 Track-out / Carry-out 15
3.6 Bulk Materials Transport 16
3.7 Unpaved Roads and Haul Roads 18
3.8 Parking Lots 20
3.9 Open Areas and Vacant Lots 22
3.10 Saw Cutting and Grinding 24
3.11 Abrasive Blasting 26
3.12 Mechanical Blowing 28
4.0 Dust Control Plan for Land Development Greater Than Five Acres 30
5.0 Resources 34
5.1 Cross Reference to Codes, Standards, Regulations, and Policies 34
5.2 City of Fort Collins Manuals and Policies 37
5.3 References for Dust Control 37
DRAFT Dust Prevention and Control Manual
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1.0 Introduction
1.1 Title
The contents of this document shall be known as the Dust Prevention and Control Manual (“the
Manual”).
1.2 Purpose of Manual
The purpose of the Manual is to establish minimum requirements consistent with nationally recognized
best management practices for controlling fugitive dust emissions and to describe applicable best
management practices to prevent, minimize, and mitigate off-property transport or off-vehicle transport
of fugitive dust emissions pursuant to Article X of the Fort Collins City Code (§12-150 et. seq) for specific
dust generating activities and sources.
The purpose of Article X of the Code is to protect the health, safety, and welfare of the public, including
prevention of adverse impacts to human health, property, sensitive vegetation and areas, waters of the
state, and other adverse environmental impacts and to prevent visibility impairment and safety hazards
caused by emissions of particulate matter into the air from human activities.
1.3 Applicability
As set forth in Code §12-150, this Manual applies to any person who conducts, or is an owner or
operator of, a dust generating activity or source, as defined in the Code and described in this Manual,
within the City of Fort Collins, subject to the exclusion set forth in Code §12-15-(b)(3).
DRAFT Dust Prevention and Control Manual
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1.4 Definitions
Abrasive blasting shall mean a process to
smooth rough surfaces; roughen smooth
surfaces; and remove paint, dirt, grease, and
other coatings from surfaces. Abrasive blasting
media may consist of sand; glass, plastic or
metal beads; aluminum oxide; corn cobs; or
other materials.
Additional best management practice shall
mean using at least one additional measure if
the required best management practices are
ineffective at preventing off-property transport
of particulate matter.
Additional requirements shall mean when
applicable, any measure that is required, e.g., a
dust control plan when project sites are over 5
acres in size.
Best management practice shall mean any
action or process that is used to prevent or
mitigate the emission of fugitive dust into the
air.
Bulk materials transport shall mean the
carrying, moving, or conveying of loose
materials including, but not limited to, earth,
rock, silt, sediment, sand, gravel, soil, fill,
aggregate, dirt, mud, construction or demolition
debris, and other organic or inorganic material
containing particulate matter onto a public road
or right-of-way in an unenclosed trailer, truck
bed, bin, or other container.
Chemical stabilization shall mean the
application of chemicals used to bind soil
particles or increase soil moisture content,
including, but not limited to, dust suppressants,
palliatives, tackifiers, surfactants, and soil
stabilizers. Asphalt-based products or any
product containing cationic polyacrylamide or
products deemed environmentally incompatible
with Code §26-498, or defined as a pollutant
per Code §26-491, or explicitly prohibited by
the U.S. Environmental Protection Agency or
the state of Colorado may not be used for
chemical stabilization. Water soluble plant-
based oils or gums, clay additives, or other
synthetic polymer emulsion that are non-toxic,
non-combustible, and harmless to fish, wildlife,
plants, pets, and humans may be used for
chemical stabilization.
Code shall mean the Fort Collins City Code, as
amended from time to time.
Dust control measure shall mean any action
or process that is used to prevent or mitigate
the emission of fugitive dust into the air,
including but not limited to the best
management practices identified in this
Manual.
Dust generating activity or source shall
mean a process, operation, action, or land use
DRAFT Dust Prevention and Control Manual
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processes or natural forces but is not emitted
through a stack, chimney, or vent
Local wind speed shall mean the current or
forecasted wind speed for the Fort Collins area
as measured at the surface weather
observation station KFNL located at the Fort
Collins Loveland Municipal Airport or at
Colorado State University’s Fort Collins or
Christman Field weather stations or as
measured onsite with a portable or hand-held
anemometer. The City will use anemometers
whenever practicable.
Maximum speed limit shall mean the speed
limit on public rights-of-way adopted by the City
pursuant to Fort Collins Traffic Code adopted
pursuant to City Code Section 28-16 For private
roadways, a speed limit shall be established as
appropriate to minimize off-site transportation
of.
Mechanical blower shall mean any portable
machine powered with an internal combustion
or electric-powered engine used to blow leaves,
clippings, dirt or other debris off sidewalks,
driveways, lawns, medians, and other surfaces
including, but not limited to, hand-held, back-
pack and walk-behind units, as well as blower-
vacuum units.
Off-property transport shall mean the visible
emission of fugitive dust beyond the property
line of the property on which the emission
originates or the project boundary when the
emission originates in the public right-of-way or
on public property.
Off-vehicle transport shall mean the visible
emission of fugitive dust from a vehicle that is
transporting dust generating materials on a
public road or right-of-way.
On-tool local exhaust ventilation shall mean
a vacuum dust collection system attached to a
construction tool that includes a dust collector
(hood or shroud), tubing, vacuum, and a high
efficiency particulate air (HEPA) filter.
On-tool wet dust suppression shall mean the
operation of nozzles or sprayers attached to a
construction tool that continuously apply water
or other liquid to the grinding or cutting area by
a pressurized container or other water source.
Open area shall mean any area of undeveloped
land greater than one-half acre that contains
less than 70 percent vegetation. This includes
undeveloped lots, vacant or idle lots, natural
areas, parks, or other non-agricultural areas.
Recreational and multi-use trails maintained by
the City are not included as an open area.
Operator or owner shall mean any person
who has control over a dust generating source
either by operating, supervising, controlling, or
maintaining ownership of the activity or source
DRAFT Dust Prevention and Control Manual
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exposed and inactive for 30 days or more or
while vegetation is being established using
mulch, compost, soil mats, or other methods.
Stockpile shall mean any accumulation of bulk
materials that contain particulate matter being
stored for future use or disposal. This includes
backfill materials and storage piles for soil,
sand, dirt, mulch, aggregate, straw, chaff, or
other materials that produce dust.
Storm drainage facility shall mean those
improvements designed, constructed or used to
convey or control stormwater runoff and to
remove pollutants from stormwater runoff after
precipitation.
Surface roughening shall mean to modify the
soil surface to resist wind action and reduce
dust emissions from wind erosion by creating
grooves, depressions, ridges or furrows
perpendicular to the predominant wind
direction using tilling, ripping, discing, or other
method.
Synthetic or natural cover shall mean the
installation of a temporary cover material on
top of disturbed soil surfaces or stockpiles, such
as tarps, plastic sheeting, netting, mulch, wood
chips, gravel or other materials capable of
preventing wind erosion.
Track-out shall mean the carrying of mud, dirt,
soil, or debris on vehicle wheels, sides, or
undercarriages from a private, commercial, or
industrial site onto a public road or right-of-
way.
Vegetation shall mean the planting or seeding
of appropriate grasses, plants, bushes, or trees
to hold soil or to create a wind break. All seeded
areas must be mulched, and the mulch should
be adequately crimped and or tackified. If
hydro-seeding is conducted, mulching must be
conducted as a separate, second operation. All
planted areas must be mulched within twenty-
four (24) hours after planting.
Wet suppression shall mean the application of
water by spraying, sprinkling, or misting to
maintain optimal moisture content or to form a
crust in dust generating materials and applied
at a rate that prevents runoff from entering any
public right-of-way, storm drainage facility or
watercourse.
Wind barrier shall mean an obstruction at
least five feet high erected to assist in
preventing the blowing of fugitive dust,
comprised of a solid board fence, chain link and
fabric fence, vertical wooden slats, hay bales,
earth berm, bushes, trees, or other materials
installed perpendicular to the predominant
wind direction or upwind of an adjacent
residential, commercial, industrial, or sensitive
area that would be negatively impacted by
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2.0 Fugitive Dust and the Problems it Causes
2.1 What is Fugitive Dust, Generally?
Dust, also known as particulate matter, is made up of solid particles in the air that consist primarily of
dirt and soil but can also contain ash, soot, salts, pollen, heavy metals, asbestos, pesticides, and other
materials. “Fugitive” dust means particulate matter that has become airborne by wind or human
activities and has not been emitted from a stack, chimney, or vent. The Colorado Department of Public
Health and Environment (CDPHE) estimates that more than 4,300 tons of particulate matter are emitted
into the air in Larimer County annually. The primary sources of this particulate matter include
construction activities, paved and unpaved roads, and agricultural operations.
The quantity of dust emitted from a particular activity or area and the materials in it can depend on the
soil type (sand, clay, silt), moisture content (dry or damp), local wind speed, and the current or past uses
of the site (industrial, farming, construction).
2.2 Why is the City Addressing Fugitive Dust?
Colorado state air regulations and Larimer County air quality standards generally require owners and
operators of dust generating activities or sources to use all available and practical methods that are
technologically feasible and economically reasonable in order to prevent fugitive dust emissions.
However, state regulations and permitting requirements typically apply to larger stationary sources
rather than to activities that generate dust. Larimer County fugitive dust standards apply only to land
development.
Although state and county requirements apply to many construction activities, they do not address
many sources of dust emissions and City code compliance officers do not have authority to enforce state
or county regulations. Fort Collins is experiencing rapid growth and development that has contributed
to local man-made dust emissions. The City has established Article X of Chapter 12 of the Code (§§12-
150-12-159) to address dust generating activities and sources that negatively impact citizens in Fort
Collins.
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2.3 Health and Environmental Effects
Dust particles are very small and can be easily inhaled. They can
enter the respiratory system and increase susceptibility to respiratory
infections, and aggravate cardio-pulmonary disease. Even short-term
exposure to dust can cause wheezing, asthma attacks and allergic
reactions, and may cause increases in hospital admissions and
emergency department visits for heart and lung related diseases.
Fugitive dust emissions can cause significant environmental impacts as well as health effects. When
dust from wind erosion or human activity deposits out of the air, it may impact vegetation, adversely
affect nearby soils and waterways, and cause damage to cultural resources. Wind erosion can result in
the loss of valuable top soil, reduce crop yields, and stunt plant growth.
According to the Environmental Protection Agency (EPA), studies have linked particulate matter
exposure to health problems and environmental impacts such as:
•Health Impacts:
o Irritation of the airways, coughing, and difficulty breathing
o Reduced lung function and lung cancer
o Aggravated asthma and chronic bronchitis
o Irregular heartbeat and increases in heart attacks
•Environmental Impacts:
o Haze and reduced visibility
o Reduced levels of nutrients in soil
2.4 Nuisance and Aesthetics
Dust, dirt and debris that become airborne eventually settle back down to
the surface. How far it travels and where it gets deposited depends on the
size and type of the particles as well as wind speed and direction. When this
material settles, it can be deposited on homes, cars, lawns, pools and ponds,
and other property. The small particles can get trapped in machinery and
electronics causing abrasion, corrosion, and malfunctions. The deposited
dust can damage painted surfaces, clog filtration systems, stain materials and
cause other expensive clean-up projects.
2.5 Safety Hazard and Visibility
Blowing dust can be a safety hazard at construction sites and on roads and
highways. Dust can obstruct visibility and can cause accidents between
vehicles and bikes, pedestrians, or site workers. Dust plumes can also
decrease visibility across a natural area or scenic vistas. The “brown cloud”,
often visible along the Front Range during the winter months, and the
brilliant red sunsets that occur are often caused by particulate matter and
other pollutants in the air.
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3.0 Best Management Practices
This Manual describes established best management practices for controlling dust emissions that are
practical and used in common practice to prevent or mitigate impacts to air quality from dust generating
activities and sources occurring within Fort Collins. The objective of the dust control measures included
in this Manual are to reduce dust emissions from human activities and to prevent those emissions from
impacting others and are based on the following principles:
Prevent – avoid creating dust emissions through good project planning and modifying or
replacing dust generating activities.
Minimize – reduce dust emissions with methods that capture, collect, or contain emissions.
Mitigate – when preventing fugitive dust or minimizing the impacts are not feasible, the
Manual provides specific measures to mitigate dust.
More specifically, the Manual establishes the following procedures for each dust generating activity
outlined in this Chapter:
1. Required Best Management Practices – this section includes the specific measures that are
required to be implemented if the dust generating activity is occurring. For example, high wind
restrictions (temporarily halting work when wind speeds exceed 30 mph) are required best
management practices for earthmoving, demolition/renovation, saw cutting or grind, abrasive
blasting, and leaf blowing.
2. Additional Best Management Practices – this section includes additional measures if the
required best management practices are ineffective at preventing off-property transport of
particulate matter. At least one of the additional best management practices outlined in the
Manual must be implemented on the site to be in compliance with the Manual and Code.
3. Additional Requirements – When applicable, additional measures are also required, e.g., a dust
control plan when project sites are over 5 acres in size.
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3.1 Earthmoving Activities
Above: This figure illustrates earthmoving, which is an activity that can generate dust.
Dust emissions from earthmoving activities depend on the type and extent of activity being conducted,
the amount of exposed surface area, wind conditions, and soil type and moisture content, including:
Site preparation (clearing, grubbing, scraping)
Road construction
Grading and overlot grading
Excavating, trenching, backfilling and compacting
Loading and unloading dirt, soil, gravel, or other earth materials
Dumping of dirt, soil, gravel, or other earth materials into trucks, piles, or receptacles
Screening of dirt, soil, gravel, or other earth materials
Best Management Practices to Control Dust
(a) Required Best Management Practices: Any person, owner, or operator who conducts earthmoving
that is a dust generating activity or source shall implement the following best management practices to
prevent off-property transport of fugitive dust emissions:
(i) Minimize disturbed area: plan the project or activity so that the minimum amount of
disturbed soil or surface area is exposed to wind or vehicle traffic at any one time.
(ii) Reduce vehicle speeds: establish a maximum speed limit or install traffic calming devices to
reduce speeds to a rate to mitigate off-property transport of dust entrained by vehicles.
(iii) Minimize drop height: Drivers and operators shall unload truck beds and loader or
excavator buckets slowly, and minimize drop height of materials to the lowest height possible,
including screening operations.
(iv) High winds restriction: temporarily halt work activities during high wind events greater than
30 mph if operations would result in off-property transport.
(v) Restrict access: restrict access to the work area to only authorized vehicles and personnel.
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(b) Additional Best Management Practices: In the event 3.1(a)(i)-(v) are ineffective to prevent off-
property transport, the person, owner, or operator shall use at least one of the following best
management practices:
(i) Wet suppression: apply water to disturbed soil surfaces, backfill materials, screenings, and
other dust generating operations as necessary and appropriate considering current weather
conditions, and prevent water used for dust control from entering any public right-of-way,
stormwater drainage facility, or watercourse.
(ii) Wind barrier: construct a fence or other type of wind barrier to prevent wind erosion of top
soils.
(iii) Vegetation: plant vegetation appropriate for retaining soils or creating a wind break.
(iv) Surface roughening: stabilize an active construction area during periods of inactivity or
when vegetation cannot be immediately established.
(v) Synthetic or natural cover: install cover materials during periods of inactivity and properly
anchor the cover.
(vi) Soil retention: stabilize disturbed or exposed soil surface areas that will be inactive for more
than 30 days or while vegetation is being established.
(vii) Chemical stabilization: apply chemical stabilizers using manufacturer’s recommended
application rates. Avoid over-application and prevent runoff of chemical stabilizers into any
public right-of-way, storm drainage facility, or watercourse. Asphalt-based products or any
product containing cationic polyacrylamide or products deemed environmentally incompatible
with Code §26-498, or defined as a pollutant per Code §26-491, or explicitly prohibited by the
U.S. Environmental Protection Agency or the state of Colorado may not be used for chemical
stabilization. Water soluble plant-based oils or gums, clay additives, or other synthetic polymer
emulsion that are non-toxic, non-combustible, and harmless to fish, wildlife, plants, pets, and
humans may be used for chemical stabilization.
(c) Additional requirements: Any person, owner, or operator who conducts earthmoving that is a dust
generating activity or source at a construction site or land development project with a total disturbed
surface area equal to or greater than five (5) acres also shall implement the following measures:
(i) Dust Control Plan: submit a plan that describes all potential sources of fugitive dust and
methods that will be employed to control dust emissions with the development construction
permit application or development review application (see Chapter 4 of this Manual). A copy of
the Dust Control Plan must be onsite at all times and one copy must be provided to all
contractors and operators engaged in dust generating activities at the site.
(ii) Construction sequencing: include sequencing or phasing in the project plan to minimize the
amount of disturbed area at any one time. Sites with greater than 25 acres of disturbed surface
exposed at any one time may be asked to provide additional justification, revise the sequencing
plan, or include additional best management practices.
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3.2 Demolition and Renovation
Above: This photo illustrates restricting access (a mandatory measure) and a wind barrier (an
engineering control) for demolition and renovation activities.
Dust generated from demolition activities may contain significant levels of silica, lead, asbestos, and
particulate matter. Inhalation of silica and asbestos is known to cause lung cancer, and exposure to
even small quantities of lead dust can result in harm to children and the unborn.
In addition to complying with the dust control measures below, any person engaged in demolition or
renovation projects must comply with applicable state and federal regulations for asbestos and lead
containing materials and notification and inspection requirements under the State of Colorado Air
Quality Control Commission's Regulation No. 8, Part B Control of Hazardous Air pollutants.
Best Management Practices to Control Dust
(a) Required Best Management Practices: Any person, owner, or operator who conducts demolition or
renovation that is a dust generating activity or source shall implement the following best management
practices to prevent off-property transport of fugitive dust emissions:
(i) Asbestos and lead containing materials: demolition and renovation activities that involve
asbestos or lead containing materials must be conducted in accordance with Code Chapter 5
Sec. 5-27 (59) §3602.1.1;
(ii) Restrict access: restrict access to the demolition area to only authorized vehicles and
personnel;
(iii) High winds restriction: temporarily halt work activities during high wind events greater than
30 mph if operations would result in off-property transport; and
(iv) Minimize drop height: Drivers and operators shall unload truck beds and loader or excavator
buckets slowly, and minimize drop height of materials to the lowest height possible, including
screening operations.
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(b) Additional Best Management Practices: In the event 3.2(a)(i)-(iv) are ineffective to prevent off-
property transport, the person, owner, or operator shall use at least one of the following best
management practices:
(i) Wet suppression: apply water to demolished materials or pre-wet materials to be
demolished as necessary. Prevent water used for dust control from entering any public right-of-
way, storm drainage facility, or watercourse.
(ii) Chemical stabilization: apply chemical stabilizers to demolished materials or materials to be
demolished using manufacturer’s recommended application rates. Avoid over-application and
prevent runoff of chemical stabilizers into any public right-of-way, storm drainage facility, or
watercourse. Asphalt-based products or any product containing cationic polyacrylamide or
products deemed environmentally incompatible with Code §26-498, or defined as a pollutant
per Code §26-491, or explicitly prohibited by the U.S. Environmental Protection Agency or the
state of Colorado may not be used for chemical stabilization. Water soluble plant-based oils or
gums, clay additives, or other synthetic polymer emulsion that are non-toxic, non-combustible,
and harmless to fish, wildlife, plants, pets, and humans may be used for chemical stabilization.
(iii) Wind barrier: construct a fence or other type of wind barrier to prevent onsite dust
generating materials from blowing offsite.
(c) Additional requirements:
(i) Building permit compliance: comply with all conditions and requirements under any building
required pursuant to the Code and/or the Land Use Code.
Above: This photo illustrates reducing drop height, a mandatory measure.
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3.3 Stockpiles
Above: This photo illustrates wet suppression, an engineering control for stockpiles.
Stockpiles are used for both temporary and long-term storage of soil, fill dirt, sand, aggregate,
woodchips, mulch, asphalt and other industrial feedstock, construction and landscaping materials.
Fugitive dust can be emitted from stockpiles while working the active face of the pile or when wind
blows across the pile. The quantity of emissions depends on pile height and exposure to wind, moisture
content and particle size of the pile material, surface roughness of the pile, and frequency of pile
disturbance.
Best Management Practices to Control Dust
(a) Required Best Management Practices: Any owner or operator of a stockpile that is a dust generating
activity or source shall implement the following best management practices to prevent off property
transport of fugitive dust emissions:
(i) Minimize drop height: Drivers and operators shall unload truck beds and loader or excavator
buckets slowly, and minimize drop height of materials to the lowest height possible, including
screening operations.
(b) Additional Best Management Practices: In the event 3.3(a)(i) is ineffective to prevent off-property
transport, the person, owner, or operator shall use at least one of the following best management
practices:
(i) Wet suppression: Apply water to the active face when working the pile or to the entire pile
during periods of inactivity. Prevent water used for dust control from entering any public right-
of-way, storm drainage facility, or watercourse.
(ii) Synthetic or natural cover: install cover materials during periods of inactivity and anchor the
cover.
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(iii) Surface roughening: stabilize a stockpile during periods of inactivity or when vegetation
cannot be immediately established.
(iv) Stockpile location: locate stockpile at a distance equal to ten times the pile height from
property boundaries that abut residential areas.
(v) Vegetation: seed and mulch any stockpile that will remain inactive for 30 days or more.
(vi) Chemical stabilization: apply chemical stabilizers using manufacturer’s recommended
application rates. Avoid over-application and prevent runoff of chemical stabilizers into any
public right-of-way, storm drainage facility, or watercourse. Asphalt-based products or any
product containing cationic polyacrylamide or products deemed environmentally incompatible
with Code §26-498, or defined as a pollutant per Code §26-491, or explicitly prohibited by the
U.S. Environmental Protection Agency or the state of Colorado may not be used for chemical
stabilization. Water soluble plant-based oils or gums, clay additives, or other synthetic polymer
emulsion that are non-toxic, non-combustible, and harmless to fish, wildlife, plants, pets, and
humans may be used for chemical stabilization.
(vii) Enclosure: construct a three-sided structure equal to or greater than the height of the pile
to shelter the pile from the predominant winds.
(c) Additional requirements:
(i) Stockpile permit compliance: comply with all conditions and requirements under any
stockpile permit required under the Code or the r Land Use Code.
(ii) Erosion control plan compliance: implement and comply with all conditions and
requirements in Section §26-500 “Fort Collins Storm Criteria”; specifically, Volume 3 Chapter 7
“Construction BMPs”. The criteria requirement may require the use of Erosion Control
Materials, soil stockpile height limit of ten feet, watering, surface roughening, vegetation, silt
fence and other control measures as contained in that chapter.
Left: This
picture
illustrates
one of the
additional
best
management
practices for
stockpiles –
to use a
synthetic
cover.
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3.4 Street Sweeping
Left: This figure illustrates the use
of a wet suppression and vacuum
system, an additional best
management practice for street
sweeping.
Street sweeping is an effective method for removing dirt and debris from streets and preventing it from
entering storm drains or becoming airborne. Regenerative air sweepers and mechanical sweepers with
water spray can also be effective at removing particulate matter from hard surfaces.
Best Management Practices to Control Dust
(a) Required Best Management Practices: Any owner or operator that conducts sweeping operations or
services on paved or concrete roads, parking lots, rights-of-way, pedestrian ways, plazas or other solid
surfaces, and whose operations are a dust generating activity or source shall implement all of the
following best management practices to prevent off-property transport of fugitive dust emissions:
(i) Uncontrolled sweeping prohibited: the use of rotary brushes, power brooms, or other
mechanical sweeping for the removal of dust, dirt, mud, or other debris from a paved public
road, right-of-way, or parking lot without the use of water, vacuum system with filtration, or
other equivalent dust control method is prohibited. Mechanical or manual sweeping that occurs
between lifts of asphalt paving operations is excluded from this prohibition, due to engineering
requirements associated with these operations.
(b) Additional Best Management Practices: In the event 3.4(a)(i) is ineffective to prevent off-property
transport, the person, owner, or operator shall use at least one of the following best management
practices:
(i) Wet suppression: use a light spray of water or wetting agent applied directly to work area or
use equipment with water spray system while operating sweeper or power broom. Prevent
water used for dust control from entering any storm drainage facility or watercourse.
(ii) Vacuum system: use sweeper or power broom equipped with a vacuum collection and
filtration system.
(iii) Other method: use any other method to control dust emissions that has a demonstrated
particulate matter control efficiency of 80 percent or more.
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3.5 Track-out / Carry-out
Above: This figure illustrates an installed grate (left) and a gravel bed (right), both of which are
additional best management practices associated with track-out/carry-out.
Mud, dirt, and other debris can be carried from a site on equipment’s wheels or undercarriage onto
public roads. When this material dries, it can become airborne by wind activity or when other vehicles
travel on it. This is a health concern and can cause visibility issues and safety hazards.
Best Management Practices to Control Dust
(a) Required Best Management Practices: Any owner or operator of any operation that has the
potential to result in track-out of dirt, dust, or debris on public roads and rights-of-way and whose
operation is a dust generating activity or source shall implement the following best management
practices to prevent off-property transport of fugitive dust emissions:
(i) Contracts and standards: comply with track-out prevention requirements and construction
best management practices as set forth in the Code, City regulations, or policies and as
specified in applicable contract documents or Fort Collins Stormwater Criteria Manual.
(ii) Remove deposition: promptly remove any deposition that occurs on public roads or rights-
of-way as a result of the owner’s or operator’s operations. Avoid over-watering and prevent
runoff into any storm drainage facility or watercourse.
(b) Additional Best Management Practices: In the event 3.5(a)(i)-(ii) are ineffective to prevent off-
property transport, the person, owner, or operator shall use at least one of the following best
management practices:
(i) Install rails, pipes, grate, or similar track-out control device.
(ii) Install a gravel bed track-out apron that extends at least 50 feet from the intersection with a
public road or right-of-way.
(iii) Install gravel bed track-out apron with steel cattle guard or concrete wash rack.
(iv) Install and utilize on-site vehicle and equipment washing station.
(v) Install a paved surface that extends at least 100 feet from the intersection with a public road
or right-of-way.
(vi) Manually remove mud, dirt, and debris from equipment and vehicle wheels, tires and
undercarriage.
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3.6 Bulk Materials Transport
Above: This figure illustrates covered loads, a required best management practice for bulk materials
transport.
Haul trucks are used to move bulk materials, such as dirt, rock, demolition debris, or mulch to and from
construction sites, material suppliers and storage yards. Dust emissions from haul trucks, if
uncontrolled, can be a safety hazard by impairing visibility or by depositing debris on roads, pedestrians,
bicyclists, or other vehicles.
Best Management Practices to Control Dust
(a) Required Best Management Practices: Any owner or operator of a dust generating activity or source
for which vehicles used for transporting bulk materials to and from a site within the City on a public or
private road or on a public right-of-way shall prevent off-vehicle transport of fugitive dust emissions. To
prevent off-vehicle transport of fugitive dust to and from the site, the owner or operator shall
implement the following measures :
(i) Cover Loads: Loads shall be completely covered or all material enclosed in a manner that
prevents the material from blowing, dropping, sifting, leaking, or otherwise escaping from the
vehicle. This includes the covering of hot asphalt and asphalt patching material with a tarp or
other impermeable material.
(ii) Minimize drop height: Drivers and operators shall unload truck beds and loader or excavator
buckets slowly, and minimize drop height of materials to the lowest height possible, including
screening operations.
(b) Additional Best Management Practices: In the event 3.6(a)(i)-(ii) are ineffective to prevent off-
vehicle transport, the person, owner, or operator shall use at least one of the following best
management practices:
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(i) Wet suppression: apply water to bulk materials loaded for transport as necessary to prevent
fugitive dust emissions and deposition of materials on roadways. Prevent water used for dust
control from entering any public right-of-way, storm drainage facility, or watercourse.
(ii) Chemical stabilization: apply chemical stabilizers using manufacturer’s recommended
application rates. Avoid over-application and prevent runoff of chemical stabilizers into any
public right-of-way, storm drainage facility, or watercourse. Asphalt-based products or any
product containing cationic polyacrylamide or products deemed environmentally incompatible
with Code §26-498, or defined as a pollutant per Code §26-491, or explicitly prohibited by the
U.S. Environmental Protection Agency or the state of Colorado may not be used for chemical
stabilization. Water soluble plant-based oils or gums, clay additives, or other synthetic polymer
emulsion that are non-toxic, non-combustible, and harmless to fish, wildlife, plants, pets, and
humans may be used for chemical stabilization.
(iii) Other technology: use other equivalent technology that effectively eliminates off-vehicle
transport, such as limiting the load size to provide at least three inches of freeboard to prevent
spillage.
Above: This figure illustrates minimizing drop heights, a required best management practice for bulk
materials transport.
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3.7 Unpaved Roads and Haul Roads
Above: This figure illustrates surface improvements on an unpaved road, an additional best management
practice.
Road dust from unpaved roads is caused by particles lifted by and dropped from rolling wheels traveling
on the road surface and from wind blowing across the road surface. Road dust can aggravate heart and
lung conditions as well as cause safety issues such as decreased driver visibility and other safety hazards.
Best Management Practices to Control Dust
(a) Required Best Management Practices: Any owner or operator of an unpaved road located on a
construction site greater than five acres on private property or an unpaved road used as a public right-
of-way shall implement the following best management practices to prevent off-property transport of
fugitive dust emissions:
(i) Reduce vehicle speeds: establish a maximum speed limit or install traffic calming devices to
reduce speeds to a rate that prevents off-property transport of dust entrained by vehicles.
(ii) Restrict access: restrict travel on unpaved roads by limiting access to only authorized vehicle
use.
(b) Additional Best Management Practices: In the event 3.7(a)(i)-(ii) are ineffective to prevent off-
property transport, the person, owner, or operator shall use at least one of the following best
management practices:
(i) Wet suppression: apply water to unpaved road surface as necessary and appropriate
considering current weather conditions, and prevent water used for dust control from entering
any public right-of-way, storm drainage facility, or watercourse.
(ii) Surface improvements: install gravel or similar materials with sufficient depth to reduce dust
or pave high traffic areas.
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(iii) Chemical stabilization: apply chemical stabilizers appropriate for high traffic areas using
manufacturer’s recommended application rates. Avoid over-application and prevent runoff of
chemical stabilizers into any public right-of-way, storm drainage facility, or watercourse.
Asphalt-based products or any product containing cationic polyacrylamide or products deemed
environmentally incompatible with Code §26-498, or defined as a pollutant per Code §26-491,
or explicitly prohibited by the U.S. Environmental Protection Agency or the state of Colorado
may not be used for chemical stabilization. Water soluble plant-based oils or gums, clay
additives, or other synthetic polymer emulsion that are non-toxic, non-combustible, and
harmless to fish, wildlife, plants, pets, and humans may be used for chemical stabilization.
(iv) Access road location: locate site access roads away from residential or other populated
areas.
Above: This figure illustrates wet suppression, an additional best management practice for
unpaved or haul roads.
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3.8 Parking Lots
Above: This figure illustrates an unpaved parking lot in Fort Collins.
This section applies to paved and unpaved areas where vehicles are parked or stored on a routine basis
and includes parking areas for shopping, recreation, or events; automobile or vehicle storage yards; and
animal staging areas.
Best Management Practices to Control Dust- Unpaved Parking Lots
(a) Required Best Management Practices: Any owners or operator of an unpaved parking lot greater
than one-half acre shall use at least one of the following best management practices to prevent off-
property transport of fugitive dust emissions
(i) Surface improvements: install gravel or similar materials with sufficient depth to reduce dust
or pave high traffic areas.
(ii) Vegetation: plant vegetation appropriate for retaining soils or creating a wind break.
(iii) Wet suppression: apply water as necessary and appropriate considering current weather
conditions to prevent off-property transport of fugitive dust emissions. Prevent water used for
dust control from entering any public right-of-way, storm drainage facility, or watercourse.
(iv) Chemical stabilization: apply chemical stabilizers appropriate for high traffic areas using
manufacturer’s recommended application rates. Avoid over-application and prevent runoff of
chemical stabilizers into any public right-of-way, storm drainage facility, or watercourse.
Asphalt-based products or any product containing cationic polyacrylamide or products deemed
environmentally incompatible with Code §26-498, or defined as a pollutant per Code §26-491,
or explicitly prohibited by the U.S. Environmental Protection Agency or the state of Colorado
may not be used for chemical stabilization. Water soluble plant-based oils or gums, clay
additives, or other synthetic polymer emulsion that are non-toxic, non-combustible, and
harmless to fish, wildlife, plants, pets, and humans may be used for chemical stabilization.
(v) Wind barrier: construct a fence or other type of wind barrier.
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(vi) Reduce vehicle speeds: establish a maximum speed limit or install traffic calming devices to
reduce speeds to a rate that prevents off-property transport of dust entrained by vehicles.
(vii) Restrict access: restrict travel in parking lots to only those vehicles with essential duties and
limit access to hours of operation or specific events.
Best Management Practices to Control Dust- Paved Parking Lots
(a) Required Best Management Practices: An owner or operator of a paved parking lot greater than
one-half acre and shall use at least one of the following best management practices to prevent off-
property transport of fugitive dust emissions.
(i) Maintenance: repair potholes and cracks and maintain surface improvements.
(ii) Mechanical sweeping: Sweep lot with a vacuum sweeper and light water spray as necessary
to remove dirt and debris. Avoid overwatering and prevent runoff from entering any public
right-of-way, storm drainage facility, or watercourse.
(iii) Reduce vehicle speeds: establish a maximum speed limit or install traffic calming devices to
reduce speeds to a rate that prevents off-property transport of dust entrained by vehicles.
(iv) Restrict access: restrict travel in parking lots to only those vehicles with essential duties and
limit access to hours of operation or specific events.
Above: This photo represents improving the surface of a parking area, which is one measure to
comply with the Manual.
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3.9 Open Areas and Vacant Lots
Above: These photos illustrate open areas in Fort Collins, which have the potential to generate dust.
Open areas are typically not a significant source of wind-blown dust emissions if the coverage of
vegetation is sufficient or soil crusts are intact. However, if soils in open areas are disturbed by vehicle
traffic, off-highway vehicle use, bicycling or grazing, or if they have become overpopulated by prairie
dogs, dust emissions can become a problem.
Best Management Practices to Control Dust
(a) Required Best Management Practices: Any owner or operator of an open area greater than one-half
acre shall use at least one of the following best management practices to stabilize disturbed or exposed
soil surface areas that are intended to or remain exposed for 30 days or more and to prevent off-
property transport of fugitive dust emissions:
(i) Vegetation: plant vegetation appropriate for retaining soils or creating a wind break.
(ii) Synthetic or natural cover: install cover materials over exposed areas during periods of
inactivity and properly anchor the cover.
(iii) Surface roughening: stabilize an exposed area during periods of inactivity or when
vegetation cannot be immediately established.
(iv) Soil retention: stabilize disturbed or exposed soil surface areas that will be inactive for more
than 30 days or while vegetation is being established, using mulch, compost, soil mats, or other
methods.
(v) Wet suppression: apply water to disturbed soil surfaces as necessary and appropriate
considering current weather to prevent off-property transport of fugitive dust emissions.
Prevent water used for dust control from entering any public right-of-way, storm drainage
facility, or watercourse.
(vi) Wind barrier: construct a fence or other type of wind barrier to prevent wind erosion of top
soils.
(vii) Chemical stabilization: apply chemical stabilizers using manufacturer’s recommended
application rates. Avoid over-application and prevent runoff of chemical stabilizers into any
public right-of-way, storm drainage facility, or watercourse. Asphalt-based products or any
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product containing cationic polyacrylamide or products deemed environmentally incompatible
with Code §26-498, or defined as a pollutant per Code §26-491, or explicitly prohibited by the
U.S. Environmental Protection Agency or the state of Colorado may not be used for chemical
stabilization. Water soluble plant-based oils or gums, clay additives, or other synthetic polymer
emulsion that are non-toxic, non-combustible, and harmless to fish, wildlife, plants, pets, and
humans may be used for chemical stabilization.
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3.10 Saw Cutting and Grinding
Above: This photo illustrates concrete cutting and how the activity can generate dust.
Cutting and grinding of asphalt, concrete and other masonry materials can be a significant short-term
source of fugitive dust that may expose workers and the public to crystalline silica. Inhalation of silica
can cause lung disease known as silicosis and has been linked to other diseases such as tuberculosis and
lung cancer. Using additional best management practices during cutting and grinding operations can
significantly reduce dust emissions.
Best Management Practices to Control Dust
(a) Required Best Management Practices: Any person, owner, or operator that cuts or grinds asphalt,
concrete, brick, tile, stone, or other masonry materials and whose operations are a dust generating
activity or source shall use the following best management practices to prevent off-property transport
of fugitive dust emissions:
(i) Restrict access: prevent the public from entering the area where dust emissions occur.
(ii) High winds restriction: temporarily halt work activities during high wind events greater than
30 mph if operations would result in off-property transport.
(iii) Equipment and work area clean up: use wet wiping, wet sweeping, or vacuuming with HEPA
filtration for equipment and work area clean up and do not cause dust to become airborne
during clean up.
(iv) Slurry clean up: prevent water used for dust control or clean up from entering any public
right-of-way, storm drainage facility, or watercourse by using containment, vacuuming,
absorption, or other method to remove the slurry, and dispose of slurry and containment
materials properly. Follow additional procedures prescribed in the City’s Fort Collins Stormwater
Criteria Manual or contract documents and specifications.
(b) Additional Best Management Practices: In the event 3.10(a)(i)-(iv) are ineffective to prevent off-
property transport, the person, owner, or operator shall use at least one of the following best
management practices:
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(i) On-tool local exhaust ventilation: use a tool-mounted dust capture and collection system.
(ii) On-tool wet suppression: use a tool-mounted water application system.
(iii) Vacuuming: use a vacuum equipped with a HEPA filter simultaneously with cutting or
grinding operations.
(iv) Wet suppression: use a water sprayer or hose simultaneously with cutting or grinding
operations.
(v) Enclosure: conduct cutting or grinding within an enclosure with a dust collection system or
temporary tenting over the work area.
Above: These photos illustrate how dust generated from cutting can be minimized by applying on-tool
wet suppression, an additional best management practice associated with saw cutting and grinding.
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3.11 Abrasive Blasting
Above: This photo illustrates abrasive blasting without dust mitigation in place.
Abrasive blasting is used to smooth rough surfaces; roughen smooth surfaces; and remove paint, dirt,
grease, and other coatings from surfaces. Abrasive blasting media may consist of sand; glass, plastic or
metal beads; aluminum oxide; corn cobs; or other materials. Abrasive blasting typically generates a
significant amount of fugitive dust if not controlled. The material removed during abrasive blasting can
become airborne and may contain silica, lead, cadmium or other byproducts removed from the surface
being blasted.*
Best Management Practices to Control Dust
(a) Required Best Management Practices: Any person, owner, or operator who conducts outdoor
abrasive blasting or indoor abrasive blasting with uncontrolled emissions vented to the outside and
whose operations are a dust generating activity or source shall implement all of the following best
management practices to prevent off-property transport of fugitive dust emissions:
(i) Restrict access: prevent the public from entering the area where dust emissions occur.
(ii) High winds restriction: temporarily halt work activities during high wind events greater than
30 mph if operations would result in off-property transport.
(iii) Equipment and work area clean up: use wet wiping, wet sweeping, or vacuuming with HEPA
filtration for equipment and work area clean up and do not cause dust to become airborne
during clean up.
(iv) Slurry clean up: prevent water used for dust control or clean up from entering any public
right-of-way, storm drainage facility, or watercourse by using containment, vacuuming,
absorption, or other method to remove the slurry, and dispose of slurry and containment
materials properly.
(b) Additional Best Management Practices: In the event 3.11(a)(i)-(iv) are ineffective to prevent off-
property transport, the person, owner, or operator shall use at least one of the following best
management practices:
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(i) Enclosure: conduct abrasive blasting within an enclosure with a dust collection system or
temporary tenting over the work area.
(ii) Wet suppression blasting: use one of several available methods that mix water with the
abrasive media or air during blasting operations.
(iii) Vacuum blasting: conduct air-based blasting that uses a nozzle attachment with negative air
pressure to capture dust.
(iv) Abrasive media: select less toxic, lower dust-generating blasting media.
* Blasting on surfaces that contain lead paint or wastes from sand blasting that contain hazardous materials may be subject
to additional state and federal requirements.
Above: This photo illustrates wet suppression blasting, an additional best management practice.
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3.12 Mechanical Blowing
Above: This photo illustrates mechanical blowing without dust mitigation in place.
Mechanical blowers are commonly used to move dirt, sand, leaves, grass clippings and other
landscaping debris to a central location for easier pick-up and removal. Mechanical blowing with a leaf
blower can be a significant source of fugitive dust in some situations and can create nuisance conditions
and cause health effects for sensitive individuals. Mechanical blowing can resuspend dust particles that
contain allergens, pollens, and molds, as well as pesticides, fecal contaminants, and toxic metals causing
allergic reactions, asthma attacks and exacerbating other respiratory illnesses.
Best Management Practices to Control Dust
(a) Required Best Management Practices: Any person, owner, or operator who operates a mechanical
leaf blower (gas, electric, or battery-powered) in a manner that is a dust generating activity or source
shall use at least one of the following best management practices as necessary to prevent off-property
transport of fugitive dust emissions
(i) Low speed: use the lowest speed appropriate for the task and equipment.
(ii) Operation: use the full length of the blow tube and place the nozzle as close to the ground as
possible.
(iii) High winds restriction: temporarily halt work activities during high wind events greater than
30 mph if operations would result in off-property transport.
(b) Additional Best Management Practices: In the event 3.11(a)(i)-(iii) are ineffective to prevent off-
property transport, the person, owner, or operator shall use at least one of the following best
management practices:
(i) Alternative method: use an alternative such as a rake, broom, shovel, manually push
sweeper or a vacuum machine equipped with a filtration system.
(ii) Prevent impact: do not blow dust and debris off-property or in close proximity to people,
animals, open windows, air intakes, or onto adjacent property, public right-of-way, storm
drainage facility, or watercourse.
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(iii) Minimize use on dirt: minimize the use of mechanical blower on unpaved surfaces, road
shoulders, or loose dirt.
(iv) Wet suppression: use a light spray of water, as necessary and appropriate considering
current weather conditions, to dampen dusty work areas. Prevent water, dirt, and debris from
entering any storm drainage facility, or watercourse.
(v) Remove debris: remove and properly dispose of blown material immediately.
Above: These photos illustrate alternative methods to mechanical blowing that can minimize dust
generation.
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4.0 Dust Control Plan for Land Development Greater Than Five Acres
A dust control plan is required for all development projects or construction sites with a total disturbed
surface area equal to or greater than five (5) acres. If the project is required to obtain a development
construction permit, then the dust control plan shall be submitted with the development review
application or the development construction permit application. A copy of the dust control plan shall be
available onsite at all times for compliance and inspection purposes.
For dust control plans associated with a Development Construction Permit (DCP), applications for the
DCP are available online at www.fcgov.com/developmentreview/applications.php. The dust control plan
may be submitted on the Dust Control Plan Form included in Chapter 4 of this Manual or other
equivalent format and shall include the following information:
Project name and location.
Name and contact information of property owner.
Project start and completion dates.
Name and contact information of the developer, general contractor, and each contractor or
operator that will be engaged in an earthmoving activity.
Total size of the development project or construction site in acres.
A description of the project phasing or sequencing of the project to minimize the amount of
disturbed surface area at any one time during the project.
A list of each dust generating activity or source associated with the project.
A list of each best management practice and engineering control that will be implemented for
each dust generating activity or source.
A list of additional best management practices that will be implemented if initial controls are
ineffective.
A signed statement from the property owner, developer, general contractor, and each
contractor or operator engaged in an earthmoving activity acknowledging receipt of the Dust
Control Plan and an understanding of and ability to comply with the best management practices
in the plan.
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DUST CONTROL PLAN
PROJECT INFORMATION
Project Name
Project Location
Start and Completion Dates
Total Size of Project Site (acres)
Maximum disturbed surface area at
any one time (acres)
Property Owner
name, address, phone, e-mail
Developer
name, address, phone, e-mail
General Contractor
name, address, phone, e-mail
Subcontractor or Operator
of a dust generating activity or source
name, address, phone, e-mail
Subcontractor or Operator
of a dust generating activity or source
name, address, phone, e-mail
Subcontractor or Operator
of a dust generating activity or source
name, address, phone, e-mail
PROJECT PHASING OR SEQUENCING
Provide a description of how this project will be phased or sequenced to minimize the disturbed surface
area. Attach phasing plan or map if available.
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DUST CONTROL PLAN CERTIFICATION
I certify the information and attachments contained in this Dust Control Plan are true and correct to the
best of my knowledge and that I and the project's subcontractors have received a copy of this Dust
Control Plan and acknowledge my understanding of and ability to comply with best management
practices for controlling fugitive dust emissions. I hereby permit City officials to enter upon the property
for the purpose of inspection of any dust generating activity or source for which I am the responsible
person, owner, or operator.
Name: ________________________________________________________________________________
Title: ___________________________________ Role on project: ________________________________
Address: ________________________________________________ Phone:
__________________________
Signature: ___________________________________________________ Date: ____________________
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
List of Subcontractors:
Title: ___________________________________ Role on project: ________________________________
Title: ____________________________________ Role on project: ________________________________
Title: ___________________________________ Role on project: ________________________________
Title: ____________________________________Role on project: ________________________________
Title: ____________________________________Role on project: ________________________________
Title: ___________________________________ Role on project: ________________________________
Title: ___________________________________ Role on project: ________________________________
Title: ___________________________________ Role on project: ________________________________
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Instructions: Place an X in each box indicating all best management practices that will be implemented for each dust
generating activity. Please refer to the Dust Prevention and Control Manual for requirements.
Dust Generating Activity
/Best Management Practice
Earthmoving
Demolition/
Renovation
Stockpile
Street Sweeping
Track-out /Carry-
out
Bulk Materials
Transport
Unpaved Roads
and Haul Roads
Parking Lot
Open Area
Saw Cutting or
Grinding
Abrasive Blasting
Leaf Blowing
.
Abrasive media
Asbestos or lead materials
Building permit
Chemical stabilization
Construction sequencing
Drop height
Enclosure
Equipment &work area clean up
Erosion Control plan
High winds restriction
Load cover
Leaf blowing techniques
Location
Minimize disturbed area
On-tool local exhaust ventilation
On-tool wet suppression
Other method
Reduce vehicle speeds
Remove deposition
Restrict access
Slurry clean up
Soil retention
Stockpile permit
Surface improvements
Surface roughening
Sweeping
Synthetic or natural cover
Track-out prevention system
Uncontrolled sweeping prohibited
Vacuum
Vegetation
Wet suppression
Wind barrier
Describe any additional dust generating activities and best management practices that will be used:
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5.0 Resources
5.1 Cross Reference to Codes, Standards, Regulations, and Policies
Earthmoving Activities
Fort Collins Land Use Code Article 3 General Development Standards §3.2.2 Access, Circulation and
Parking.
Fort Collins Land Use Code Article 3 General Development Standards §3.4.1(N) Standards for Protection
During Construction.
Fort Collins Land Use Code Article 3 General Development Standards §3.4.2 Air Quality.
Fort Collins City Code, Chapter 5 Buildings and Building Regulations, Section 5-27 (59) §3602.1.1
Building demolitions.
Fort Collins City Code Chapter 20 Nuisances, Article 1 In General, §20-1 Air pollution nuisances
prohibited.
Fort Collins City Code Chapter 23 Public Property §23-16. Permit required; exception in case of
emergency.
Fort Collins City Code Chapter 26 Utilities, Article VII Stormwater Utility, §26-498 Water quality control.
Fort Collins Stormwater Criteria Manual, Volume 3, Chapter 7, Section 1.3 Policy, Standards and
Submittal Requirements, §1.3.3.e.5.
Fort Collins Stormwater Criteria Manual – Fact Sheet SM-1 Construction Phasing/Sequencing and Fact
Sheet EC-1 Surface Roughening.
Larimer County Land Use Code §8.11.4. Fugitive dust during construction.
State of Colorado, Air Quality Control Commission, 5 CCR 1001-3, Regulation No. 1, §III.D.2.b
Construction Activities.
OSHA Safety and Health Regulations for Construction 29 CFR Part 1926.55 Gases, vapors, fumes, dusts,
and mists.
Demolition and Renovation
Fort Collins Land Use Code, Division 2.7 Building Permits §2.7.1
Fort Collins City Code, Chapter 5 Buildings and Building Regulations, Section 5-27 (59) §3602.1.1
Building demolitions.
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Fort Collins City Code Chapter 20 Nuisances, Article 1 In General, §20-1 Air pollution nuisances
prohibited.
Fort Collins City Code Chapter 26 Utilities, Article VII Stormwater Utility, §26-498 Water quality control.
State of Colorado, Air Quality Control Commission, Regulation Number 8, Part B Control of Hazardous
Air Pollutants, 5 CCR 1001-10.
Stockpiles
Fort Collins Land Use Code, Division 2.6 Stockpiling Permits and Development Construction Permits
§2.6.2.
Fort Collins Land Use Code §2.6.3 (K) Stockpiling Permit and Development Construction Permit Review
Procedures.
Fort Collins City Code Chapter 20 Nuisances, Article 1 In General, §20-1 Air pollution nuisances
prohibited.
Fort Collins City Code Chapter 26 Utilities, Article VII Stormwater Utility, §26-498 Water quality control.
Fort Collins Stormwater Criteria Manual Volume 3, Chapter 7, Section 1.3 Policy, Standards and
Submittal Requirements, §1.3.3.e.7.
Fort Collins Stormwater Criteria Manual - Fact Sheet MM-2 Stockpile Management.
State of Colorado, Air Quality Control Commission, 5 CCR 1001-3, Regulation No. 1, §III.D.2.c Storage and
Handling of Materials.
Street Sweeping
Fort Collins City Code Chapter 20 Nuisances, Article 1 In General, §20-1 Air pollution nuisances
prohibited.
Fort Collins City Code Chapter 26 Utilities, Article VII Stormwater Utility, §26-498 Water quality control.
Fort Collins Stormwater Criteria Manual - Fact Sheet SM-7 Street Sweeping and Vacuuming.
Track-out/Carry-out
Fort Collins Traffic Code, Part 1407 Spilling loads on highways prohibited.
Fort Collins Land Use Code §5.2.1 Definitions Maintenance (of a newly constructed street).
Fort Collins City Code: Chapter 20 – Nuisances, Article V - Dirt, Debris and Construction Waste, §Sec.
20-62. Depositing on streets prohibited.
Fort Collins City Code Chapter 26 Utilities, Article VII Stormwater Utility, §26-498 Water quality control.
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Fort Collins Stormwater Criteria Manual, Volume 3, Chapter 7, Section 1.3 Policy, Standards and
Submittal Requirements, §1.3.3.e.8.
Fort Collins Stormwater Criteria Manual – Fact Sheet SM-4 Vehicle Tracking Control.
Fort Collins Stormwater Criteria Manual – Fact Sheet SM-7 Street Sweeping and Vacuuming.
State of Colorado, Air Quality Control Commission, 5 CCR 1001-3, Regulation No. 1, §III.D.2.a.(ii).(B)
General Requirements.
Bulk Materials Transport
Fort Collins Traffic Code, Part 1407 Spilling loads on highways prohibited.
Fort Collins City Code Chapter 20 Nuisances, Article 1 In General, §20-1 Air pollution nuisances
prohibited.
Fort Collins City Code Chapter 26 Utilities, Article VII Stormwater Utility, §26-498 Water quality control.
State of Colorado, Air Quality Control Commission, 5 CCR 1001-3, Regulation No. 1, §III.D.2.f Haul Trucks.
Colorado Revised Statutes. 42-4-1407 Spilling loads on highways prohibited.
Unpaved Roads and Haul Roads
Fort Collins City Code Chapter 20 Nuisances, Article 1 In General, §20-1 Air pollution nuisances
prohibited.
Fort Collins City Code Chapter 26 Utilities, Article VII Stormwater Utility, §26-498 Water quality control.
State of Colorado, Air Quality Control Commission, 5 CCR 1001-3, Regulation No. 1, §III.D.2.a Roadways
and §III.D.2.e Haul Roads.
Parking Lots
Fort Collins City Code Chapter 20 Nuisances, Article 1 In General, §20-1 Air pollution nuisances
prohibited.
Fort Collins City Code Chapter 26 Utilities, Article VII Stormwater Utility, §26-498 Water quality control.
Open Areas and Vacant Lots
Fort Collins City Code Chapter 20 Nuisances, Article 1 In General, §20-1 Air pollution nuisances
prohibited.
Fort Collins City Code Chapter 26 Utilities, Article VII Stormwater Utility, §26-498 Water quality control.
Saw Cutting and Grinding
Fort Collins City Code Chapter 20 Nuisances, Article 1 In General, §20-1 Air pollution nuisances
prohibited.
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Fort Collins City Code Chapter 26 Utilities, Article VII Stormwater Utility, §26-498 Water quality control.
Fort Collins Stormwater Criteria Manual – Fact Sheet SM-12 Paving and Grinding Operations.
Colorado Department of Transportation Standard Specifications for Road and Bridge Construction,
Section 208.04 Best Management Practices for Stormwater.
Abrasive Blasting
Fort Collins City Code Chapter 20 Nuisances, Article 1 In General, §20-1 Air pollution nuisances
prohibited.
Fort Collins City Code Chapter 26 Utilities, Article VII Stormwater Utility, §26-498 Water quality control.
Mechanical (Leaf) Blowing
Fort Collins City Code Chapter 20 Nuisances, Article 1 In General, §20-1 Air pollution nuisances
prohibited.
Fort Collins City Code Chapter 26 Utilities, Article VII Stormwater Utility, §26-498 Water quality control.
5.2 City of Fort Collins Manuals and Policies
Fort Collins Stormwater Criteria Manual http://www.fcgov.com/utilities/business/builders-and-
developers/development-forms-guidelines-regulations/stormwater-criteria
City of Fort Collins Parks and Recreation Environmental Best Management Practices Manual 2011,
Chapter Four: Best Management Practices for Construction http://www.fcgov.com/parks/pdf/bmp.pdf
City of Fort Collins Building Design and Construction Standards, Oct. 2013
http://www.fcgov.com/opserv/pdf/building-design-standards2.pdf?1390850442
City of Fort Collins, Recommended Species and Application Rates of Perennial Native Upland Grass Seed
for Fort Collins, Colorado.
City of Fort Collins Plant List, April 2011.
5.3 References for Dust Control
Leaf Blowing
A Report to the California Legislature on the Potential Health and Environmental Impacts of Leaf
Blowers, California Environmental Protection Agency – Air Resources Board, Feb. 2000.
http://www.arb.ca.gov/msprog/mailouts/msc0005/msc0005.pdf
Abrasive Blasting
Sandblasting and Other Air-based Blasting Fact Sheet, Minnesota Pollution Control Agency, Dec. 2011.
Protecting Workers from the Hazards of Abrasive Blasting Materials, OSHA Fact Sheet.
DRAFT Dust Prevention and Control Manual
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California Air Resources Board, Abrasive Blasting Program.
http://www.arb.ca.gov/ba/certabr/certabr.htm
Saw Cutting
OSHA Fact Sheet on Crystalline Silica Exposure
https://www.osha.gov/OshDoc/data_General_Facts/crystalline-factsheet.pdf
State of New Jersey – Dry Cutting and Grinding Fact Sheet
http://www.state.nj.us/health/surv/documents/dry_cutting.pdf
Centers for Disease Control and Prevention - Engineering Controls for Silica in Construction
http://www.cdc.gov/niosh/topics/silica/cutoffsaws.html
Shepherd-S; Woskie-S, Controlling Dust from Concrete Saw Cutting. Journal of Occupational and
Environmental Hygiene, 2013 Feb; 10(2):64-70. http://www.cdc.gov/niosh/nioshtic-2/20042808.html
Akbar-Khanzadeh F, Milz SA, Wagner CD, Bisesi MS, Ames AL, Khuder S, Susi P, Akbar-Khanzadeh M,
Effectiveness of dust control methods for crystalline silica and respirable suspended particulate matter
exposure during manual concrete surface grinding. Journal of Occupational and Environmental Hygiene,
2010 Dec;7(12):700-11. http://www.ncbi.nlm.nih.gov/pubmed/21058155
HSE, On-Tool Controls to Reduce Exposure to Respirable Dusts in the Construction Industry – A Review.
Health and Safety Executive, RR926, 2012, Derbyshire, U.K.
http://www.hse.gov.uk/research/rrpdf/rr926.pdf
Croteau G, Guffey S, Flanagan ME, Seixas N, The Effect of Local Exhaust Ventilation Controls on Dust
Exposures During Concrete Cutting and Grinding Activities. American Industrial Hygiene Association
Journal, 2002 63:458–467
http://deohs.washington.edu/sites/default/files/images/general/CroteauThesis.pdf
Unpaved Roads, Parking Lots, and Open Areas
Dust Control from Unpaved Roads and Surfaces, Code 373, USDA-NRCS, April 2010.
http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs143_025946.pdf
CPWA, 2005, Dust Control for Unpaved Roads, A Best Practice by the National Guide to Sustainable
Municipal Infrastructure, Canadian Public Works Association.
Colorado Forest Road Field Handbook, Colorado State Forest, Editor: Richard M. Edwards, CF; CSFS
Assistant Staff Forester, July 2011.
Fay L., Kociolek A., Road Dust Management and Future Needs: 2008 Conference Proceedings, Western
Transportation Institute, March 2009.
Chemical Stabilizers
Interim Guidelines on Dust Palliative Use in Clark County, Nevada. Nevada Division of Environmental
Protection, Feb. 2001. http://ndep.nv.gov/admin/dustpa1.pdf
DRAFT Dust Prevention and Control Manual
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Bolander, Peter, ed. 1999. Dust Palliative Selection and Application Guide. Project Report. 9977-1207-
SDTDC. San Dimas, CA: U.S. Department of Agriculture, Forest Service, San Dimas Technology and
Development Center. http://www.fs.fed.us/eng/pubs/html/99771207/99771207.html
Techniques for Fugitive Dust Control – Chemical Suppressants, City of Albuquerque NM, website last
accessed on Oct. 25, 2014.
http://www.cabq.gov/airquality/business-programs-permits/ordinances/fugitive-dust/fugitive-dust-
control
USDA BioPreferred Catalog: Dust Suppressants
http://www.biopreferred.gov/BioPreferred/faces/catalog/Catalog.xhtml
USGS Columbia Environmental Research Center Project: Environmental Effects of Dust Suppressant
Chemicals on Roadside Plant and Animal Communities,
http://www.cerc.usgs.gov/Projects.aspx?ProjectId=77
Street Sweeping
U.S. Department of Transportation, Federal Highway Administration, Stormwater Best Management
Practices: Street Sweeper Fact Sheet. http://environment.fhwa.dot.gov/ecosystems/ultraurb/3fs16.asp
Agriculture and Livestock
Agricultural Air Quality Conservation Measures - Reference Guide for Cropping Systems and General
Land Management, USDA-NRCS, Oct. 2012.
http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1049502.pdf
Dust Control from Animal Activity on Open Lot Surfaces, Code 375, USDA-NRCS, Sept. 2010.
http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs143_025821.pdf
Residue and Tillage Management, Reduced Till, Code 345, USDA-NRCS, Dec. 2013.
http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1251402.pdf
Herbaceous Wind Barriers, Code 603, USDA-NRCS, Jan. 2010.
http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs143_025927.pdf
Michalewicz, D. A., J. D. Wanjura, B. W. Shaw, and C. B. Parnell. 2005. Evaluation of sources and controls
of fugitive dust from agricultural operations. In Proc. 2005 Beltwide Cotton Conference.
http://caaqes.tamu.edu/Publication-Particulate%20Matter.html
Harner J., Maghirang R., Razote E., Water Requirements for Dust Control on Feedlots, from the
proceedings of Mitigating Air Emissions From Animal Feeding Operations Conference, May 2008.
http://www.extension.org/pages/23966/water-requirements-for-dust-control-on-feedlots
California Air Pollution Control Officers Association Agriculture Clearinghouse
http://www.capcoa.org/ag-clearinghouse/
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U.S. Department of Agriculture Natural Resources Conservation Service - Nevada, Fugitive Dust: A Guide
to the Control of Windblown Dust on Agricultural Lands in Nevada. Jan. 2007.
http://www.cdsn.org/images/FugitiveDustGuide_v7_201_.pdf
Demolition and Renovation
CDPHE, Demolition and Asbestos Abatement forms and information
https://www.colorado.gov/pacific/cdphe/asbestos-forms
Earthmoving Activities
CDPHE, An Overview of Colorado Air Regulations for Land Development, August 2014
https://www.colorado.gov/pacific/sites/default/files/AP_Land-Development-Guidance-Document_1.pdf
Working With Dirt When the Wind Blows
http://www.gradingandexcavation.com/GX/Articles/Working_With_Dirt_When_the_Wind_Blows_5455
.aspx
EPA – Stormwater Best Management Practices: Dust Control
http://water.epa.gov/polwaste/npdes/swbmp/Dust-Control.cfm
EPA – Stormwater Best Management Practices: Wind Fences and Sand Fences
http://water.epa.gov/polwaste/npdes/swbmp/Wind-Fences-and-Sand-Fences.cfm
EPA – Stormwater Best Management Practices: Construction Sequencing
http://water.epa.gov/polwaste/npdes/swbmp/Construction-Sequencing.cfm
EPA – Stormwater Best Management Practices: Construction Entrances
http://water.epa.gov/polwaste/npdes/swbmp/Construction-Entrances.cfm
An Overview of Colorado Air Regulations for Land Development. Colorado Department of Public Health
and Environment – Air Pollution Control Division.
https://www.colorado.gov/pacific/sites/default/files/AP_Land-Development-Guidance-Document_1.pdf
Health Effects of Particulate Matter
U.S. Environmental Protection Agency, Integrated Science Assessment for Particulate Matter.
EPA/600/R-08/139F Dec. 2009.
http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=216546#Download
World Health Organization, Health Effects of Particulate Matter - Policy. 2013
http://www.euro.who.int/__data/assets/pdf_file/0006/189051/Health-effects-of-particulate-matter-
final-Eng.pdf
Preventing Silicosis in Construction Workers, NIOSH http://www.cdc.gov/niosh/docs/96-112/
General
Dust Abatement Handbook, Maricopa County Air Quality Department, June 2013.
http://www.maricopa.gov/aq/divisions/compliance/dust/docs/pdf/Rule%20310-Dust%20Handbook.pdf
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Fugitive Dust Control: Self Inspection Handbook, California Air Resources Board, 2007.
http://www.arb.ca.gov/pm/fugitivedust_large.pdf
WRAP Fugitive Dust Handbook, Western Governors’ Association. Sept. 2006.
Managing Fugitive Dust: A Guide for Compliance with the Air Regulatory Requirements for Particulate
Matter Generation, Michigan Department of Environmental Quality. March 2014.
Colorado Oil and Gas Conservation Commission, Rules and Regulations, Rule 805 Odors and Dust
http://cogcc.state.co.us/
PUBLIC ENGAGEMENT SUMMARY
PROJECT TITLE: Dust Control and Prevention
OVERALL PUBLIC INVOLVEMENT LEVEL: Involve
BOTTOM LINE QUESTION: Shall the Council adopt code amendments to control fugitive dust?
KEY STAKEHOLDERS: Developer/contractor community, City Departments, residents
TIMELINE: 2013-2016
PHASE 1: Internal stakeholder outreach
Timeframe: April 2014 – September 2014
Key Messages: Help us define the problem and devise a solution
Tools and Techniques: Meetings with affected staff groups
• Community Development & Neighborhood Services
• Engineering
• Streets
• Regulatory & Governmental Affairs
• Storm Water
• Water Engineering & Field Services
• City Attorney
• Larimer County Department of Health and Environment
PHASE 2: External and internal stakeholder engagement
Timeframe: June 2014 – February 2015
Key Messages: Staff is working on fugitive dust control. How can we improve our proposal? How will
dust control requirements affect you?
Tools and Techniques:
• Board/Commission meetings - Air Quality Advisory Board, Building Review Board, Planning and
Zoning Board, Natural Resources Advisory Board, Parks and Recreation Board, Land Conservation
and Stewardship Board
• Online Survey – 163 respondents
• Open House – February 2015 (14 attendees)
• Specific outreach to the business community, including the Chamber of Commerce, business
meetings, and a stakeholder meeting with 23 attendees in December 2014
PHASE 3: Pilot Project – Field Data Collection and Fugitive Dust Working Group
Timeframe: June 2015 – February 2016
Key Messages: Now that draft Ordinances and a Draft Dust Prevention and Control Manual has been
drafted, how can these products be improved? What are the cost, time to implement, water use, dust
prevention, and other impacts of this proposal?
Tools and Techniques:
• Monthly Fugitive Dust Working Group Meetings
• Data collection at construction sites (baseline data to understand current practices) and controlled
observations (to test how applying the best management practices outlined in the manual reduces
dust generation)
PHASE 4: Additional Outreach
Timeframe: September 2015 – February 2016
Key Messages: What remaining concerns do you have on this project?
Tools and Techniques:
• Council Work Session (February 9)
• Additional outreach to the business community, e.g., the Northern Colorado Homebuilders
Association, Chamber of Commerce Local Legislative Affairs Committee, etc.
• Recommendations from Boards and Commissions
PHASE 4: (If Adopted) Training and Public Outreach
Timeframe: March 2016 – December 2016
Key Messages: This is how to implement the Dust Prevention and Control Manual – from either an
enforcement perspective or a contractor perspective
Tools and Techniques:
• Training sessions will include presentations that include a general overview of the changes to the
Code, the guidance manual, and requirements of individual parties. Training sessions will be
conducted with a) all City staff, including front line building staff; b) City inspectors; c)
Contractors, developers, etc. (including both City and private sector staff that generate dust).
• Enforcement materials will include draft enforcement worksheet that will be completed by
inspectors in the field, the draft spreadsheet for tracking enforcement, and a Sharepoint site to
manage the various inspection documents.
• Outreach is designed to inform the general public about the regulations that have been adopted.
Staff intends to develop a communication plan that includes both traditional notifications, e.g.,
Utility mailer, as well as social media. Staff will work with the Communications and Public
Involvement Office to craft these materials.
*The Fort Collins SAT was developed by modifying the Triple Bottom Line (TBL) Analysis Tool developed
by Eugene, Oregon, July 2009. 1
SUSTAINABILITY ASSESSMENT SUMMARY
DATE: November 2015
SUBJECT: Sustainability Assessment (SA) Summary for Dust Prevention and Control Strategies
Key issues identified:
• Dust control proposal will likely reduce fugitive dust, leading to improved human health for
residents and workers at dust-generating sties, improved safety, and improved aesthetics such
as visual air quality.
• Overall, proposal will have a positive impact on the environment by reducing particulate matter
emission into the air and water. Proposal may result in more water use. Proposal may result in
more waste generation from increased use of wind barriers.
• Although many companies already employ dust mitigations strategies, and mitigation strategies
are required by county and state government for dust-generating sources greater than five
acres, the cost associated with implementing control measures not previously required could
negatively impact those businesses.
Suggested mitigation actions:
• Dust control ordinance could be over-ridden by City Council at times where a drought conditions
exist.
• At least some wind barrier materials could be recycled.
Economic , -1.1
Social , 1.7
Environmental
1.8
Rating
Average, 0.8
-4.0
-3.0
-2.0
-1.0
0.0
1.0
2.0
3.0
4.0
Sustainability Rating
Rating without mitigation Rating with mitigation
Rating Legend
3 Very positive
2 Moderately positive
1 Slightly positive
0 Not relevant or neutral
*The Fort Collins SAT was developed by modifying the Triple Bottom Line (TBL) Analysis Tool developed by Eugene, Oregon, July 2009. 2
City of Fort Collins SUSTAINABILITY ASSESSMENT TOOL (SAT)
(Completed November 2015)
Creating a sustainable community
Plan Fort Collins is an expression of the community’s resolve to act sustainably: to systemically, creatively, and thoughtfully utilize environmental,
human, and economic resources to meet our present needs and those of future generations without compromising the ecosystems upon which we
depend.
How to use the tool
The Sustainability Assessment Tool (SAT) is designed to inform a deeper understanding of how policy and program choices affect the social
equity, environmental health and economic health of the community. The City of Fort Collins has developed a Sustainability Assessment
Framework that describes the purpose, objectives, and guidelines to assist City Program/Project Managers to determine:
• The process for cross-department collaboration in using the SAT
• Timing for applying a SAT
• When to apply a SAT
• How to document the results of the SAT and present at City Council Work Sessions and Regular Council Meetings
Further detailed guidance is available at: http://citynet.fcgov.com/sustainability/sustainabilityassessments.php
The SAT does not dictate a particular course of action; rather, the analysis provides policy makers and staff with a greater awareness of some
of the trade-offs, benefits and consequences associated with a proposal, leading to more mindful decision-making.
Brief description of proposal
Please provide a brief description of your proposal – 100 words or less
The City has developed a proposed ordinance to adopt municipal code language and a Dust Prevention and Control Manual that establishes minimum
requirements consistent with nationally recognized practices for controlling fugitive dust emissions, and identifies additional dust control measures that could be
used to prevent off-property transport or off-vehicle transport of fugitive dust emissions for 12 specific dust generating activities. The objective of the City’s
fugitive dust control program is to prevent health and ecosystem impacts as well as nuisances from dust emissions through the application of readily available
and generally accepted dust control measures.
Staff lead(s):
Please note staff name, position/division and phone number
Lindsay Ex, Environmental Program Manager
Environmental Services Department
(970) 224-6143
3
Social Equity
Described: Placing priority upon protecting, respecting, and fulfilling the full range of universal human rights, including those pertaining to civil,
political, social, economic, and cultural concerns. Providing adequate access to employment, food, housing, clothing, recreational opportunities, a
safe and healthy environment and social services. Eliminating systemic barriers to equitable treatment and inclusion, and accommodating the
differences among people. Emphasizing justice, impartiality, and equal opportunity for all.
Goal/Outcome: It is our priority to support an equitable and adequate social system that ensures access to employment, food, housing, clothing,
education, recreational opportunities, a safe and healthy environment and social services. Additionally, we support equal access to services and
seek to avoid negative impact for all people regardless of age, economic status, ability, immigration or citizenship status, race/ethnicity, gender,
relationship status, religion, or sexual orientation. Equal opportunities for all people are sought. A community in which basic human rights are
addressed, basic human needs are met, and all people have access to tools and resources to develop their capacity. This tool will help identify how
the proposal affects community members and if there is a difference in how the decisions affect one or more social groups. Areas of consideration in
creating a vibrant socially equitable Fort Collins are: basic needs, inclusion, community safety, culture, neighborhoods, and advancing social equity.
Analysis Prompts
• The prompts below are examples of the issues that need to be addressed.
They are not a checklist. Not all prompts and issues will be relevant for any
one project. Issues not covered by these prompts may be very pertinent to a
proposal - please include them in the analysis.
• Is this proposal affected by any current policy, procedure or action plan?
Has advice been sought from organizations that have a high level of
expertise, or may be significantly affected by this proposal?
Proposal Description
1. Meeting Basic Human Needs
• How does the proposal impact access to food, shelter,
employment, health care, educational and recreational
opportunities, a safe and healthy living environment or
social services?
• Does this proposal affect the physical or mental health of
individuals, or the status of public health in our community?
• How does this proposal contribute to helping people achieve
and maintain an adequate standard of living, including housing,
or food affordability, employment opportunities, healthy families,
or other resiliency factors?
Analysis/Discussion
• Increased dust control can improve the health of residents who
otherwise would be subject to fugitive dust emissions, esp. keeping in
mind ¼ of Fort Collins households have a member who has a
respiratory illness. This could lead to decreased costs for doctor or
hospital visits.
• Dust control can improve worker health or reduce risk of health
problems at the site of the dust generating activity. Dust that contains
silica or toxic materials can be especially harmful.
• Dust control can also improve indoor air quality and reduce the
amount of particulates that are tracked in a home.
• Reducing or eliminating blowing dust in traffic areas and the improved
visibility will improve safety for drivers, bicyclists, pedestrians, etc.
• The whole objective of the proposal is to prevent health and
ecosystem impacts from fugitive dust.
2. Addressing Inequities and being Inclusive
• Are there any inequities to specific population subsets in this
proposal? If so, how will they be addressed?
• The proposal will provide increased relief to neighborhoods/residents who
experience the impacts of fugitive dust while any additional costs for
4
• Does this proposal meet the standards of the Americans with
Disabilities Act?
• How does this proposal support the participation, growth
and healthy development of our youth? Does it include
Developmental Assets?
• If the proposal affects a vulnerable section of our community (i.e.
youth, persons with disabilities, etc.)
implementation may be passed on to a larger group of customers.
• The EPA’s Web page on PM states ‘According to the American Academy of
Pediatrics, children and infants are among the most susceptible to many
air pollutants. Children have increased exposure compared with adults
because of higher minute ventilation and higher levels of physical
activity.”
• People with heart or lung diseases, children and older adults are the
most likely to be affected by particle pollution exposure. However, even
if you are healthy, you may experience temporary symptoms from
exposure to elevated levels of particle pollution.
3. Ensuring Community Safety
• How does this proposal address the specific safety and
personal security needs of groups within the community,
including women, people with disabilities, seniors, minorities,
religious groups, children, immigrants, workers and others?
• The proposal will increase safety of everyone who otherwise would have
been experiencing fugitive dust emission (work site employees, drivers and
bicyclists, pedestrians and neighbors)
4. Culture
• Is this proposal culturally appropriate and how does it affirm
or deny the cultures of diverse communities?
• How does this proposal create opportunities for artistic and
cultural expression?
• Citizen surveys have repeatedly shown that Fort Collins citizens value good
visual air quality and mountain views. Controlling dust would reduce visual
impairment and increase good visibility in Fort Collins.
• The proposal will not have a negative impact on minorities.
• Proposal may influence citizens’ perspective of the City government either
favorably or negatively.
5. Addressing the Needs of Neighborhoods
• How does this proposal impact specific Fort Collins
neighborhoods?
• How are community members, stakeholders and interested
parties provided with opportunities for meaningful participation
in the decision making process of this proposal?
• How does this proposal enhance neighborhoods and
stakeholders’ sense of commitment and stewardship to our
community?
• Urban fugitive dust concerns are often localized in nature. Controlling dust
will aid neighborhoods or individuals who have dust concerns.
• There has been significant outreach regarding this proposal include 2 open
houses, an on-line survey, individual meetings with stakeholders, meetings
with stakeholder groups, a Fugitive Dust Working group, and discussion
with many staff departments.
6. Building Capacity to Advance Social Equity
• What plans have been made to communicate about and
share the activities and impacts of this proposal within the
City organization and/or the community?
• How does this proposal strengthen collaboration and
cooperation between the City organization and community
members?
• Staff will engage with the private sector dust-generating activities to
5
• ESD staff will provide training on inspection and enforcement to City
inspectors who are routinely in the field for other inspections, and will also
provide info to Admin and other staff in departments who might encounter
calls/questions about the dust control program.
Social Equity Summary
Key issues:
Dust control proposal will likely reduce fugitive dust, leading to improved human health for residents and workers at dust-generating sties, improved
safety, and improved aesthetics such as visual air quality.
Potential mitigation strategies:
Overall, the effect of this proposal on social equity would be:
Please reach a consensus or take a group average on the rating, enter an “x” in one of
the following boxes and indicate the overall rating.
Rating represents group consensus
Rating represents group average +1.7
+3 +2 +1 0 -1 -2 -3
Very
positive
Moderately
positive
Slightly
positive
Not
relevant
or neutral
Slightly
negative
Moderately
negative,
impact
likely
Very
negative,
impact
expected
Environmental Health
Described: Healthy, resilient ecosystems, clean air, water, and land. Decreased pollution and waste, lower carbon emissions that contribute to
climate change, lower fossil fuel use, decreased or no toxic product use. Prevent pollution, reduce use, promote reuse, and recycle natural
resources.
Goal/Outcome: Protect, preserve, and restore the natural environment to ensure long-term maintenance of ecosystem functions necessary for
support of future generations of all species. Avoid or eliminate adverse environmental impacts of all activities, continually review all activities to identify
and implement strategies to prevent pollution; reduce energy consumption and increase energy efficiency; conserve water; reduce consumption and
waste of natural resources; reuse, recycle and purchase recycled content products; reduce reliance on non-renewable resources.
Analysis Prompts
• The prompts below are examples of issues that need to be addressed.
They are not a checklist. Not all prompts and issues will be relevant for
any one project. Issues not covered by these prompts may be very pertinent
to a proposal - please include them in the analysis.
6
• Is this proposal affected by any current policy, procedure or action
plan? Has advice been sought from organizations that have a high level
of expertise, or may be significantly affected by this proposal?
1. Environmental Impact
• Does this proposal affect ecosystem functions or
processes related to land, water, air, or plant or
animal communities?
• Will this proposal generate data or knowledge related to the
use of resources?
• Will this proposal promote or support education in
prevention of pollution, and effective practices for
reducing, reusing, and recycling of natural resources?
• Does this proposal require or promote the continuous
improvement of the environmental performance of the City
organization or community?
• Will this proposal affect the visual/landscape or aesthetic
elements of the community?
Analysis/Discussion
• Fugitive dust can harm ecosystems so controlling dust will reduce or
minimize harmful ecosystem impacts (i.e. harm plant growth, water quality,
air quality).
• Implementation of the proposal will raise awareness for dust-generating
sources about pollution prevention and dust control best management
practices.
• If mis-applied, chemical stabilization agents can harm ecosystem health.
• Controlling dust will improve the visual and aesthetic environment in Fort
Collins, as well as air quality
• Implementation of the proposal will likely increase water use for wet
suppression and therefore not support water conservation goals.
2. Climate Change
• Does this proposal directly generate or require the
generation of greenhouse gases (such as through
electricity consumption or transportation)?
• How does this proposal align with the carbon reduction goals for
2020 goal adopted by the City Council?
• Will this proposal, or ongoing operations result in an
increase or decrease in greenhouse gas emissions?
• How does this proposal affect the community’s efforts to reduce
greenhouse gas emissions or otherwise mitigate adverse climate
change activities?
The proposal may have very minor positive or negative impacts on GHG
emissions.
Would reduce GHG emissions:
• Reduced vehicle speeds might use less fuel per mile than higher speeds.
• If causes reduction in use of mechanical blowing
• Carbon sequestration would increase from revegetation efforts.
Would increase GHG emissions:
• Increased water use and the GHG emissions associated with water
treatment
• Increased driving if conducting more site inspection visits
3. Protect, Preserve, Restore
• Does this proposal result in the development or modification
of land resources or ecosystem functions?
• Does this proposal align itself with policies and procedures
related to the preservation or restoration of natural habitat,
greenways, protected wetlands, migratory pathways, or the
urban growth boundary
• How does this proposal serve to protect, preserve, or restore
important ecological functions or processes?
7
4. Pollution Prevention
• Does this proposal generate, or cause to be generated,
waste products that can contaminate the environment?
• Does this proposal require or promote pollution prevention
through choice of materials, chemicals, operational practices
and/or engineering controls?
• Does this proposal require or promote prevention of
pollution from toxic substances or other pollutants
regulated by the state or federal government?
• Will this proposal create significant amounts of waste or
pollution?
• Use of chemical stabilization agents can have harmful environmental
impacts.
• The Dust Manual prohibits the use of asphalt-based chemical stabilizers.
5. Rethink, Replace, Reduce, Reuse, Recirculate/Recycle
• Does this proposal prioritize the rethinking of the materials or
goods needed, reduction of resource or materials use, reuse of
current natural resources or materials or energy products, or
result in byproducts that are recyclable or can be re-circulated?
• Proposal may result in increased slurry and associated clean up needs.
• Proposal may increase waste from disposal of used wind barrier material.
NOTE: this could be mitigated through recycling of the material.)
6. Emphasize Local
• Does this proposal emphasize use of local materials,
vendors, and or services to reduce resources and
environmental impact of producing and transporting
proposed goods and materials?
• Will the proposal cause adverse environmental effects
somewhere other than the place where the action will take
place?
• Proposal may benefit those outside City limits (i.e. in the GMA) by
preventing dust from being transported out of the city.
• Proposal could foster a tool-sharing opportunity for certain dust
suppression tools.
Environmental Health Summary
Key issues:
Overall, proposal will have a positive impact on the environment by reducing particulate matter emission into the air and water. Proposal may
result in more water use. Proposal may result in more waste generation from increased use of wind barriers.
Potential mitigation strategies:
Dust control ordinance could be over-ridden by City Council at times where a drought conditions exist.
At least some wind barrier materials could be recycled.
Overall, the effect of this proposal on environmental health would be:
Please reach a consensus or take a group average on the rating, enter an “x” in one of
the following boxes and indicate the overall rating.
Rating represents group consensus
Rating represents group average +1.8
+3 +2 +1 0 -1 -2 -3
Very
positive
Moderately
positive
Slightly
positive
Not
relevant
or neutral
Slightly
negative
Moderately
8
Economic Health
Described: Support of healthy local economy with new jobs, businesses, and economic opportunities; focus on development of a diverse economy,
enhanced sustainable practices for existing businesses, green and clean technology jobs, creation or retention of family waged jobs.
Goal/Outcome: A stable, diverse and equitable economy; support of business development opportunities.
Analysis Prompts
• The prompts below are examples of the issues that need to be addressed.
They are not a checklist. Not all prompts and issues will be relevant for any
one project. Issues not covered by these prompts may be very pertinent to a
proposal - please include them in the analysis
• Is this proposal affected by any current policy, procedure or action plan? Has
advice been sought from organizations that have a high level of expertise, or
may be significantly affected by this proposal?
1. Infrastructure and Government
• How will this proposal benefit the local economy?
• If this proposal is an investment in infrastructure is it designed
and will it be managed to optimize the use of resources
including operating in a fossil fuel constrained society?
• Can the proposal be funded partially or fully by grants, user
fees or charges, staged development, or partnering with
another agency?
• How will the proposal impact business growth or operations
(ability to complete desired project or remain in operation), such
as access to needed permits, infrastructure and capital?
Analysis/Discussion
• Proposal may harm local private sector who engages in dust generating
activities if they have to implement controls that have added cost.
• Proposal may benefit companies who offer dust suppression services.
• Proposal does not introduce any new permits or fees.
• Proposal may decrease workers comp costs if employees are exposed to
less dust pollution.
• Proposal is likely to increase the amount of staff times spent inspecting and
enforcing dust control, but should result in better outcomes.
• may either add net add work load to existing staff for conducting
inspections/do enforcement or reduce net time spent by multiple staff
responding to dust complaints with no enforcement approach available.
2. Employment and Training
• What are the impacts of this proposal on job creation
within Larimer County?
• Are apprenticeships, volunteer or intern opportunities
available?
• How will this proposal enhance the skills of the local workforce?
• Likely minimal impact on job creation unless City inspection needs rise to
level of needed new staff resources that are funded.
• Implementation of dust program could add an intern or graduate student
job opportunities.
• Proposal will provide training to city staff and dust generators on dust
control BMPs.
3. Diversified and Innovative Economy
• How does this proposal support innovative or
entrepreneurial activity?
• Will “clean technology” or “green” jobs be created in this
proposal?
• Proposal could support research into environmentally preferable chemical
stabilizers or alternative methods for dust suppression from street
sweeping.
9
• How will the proposal impact start-up or existing businesses or
development projects?
4. Support or Develop Sustainable Businesses
• What percentage of this proposal budget relies on local services
or products? Identify purchases from Larimer County and the
State of Colorado.
• Will this proposal enhance the tools available to businesses
to incorporate more sustainable practices in operations and
products?
• Are there opportunities to profile sustainable and socially
responsible leadership of local businesses or educate
businesses on triple bottom line practices?
• Proposal does enhance the tools available to local businesses by providing
clarity about dust suppression BMP as discussed in the manual.
• Proposal could benefit local companies that provide dust suppression
services.
• Businesses excelling at dust suppression could be showcased for their
exemplary efforts.
5. Relevance to Local Economic Development Strategy
• Proposal could benefit local companies that provide dust suppression
services.
Economic Prosperity Summary
Key issues:
Although many companies already employ dust mitigations strategies, and mitigation strategies are required by county and state government for
dust-generating sources greater than five acres, the cost associated with implementing control measures not previously required could negatively
impact those businesses.
Potential mitigation strategies:
Overall, the effect of this proposal on economic prosperity will be:
Please reach a consensus or take a group average on the rating, enter an “x” in one of
the following boxes and indicate the overall rating.
Rating represents group consensus
Rating represents group average -1.1
+3 +2 +1 0 -1 -2 -3
Very
positive
Moderately
positive
Slightly
positive
Not
relevant
or neutral
Slightly
negative
Moderately
negative,
impact
likely
Very
negative,
impact
expected
Environmental Services
215 N. Mason
PO Box 580
Fort Collins, CO 80522
970.221-6600
970.224-6177 - fax
fcgov.com
Fugitive Dust – Pilot Project Summary
Executive Summary:
Overview – The Fugitive Dust Pilot Project was initiated in 2015 at the direction of Council and
included two components: (1) stakeholder engagement primarily through the Fugitive Dust
Working Group (FDWG) and (2) the collection of field data to evaluate the potential impacts of
the proposed dust ordinance and guidance manual on the City and the “regulated” community.
The FDWG focused on providing input on the Dust Prevention and Control Manual (Manual)
and overseeing the field data collection process.
Methods – The Dust Prevention and Control Manual (see Attachment 2 to the AIS) and the Air
Quality Field Note Data Sheets (see page 5 for example) were created with the assistance of
the FDWG to support the field data collection project. A total of 46 site observations at 20 sites
were conducted between May 2015 and November 2015. The field observations were designed
to assess issues around dust control practices and the impacts to project cost, time, water use,
and air quality. As this effort was a pilot study, staff focused efforts on collecting data at a
number of different sites that included a range of dust generating activities and best
management practices. However, the data collection effort was not designed for the results to
be statistically significant, e.g., sites were not randomly selected from all construction sites in
Fort Collins.
Findings – Out of 46 observations, 17 (37%) showed full compliance with the Dust Prevention
and Control Manual, while 31 of these 46 (67%) demonstrated at least one dust control
measure for preventing fugitive dust from leaving the property. 15 of the observations (33%)
showed no BMPs in place.
o Costs: Implementing new BMPs for dust mitigation can result in an increase in cost at job
sites, though these costs vary greatly and depend on mitigation measures and size of job
site. Staff worked with the Fugitive Dust Working Group and a consultant over three
separate meetings to assess the cost of the required dust mitigation measures for each dust
generating activity. Following an iterative procedure, costs for each required BMP identified
in the Manual have been characterized and summarized in Attachment 3 to the AIS.
o Water: Water use varies between best management practices, though water use is
generally expected to be minimal, e.g., wetting a saw during concrete cutting. Two
exceptions are wet suppression on large sites or in street maintenance, where water use
could be higher.
o Stormwater: During each field visit, staff observed through either direct observation or on-
site interviews no direct conflicts with stormwater requirements. Staff has also worked
closely with Utilities’ staff to make sure the BMPs listed in the Manual are not in conflict with
the stormwater requirements.
o Time: While specific data on time were difficult to collect, staff’s observations during the field
project indicate that while time to implement these requirements would increase, overall time
varies significantly based on the dust generating activity.
o Air Quality: Applying BMPs at the eight control sites reduced the amount of dust generated
on average by 50%, and up to 99% below the amounts generated by activities without
BMPs in place.
2
Overview: The Fugitive Dust Pilot Project was created in 2015 to collect additional data related to the
costs, air quality impacts, water use, and overall time required should the regulations and best practices
be implemented. The Fugitive Dust Pilot Project also included the formation of a Fugitive Dust Working
Group (FDWG) to review the field study, the proposed Ordinance, and the guidance manual. The
FDWG consists of stakeholder representatives from the construction industry, Colorado State
University, environmental firms, and City staff affected by the proposed regulations (including
Engineering, Utilities and Code Compliance Staff).
The purpose of the field study was to evaluate the potential impacts of the proposed dust ordinance
and guidance manual on the City and the “regulated” community. It involves observations and data
collection at City operations and projects that have the potential to create fugitive dust. The Fugitive
Dust Pilot Project was focused on evaluating the following questions:
Cost – Does implementation of best management practices (BMPs) result in increases to
project costs?
Time – Does implementation of BMPs result in increased time to complete a project?
Water – Does implementation of BMPs result in significant increases in water use?
Stormwater requirements – Does implementation of BMPs result in conflicts with stormwater
requirements?
Air quality – Does implementation of BMPs result in air quality improvement?
Methods & Findings: Before implementing the Fugitive Dust Pilot Project’s field data collection, staff
worked with the Fugitive Dust Working Group to develop the Air Quality Field Note Data Sheets, get
feedback on the study design, and potential construction sites to observe. Due to a wet spring, the field
data collection for the pilot project was postponed until early May. Data were collected by two City
employees. A total of 46 site observations were conducted between May 2015 and November 2015.
These observations occurred at 20 individual locations, which were a mixture of City facilities and
projects, as well as private construction sites. The findings are as follows:
67% (31 out of 46) of the observations demonstrated at least one BMP for preventing fugitive
dust from leaving the property
37% (17 out of 46, or 17 out of the 31 observations listed above)f 31) were in full
compliance with the Manual
33% (15 of 46) of the observations did not show any BMPs in use.
Staff also observed that construction sites were inconsistent in their application of dust mitigation
practices, e.g., the site may not have dust mitigation measures in place for one portion of a site and
then have no measures in place for another portion of a site.
Staff made 46 observations of 20 construction sites to assess (1) cost, (2) air quality impacts, (3) water
use, (4) stormwater impacts, and (5) overall time requirements:
Cost: Cost data were initially collected to inform the project and included information from a regional
manual on construction costs (RS Means 2014 Construction Cost Data) and City contracts from the
past five years. The FDWG along with AECOM helped assemble relevant cost data for dust control
3
measures which can be found in Attachment 3 to the AIS. Following an iterative procedure, costs
for each required BMP identified in the Manual have been characterized and summarized.
Costs were defined into initial, upfront costs, and ongoing operations and maintenance costs
(O&M)
Costs can generally be broken into five categories
1. Measures that result in negligible or no additional initial or O&M costs to the operator
(less than $100):
Negligible costs include lowering drop height, covering loads, leaf blowing
techniques, reducing vehicle speeds, and restricting access (in small
projects)
2. Measures that result in minor O&M or initial upfront costs (hundreds of dollars):
Minor cost measures include minimizing the disturbed areas, reducing vehicle
speeds (on unpaved or haul roads), and restricting access (on larger
projects)
3. Measures that have little to no initial cost (<$100s) but have high O&M costs
(ranging in the thousands to tens of thousands of dollars):
These are dominated by BMPs that include work curtailment (i.e., high wind
restrictions) or equipment rental
4. Measures that have high initial costs (ranging in the thousands to tens of thousands
of dollars), but negligible or low O&M costs:
These measures include chemical stabilization (on parking lots), vegetating
open areas, cleaning up the slurry after saw cutting/grinding or abrasive
blasting, and erecting wind barriers
5. Measures that have both high initial costs and high O&M costs (ranging in the
thousands to tens of thousands of dollars):
They are characterized by controlling emissions from areas of large surface
disturbance through methods such as chemical stabilization, wet
suppression, surface roughening, gravel surface improvements, sweeping,
soil retention, vegetation, and synthetic or natural covers
Note that all of these assessments are estimates. While the staff team, AECOM, and the
FDWG worked hard to develop meaningful estimates, there are many variables that affect
these costs that cannot be precisely quantified.
Air Quality Impacts: Controlled observations included surveying and sampling a dust generating
activity without any mitigation measures and then conducting the same activity with mitigation
measures in place. In these eight observations, controlled field measurements of dust mitigating
activities showed an average of 50% dust mitigation capability, with the maximum mitigation of up
to 99%. The conclusions from the control sites indicate that the dust measures implemented do
make a notable difference in reducing the amount of dust on site.
Water Use: Certain dust measures do require water use, however data on specific amounts of
water is difficult to collect, e.g., the amount of water spraying from a hose during site compaction. In
some cases, water use can be as minimal as spraying water from a small tank while cutting
4
concrete. On the other hand, a water truck required to be on site daily to reduce fugitive dust from
stockpiles can require much more water. Generally, water use is expected to be minimal, e.g.,
wetting a saw during concrete cutting. The two exceptions to this are wet suppression on large sites
or in street maintenance, where water use could be higher. It should be noted the greatest water
use would likely be seen at sites over 25 acres or exceeding 6 months duration; these sites already
are required to have a dust control plan in accordance with county regulations, and thus, overall
water use may not increase significantly because of these regulations.
Stormwater: During each field visit staff assessed if there were stormwater conflicts either by
directly observing the dust generating activity or by speaking with the on-site operator. In every
case, staff did not observe any conflicts with stormwater requirements. Staff has also worked
closely with Utilities’ staff to make sure the BMPs listed in the Manual are not in conflict with the
stormwater requirements.
Overall Time Requirements: Similar to water use, time requirements vary greatly for different dust
measurements. The concrete cutting example required a second laborer to hold the water bottle,
but the duration of the activity was short (approximately 30 minutes). During the completion of the
Horsetooth and Timberline intersection renovation, on the other hand, cutting occurred over a four
day period, so an additional laborer would likely be required for a four day period. With the water
truck example, operation of the equipment can vary based on site scale and the number of
materials that need to be watered. Thus, while specific data on time were difficult to collect, staff’s
observations during the field project indicate that while time to implement these requirements would
increase, overall time varies significantly based on the dust generating activity.
Conclusion: 67% of the sites observed during the pilot project were applying some type of dust
mitigation method, while 36% of the sites were in full compliance with the Manual. The data collected
through the 8 field observations on controlled sites indicate a significant reduction in dust generated
when the required BMPs are in place. For instance, when water was applied to concrete cutting at one
control site, there was a 98% reduction in dust being generated from the saw. At another control site,
when the BMPs from the Dust Prevention and Control Manual were put into place, there was a 91%
reduction in dust being generated from the sweeping. Thus, while incorporating BMPs into construction
projects will increase costs for a portion of the operators who are not already applying them, utilizing
the BMPs outlined in the Manual does result in significant reductions in dust generated from various
activities.
5
Air Quality Field Notes Data Sheet
Project Name:
Dust Generating Activity:
Date:
Time:
Onsite Supervisor: Employee doing activity:
Location: Site Description:
Temp: Precipitation: 24 hrs: 48 hrs:
Wind
Speed:
Average: Max: Wind Direction:
Property Dust is Blowing
Towards:
Humidity: Soil Type: Field Surveyor:
Dust Trax II Readings
Min: Max:
Average: TWA:
Run Time: File:
Dust Control Measures Onsite:
1. 4.
2. 5.
3. 6.
Impacts from Current Dust Control Measures:
Cost (dust control measure increase cost to
project?)
Yes or No
Explain:
Time (dust control measure increase time to
complete project?)
Yes or No
Explain:
Water (significant increase in usage?) Yes or No
Explain:
Stormwater (control measures conflict with
stormwater requirement?)
Yes or No
Explain:
Air quality (improved due to control measures?) Yes or No
Explain:
Testing Dust Trak II
Zero Cal Calibration Complete: Y: N:
2 Drops Impactor Oil Complete: Y: N:
Flow Cal Calibration Readings: Rotometer: True:
6
Dust Control Measures Asked to Implement:
1. 4.
2. 5.
3. 6.
Dust Trax II Readings
Min: Max:
Average: TWA:
Run Time: File:
Impacts from Implementing New Dust Control Measures:
Cost (dust control measure increase cost to
project?)
Yes or No
Explain:
Time (dust control measure increase time to
complete project?)
Yes or No
Explain:
Water (significant increase in usage?) Yes or No
Explain:
Stormwater (control measures conflict with
stormwater requirement?)
Yes or No
Explain:
Air quality (improved due to control measures?) Yes or No
Explain:
Notes:
Dust Trax II Readings
Min: Max:
Average: TWA:
Run Time: File:
Dust Trax II Readings
Min: Max:
Average: TWA:
Run Time: File:
Initial BMP Cost Assessments
Fort Collins Fugitive Dust Working Group (FDWG)
11/9/2015
AECOM
Tom Damiana and Samantha August
Overview and Executive Summary
Objective:
Characterize order-of-magnitude costs associated with each required Best Management Practice (BMP) listed in the Fort
Collins Fugitive Dust Prevention Manual (Dust Manual).
Approach:
Following an iterative procedure, costs for each required BMP identified in the Dust Manual have been characterized and
summarized for City Council review. In this initial draft, estimates have been developed based on a consolidation of
comments received on a prior preliminary draft from the Fort Collins Fugitive Dust Working Group (FDWG). This initial
draft will be reviewed one last time by the FDWG and finalized following an upcoming FDWG meeting.
Summary:
Engineering controls BMPs and required BMPs from the Dust Manual have been summarized and are presented in
Figure 1. As shown in Figure 1, each BMP evaluated is referenced by an activity number and a BMP number under that
activity. For example, Earthmoving is given activity number 1, and the “Reduce Vehicle Speeds”, the 4th BMP, assigned 4.
Therefore, when referring to this BMP, it will be designated 1.4. This short-hand nomenclature is used in various locations
in this document to help organize the BMP cost assessment.
Figure 2 presents a high level graphical summary of costs associated with particular BMPs for each activity. In this
graphic, the bottom axis represents Initial costs increasing to the right and the vertical axis represents Operational and
Maintenance (O&M) cost increasing vertically. BMPs with the lowest combination of Initial and O&M costs plot in the lower
left corner and those with the highest combination of Initial and O&M costs plot to the upper right. Representing the cost
assessment in this manner enables visual filtering of BMPs to focus the assessment on just those BMPs that plot to the
upper and right hand extreme of the plot. These BMP represent the biggest costs. Conversely, BMPs plotting in the lower
left portion of the plot represent negligible costs and are not expected to be the focus.
Focusing on those measures with the highest overall costs, the upper right corner of Figure 2 shows that BMPs
associated with activities 8 (Parking Lot) and 9 (Open Area) consistently rank among the most costly. These BMPs
involve controlling large areas with expensive measures (chemical stabilization) that require special equipment and
additional manpower. Project costs will depend on the size of the project, but are expected to range from multiple
thousands to multiple 10’s of thousands of dollars. Fortunately, for activities 8 and 9, only one of the BMPs are required
per project which controls cost to some degree.
BMPs with the highest O&M costs are characterized primarily by lost work (high wind restrictions), but very little other
investment. In the case of high wind restrictions, it is estimated that winds >30 mph occur between 1% and 6% of the time
between 6 am and 6 pm yearly. Assuming this translates directly to stop work 1%-6% of a 40 hour week, this could result
in 10’s of thousands of dollars additional cost to a project lasting longer than a year.
In general, it does not appear that any one activity will result in BMPs greater than 10’s of thousands per project, and
BMPs required for most activities (i.e., those falling within the blue cloud on Figure 2) would either be minor (i.e., less
than thousands of dollars) or negligible/no additional cost.
To facilitate a more detailed review of the costs associated with specific BMPs, each dust generating activity shown in
Figure 1 and ranked in Figure 2 has been given a section in this document corresponding to the activity number and
each associated BMP a subsection. The document Table of Contents outlines this organization of information. Costs
associated with each required BMP under a particular activity are summarized according to the graphic shown in
Figure 3.
1
Figure 1 Dust Control Best Management Practices
Legend =
Dust Generating Activity
/BMP
Earthmoving
Demolition/
Renovation
Stockpile
Street Sweeping
Track-out /Carry-
out
Bulk Materials
Transport
Unpaved Roads
and Haul Roads
Parking Lot*
Open Area*
Saw Cutting or
Grinding
Abrasive Blasting
Leaf Blowing
Notes
Abrasive media
Asbestos or lead materials 2.1
Building permit 2.2
Chemical stabilization 8.1 9.1
Contracts & Standards
Drop height 1.1 2.3 3.1 6.1
Enclosure
Equipment &work area clean up 10.1 11.1
Erosion Control plan 3.2
High winds restriction 1.2 2.4 10.2 11.2 12.1
Load cover 6.2
Leaf blowing techniques 12.2
Load Restrictions
Minimize disturbed area 1.3
On-tool local exhaust ventilation
On-tool wet suppression
Pavement or Gravel Apron
Reduce vehicle speeds 1.4 7.1 8.2
Remove deposition 5.1
Restrict access 1.5 2.5 7.2 8.3 10.3 11.3
Slurry clean up 10.4 11.4
Soil retention 9.2
Stockpile permit 3.3
Surface improvements 8.4
Surface roughening 9.3
Sweeping 8.5
Synthetic or natural cover 9.4
Track-out prevention system
Uncontrolled sweeping prohibited 4.1
Vacuum
Vegetation 8.6 9.5
Washing Station
Wet suppression 8.7 9.6 12.3
Wind barrier 8.8 9.7
*Note – For parking lots and open areas, all of these measures are “at least one or more”, so not all are required.
Light grey boxes are additional BMPs, analysis was only conducted for required BMPs
Negligible or no
Figure 2 Dust Control Measures vs Estimated Costs
Mitigations only expected to result in
minor O&M and Initial costs
BMPs with the Highest O&M Costs
BMPs in this region have
negligible to no initial costs, but
high O&M costs. These are
dominated by BMPs that include
work curtailment (i.e., high wind
restrictions) or equipment rental.
BMPs in this region
result in high O&M and
Initial costs. They are
characterized by
controlling emissions
from areas of large
surface disturbance
through methods such
as chemical
stabilization, wet
suppression, surface
roughening, gravel
surface improvements,
sweeping, soil
retention, vegetation,
and synthetic or natural
covers.
BMPs result in negligible or
no additional O&M and Initial
costs to the operator
BMPs in this region have negligible to no
O&M costs, but high Initial costs. These
are dominated by BMPs that applicable
to stabilizing larger areas with chemicals
or vegetation.
BMPs with the Highest Initial Costs
Figure 3 Key to Understanding the Presentation of Cost for a Particular Activity/BMP
1. Earthmoving
1.1 Mitigation: Drop Height
Comments
Initial Investment:
Operations:
Large Scale Job Comments:
Dust Generating Activity
Comments to help
understand how the
FDWG arrived at the
cost estimates.
Large scale jobs (>5
acres) are already
required to include
BMPs by the State
and County - these
considerations are
discussed here.
Rough Order-of-
Magnitude Initial
Investment Costs
Rough Order-of-
Magnitude
Operational Costs
Best Management Practice
1
Contents
1. Earthmoving ................................................................................................................................. 3
1.1 Mitigation: Drop Height......................................................................................................................... 3
1.2 Mitigation: High Winds Restriction ....................................................................................................... 4
1.3 Mitigation: Minimize Disturbed Area .................................................................................................... 4
1.4 Mitigation: Reduce Vehicle Speeds ..................................................................................................... 5
1.5 Mitigation: Restrict Access ................................................................................................................... 5
2. Demolition/Renovation ................................................................................................................ 6
2.1 Mitigation: Asbestos or Lead Materials ................................................................................................ 6
2.2 Mitigation: Building Permit.................................................................................................................... 6
2.3 Mitigation: Drop Height......................................................................................................................... 7
2.4 Mitigation: High Winds Restriction ....................................................................................................... 7
3. Stockpile ....................................................................................................................................... 8
3.1 Mitigation: Drop Height......................................................................................................................... 8
3.2 Mitigation: Erosion Control Plan ........................................................................................................... 8
3.3 Mitigation: Stockpile Permit .................................................................................................................. 9
4. Street Sweeping ......................................................................................................................... 10
4.1 Mitigation: Uncontrolled Sweeping Prohibited ................................................................................... 10
5. Track-out/Carry-out.................................................................................................................... 11
5.1 Mitigation: Remove Deposition .......................................................................................................... 11
6. Bulk Materials Transport ........................................................................................................... 12
6.1 Mitigation: Drop Height....................................................................................................................... 12
6.2 Mitigation: Load Cover ....................................................................................................................... 12
7. Unpaved Roads and Haul Roads .............................................................................................. 13
7.1 Mitigation: Reduce Vehicle Speeds ................................................................................................... 13
7.2 Mitigation: Restrict Access ................................................................................................................. 13
8. Parking Lot ................................................................................................................................. 14
8.1 Mitigation: Chemical Stabilization ...................................................................................................... 14
8.2 Mitigation: Reduce Vehicle Speeds ................................................................................................... 14
8.3 Mitigation: Restrict Access ................................................................................................................. 15
8.4 Mitigation: Surface Improvements ..................................................................................................... 15
8.5 Mitigation: Sweeping .......................................................................................................................... 16
8.6 Mitigation: Vegetation ......................................................................................................................... 16
8.7 Mitigation: Wet Suppression .............................................................................................................. 17
8.8 Mitigation: Wind Barrier ...................................................................................................................... 17
9. Open Area ................................................................................................................................... 18
9.1 Mitigation: Chemical Stabilization ...................................................................................................... 18
9.2 Mitigation: Soil Retention ................................................................................................................... 18
9.3 Mitigation: Surface Roughening ......................................................................................................... 19
9.4 Mitigation: Synthetic or Natural Cover ............................................................................................... 19
9.5 Mitigation: Vegetation ......................................................................................................................... 20
9.6 Mitigation: Wet Suppression .............................................................................................................. 20
9.7 Mitigation: Wind Barrier ...................................................................................................................... 21
10. Saw Cutting or Grinding ............................................................................................................ 22
2
10.1 Mitigation: Equipment & Work Area Clean-up ................................................................................... 22
10.2 Mitigation: High Winds Restriction ..................................................................................................... 22
10.3 Mitigation: Restrict Access ................................................................................................................. 23
10.4 Mitigation: Slurry Clean Up ................................................................................................................ 23
11. Abrasive Blasting ....................................................................................................................... 24
11.1 Mitigation: Equipment & Work Area Clean-up ................................................................................... 24
11.2 Mitigation: High Winds Restriction ..................................................................................................... 24
11.3 Mitigation: Restrict Access ................................................................................................................. 25
11.4 Mitigation: Slurry Clean Up ................................................................................................................ 25
12. Mechanical Blowing ................................................................................................................... 26
12.1 Mitigation: High Winds Restriction ..................................................................................................... 26
12.2 Mitigation: Blowing Techniques ......................................................................................................... 26
3
1. Earthmoving
1.1 Mitigation: Drop Height Comments
Initial Investment: None/Negligible
Operations: None/Negligible;
minimizing drop heights should
not have a large impact on the
operations of both small and large
jobs.
This mitigation is about awareness. Therefore,
minimizing drop heights should not have a large
impact on operations since it is about being mindful
to minimize dump heights from loaders to trucks and
stockpiles. There might be a delay and cost
associated with increased or more focused time
operating equipment this will probably be negligible
with the exception of training.
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
county and State. Therefore, this may already to a
cost to this scale of project. Regardless, costs
associated with large jobs are not expected to be
much different that smaller jobs.
4
Earthmoving
1.2 Mitigation: High Winds Restriction Comments
1.3 Mitigation: Minimize Disturbed Area Comments
Initial Investment: None/Negligible
An analysis of wind speeds from local sources shows
winds >30 mph on an hourly basis (maximum) is
between 1% and 6% of the time between 6 am and
6 pm yearly, so assume stop work 1%-6% of a
40-hour week, based on location.
Assuming $25/hr/employee, 5 employees and a 6%
stop work time, at a minimum, the cost of using this
mitigation would be $300/week, or $15,600/year.
Large-Scale Job Comments:
Large scale jobs have more employees and
potentially larger costs due to stop work; however, as
a percentage of total job cost, job scale is less a
factor. Regardless, large jobs are already required to
comply with high wind BMPs under the State and
County Rules. Therefore, this is already a cost to this
scale of jobs.
Operations:
Lost work Cost:
$$$$/person/year
Cost due to Schedule delays.
0 to 0.5% of total job cost
Operations: This can vary greatly
based on the size of the job.
0 to <0.5% of total job cost
depending on scale. If a bigger
project is being phased, it could add
5-10% to the overall grading costs.
Initial Investment: None/Negligible.
However, this could require phased
construction plans, which could
increase costs during engineering
potentially adding 4-5% to the cost
of engineering.
With larger projects, it is more economical to have all
of the surface disturbance occur at once, so going
piece by piece on larger jobs means remobilizing
equipment which increases cost. On small jobs this
may not even be feasible.
Large-Scale Job Comments:
Large scale jobs may be required to include this BMP
as part of a fugitive dust plan required by the county
and State. Therefore, this may already to a cost to
this scale of project.
5
Earthmoving
1.4 Mitigation: Reduce Vehicle Speeds Comments
1.5 Mitigation: Restrict Access Comments
Since speeds are generally low to begin with on jobs
of the scale impacted by this rulemaking, this
mitigation should have minimal cost impact on the
project.
Large-Scale Job Comments:
On large scale grading, scrapers will run about 40-60
mph at any given time. A reduction on such a large
scale from 40 to 20 mph would half the amount of
grading completed in a work day and double the
duration of grading. Something that would have
taken a month to accomplish now will take two
months and result in an increase in costs. While this
type of mitigation could be required by the State or
the county, because of costs, it is more likely that a
BMP involving water to wet haul roads to mitigate
dust will be used rather than inhibiting the speed of
the scrapers.
Operations: Negligible impacts on
operations since speeds are
typically low to begin with on the
scale of jobs impacted by this
specific rule making.
Initial Investment: None/Negligible
(signage, dirt speed bumps).
It is typical for areas of projects to have
limited/restricted access for safety concerns;
therefore, it is anticipated that projects already
control access to only necessary project vehicles.
Enforcement is also assumed to be part of jobs due
to safety concerns and not cost specific to this
rulemaking. Note that this may likely result in a cost
already shared for the storm water requirements of a
site.
Large-Scale Job Comments:
Costs will scale with the size of the job. However,
large scale jobs may be required to include this BMP
as part of fugitive dust plans required by the County
and State. Therefore, this may already to a cost to
this scale of project.
Operations: Negligible impact on
operations since areas are typically
restricted for safety concerns
anyway.
Initial Investment: None/Negligible
(limited to signage and potentially
blockades). Could also include
fencing at $1-$3/linear foot which
will work out to $300-$1000/month,
depending on the size of the
project.
6
2. Demolition/Renovation
2.1 Mitigation: Asbestos or Lead Materials Comments
2.2 Mitigation: Building Permit
Comments
Initial Investment: None/Negligible
Operations: None/Negligible
Initial Investment: None/Negligible Costs would be incurred as a result of another City
permitting program; therefore this mitigation does not
result in cost incurred as part of the dust manual.
Large-Scale Job Comments:
None
Operations: None/Negligible
Costs would be incurred as a result of State
permitting programs; therefore this mitigation does
not result in costs incurred as part of the dust manual.
Large-Scale Job Comments:
Costs will scale depending on the nature (i.e., indoor
vs. outdoor) and extent of the project. Regardless,
costs will be incurred as a results of State permitting
programs regardless of size.
7
Demolition/Renovation
2.3 Mitigation: Drop Height Comments
2.4 Mitigation: High Winds Restriction Comments
Initial Investment: None/Negligible
Operations: None/Negligible;
minimizing drop heights should
not have a large impact on the
operations of both small and large
jobs.
This mitigation is about awareness. Therefore,
minimizing drop heights should not have a large
impact on operations since it is about being mindful to
minimize dump heights from loaders to trucks and
stockpiles. There might be a delay and cost
associated with increased or more focused time
operating equipment this will probably be negligible
with the exception of training.
Large-Scale Job Comments:
Large scale jobs may be required to include this BMP
as part of fugitive dust plans required by the county
and State. Therefore, this may already to a cost to
this scale of project. Regardless, costs associated
with large jobs are not expected to be much different
that smaller jobs.
Initial Investment: None/Negligible
An analysis of wind speeds from local sources
shows winds >30 mph on an hourly basis
(maximum) is between 1% and 6% of the time
between 6 am and 6 pm yearly, so assume stop
work 1%-6% of a 40-hour week, based on location.
Assuming $25/hr/employee, 5 employees and a 6%
stop work time, at a minimum, the cost of using this
mitigation would be $300/week, or $15,600/year.
Large-Scale Job Comments:
Large scale jobs have more employees and
potentially larger costs due to stop work; however,
as a percentage of total job cost, job scale is less a
factor. Regardless, large jobs are already required to
comply with high wind BMPs under the State and
County Rules. Therefore, this is already a cost to
this scale of jobs.
Operations:
Lost work Cost:
$$$$/person/year
Cost due to Schedule delays.
0 to 0.5% of total job cost
8
3. Stockpile
3.1 Mitigation: Drop Height Comments
3.2 Mitigation: Erosion Control Plan
Comments
Initial Investment: None/Negligible
This mitigation is about awareness. Therefore,
minimizing drop heights should not have a large
impact on operations since it is about being
mindful to minimize dump heights from loaders to
trucks and stockpiles. There might be a delay and
cost associated with increased or more focused
time operating equipment this will probably be
negligible with the exception of training.
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
County and State. Therefore, this may already to
a cost to this scale of project. Regardless, costs
associated with large jobs are not expected to be
Operations: None/Negligible; much different that smaller jobs.
minimizing drop heights should not
have a large impact on the
operations of both small and large
jobs.
Initial Investment: Time for
creation, implementation, and
management. Costs also
associated with training of
staff. The cost of silt fencing
will also be included on each
job. Costs from $$$$ to $$$$$
depending on job scale
(management)
Operations:
Job-specific ongoing training
Managing the implementation
of the plan.
Policing compliance of the
plan.
Costs 0.5 to 1% of total job cost
Training, creating and implementing the plan,
materials (silt fencing, etc.) may cost
approximately 0.5% to 1% of total job costs.
Larger projects that require more training and
management to implement the plan could have
greater costs.
Large-Scale Job Comments:
Large scale jobs are required to include this BMP
as part of a fugitive dust plan required by the
county and State. Therefore, this is already to a
cost to this scale of project. These costs are on
the order of $$$$’s.
9
Stockpile
3.3 Mitigation: Stockpile Permit Comments
Initial Investment: None/Negligible
Costs would be incurred as a result of another City
permitting program; therefore this mitigation does not
result in costs incurred as part of the dust manual.
Large-Scale Job Comments:
Costs associated with large jobs are not expected to
be much different that smaller jobs.
Operations: None/Negligible
10
4. Street Sweeping
4.1 Mitigation: Uncontrolled Sweeping Prohibited Comments
Initial Investment: Purchasing new
skid steer brooms, which are the
most commonly used broom type,
cost ~$5,000, and water system
adds ~$1,500. To purchase a
vacuum type skid steer broom
costs can exceed $10,000.
The effects of this mitigation will depend on
whether or not the company or individual
performing work already has possession of a
vacuum system or wetting system.
If already in possession of the system, and it is
familiar to staff, then negligible initial cost and
added time to use. If not, the project will have to
purchase the equipment and there will be time
training staff in equipment use.
Mitigation might include costs due to wetting as a
form of control. Important to note that there might
be some cost-sharing associated with already
required storm water regulations if this is part of a
construction operation.
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of a fugitive dust plan required by
the county and State. Therefore, this may already
to a cost to this scale of project.
Operations: Depends on whether or
not the company or individual(s)
performing work has possession of
a vacuum system.
Costs 0.5 to 1% of total job cost
11
5. Track-out/Carry-out
5.1 Mitigation: Remove Deposition Comments
Initial Investment: There will be
an initial cost associated with
every engineering control. The
difference is what engineering
control is selected. For example,
removing deposition would result
in an initial investment of about
$150. However, a gravel apron
or vehicle tracking pad could
cost around $600-$700. Labor
could add an additional $1000 to
these totals.
Depending on the engineering control chosen,
there will be a range of potential costs (both initial
and maintenance). However, certain engineering
controls may have larger initial costs but save time
in the long run. For example, the cost and time
associated with installing and maintaining a gravel
apron may be less over time than a vehicle and
equipment wash station. However, with an
ineffective gravel apron or vehicle tracking pad
there will be a significant increase in material and
time sweeping.
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of a fugitive dust plan required by the
County and State. Therefore, this may already be
a cost to this scale of project.
Regardless, costs associated with large jobs are
not expected to be much different that smaller jobs
as a percentage of total project cost.
Operations: None/Negligible effects
on operations, unless the
engineering control(s) chosen are a
washing station or the manual
removal of mud, dirt, debris, etc.
from equipment and vehicles. In
which case, costs will be $$$$$.
12
6. Bulk Materials Transport
6.1 Mitigation: Drop Height Comments
6.2 Mitigation: Load Cover Comments
Initial Investment: None/Negligible
This mitigation is about awareness. Therefore,
minimizing drop heights should not have a large
impact on operations since it is about being
mindful to minimize dump heights from loaders to
trucks and stockpiles. There might be a delay and
cost associated with increased or more focused
time operating equipment this will probably be
negligible with the exception of training.
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
county and State. Therefore, this may already to a
cost to this scale of project. Regardless, costs
associated with large jobs are not expected to be
much different that smaller jobs.
Operations: None/Negligible;
minimizing drop heights should not
have a large impact on operations
of small and large jobs.
Initial Investment: None/Negligible.
There may be an initial cost
associated with the cover itself,
which is on the magnitude of $100.
Covering/Enclosing all material should have very
limited impact on costs and operations.
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
county and State. Therefore, this may already to a
cost to this scale of project. Regardless, costs
associated with large jobs are not expected to be
much different that smaller jobs.
Operations: None/Negligible, with
some (minimal) added time
required to cover and uncover the
material daily.
13
7. Unpaved Roads and Haul Roads
7.1 Mitigation: Reduce Vehicle Speeds Comments
7.2 Mitigation: Restrict Access Comments
Initial Investment: None/Negligible;
approximately $200-$1000 for
signage and installation of speed
bumps.
Since speeds are generally low to begin with on
jobs of the scale impacted by this rulemaking, this
mitigation should have minimal cost impact on the
project.
Large-Scale Job Comments:
On large scale projects, higher speeds on long
roads allow the activity to move more quickly to
control costs. A reduction on such a large scale
will impact project progress and result in an
increase in costs. While this type of mitigation
could be required by the State or the County,
because of costs, it is more likely that a BMP
involving water to wet haul roads to mitigate dust
will be used rather than inhibiting vehicle speeds.
Operations: Negligible impacts on
operations since speeds are
typically low to begin with on the
scale of jobs impacted by this
specific rule making.
Initial Investment: None/Negligible
(limited to signage and potentially
blockades). Could also include
fencing at $1-$3/linear foot which
will work out to $300-$1000/month,
depending on the size of the
project.
It is typical for areas of projects to have
limited/restricted access for safety concerns;
therefore, it is anticipated that projects already
control access to only necessary project vehicles.
Enforcement is also assumed to be part of jobs
due to safety concerns and not cost specific to
this rulemaking. Note that this may result in a cost
already shared for the storm water requirements
of a site.
Large-Scale Job Comments:
Costs will scale with the size of the job. However,
large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
County and State. Therefore, this may already to
a cost to this scale of project. Costs will scale with
the size of the job.
Operations: Negligible impact on
operations since areas are typically
restricted for safety concerns
anyway.
14
8. Parking Lot
8.1 Mitigation: Chemical Stabilization Comments
8.2 Mitigation: Reduce Vehicle Speeds Comments
Initial Investment: There will be an
initial cost for the application of the
chemical stabilizers, depending on
the area it’s being applied to.
Approximately $6000-$10,000
which includes rental of the
equipment.
Depending on the area of the parking lot, activity
in the parking lot, the price of chemical
stabilization and the efforts necessary to prevent
run-off will have varying degrees of intensity. Also,
due to exposure time to the elements or increased
traffic usage, this might result in multiple
subsequent applications.
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
County and State. Therefore, this may already be
a cost to this scale of project. This BMP could be
costly depending on size, use and number of
Operations: Expect minimal applications (Costs 0.5 to 1% of total job cost).
operations costs after initial
application, with the exception of
preventing runoff.
Initial Investment: None/Negligible
(signage, dirt speed bumps).
Since speeds are generally low to begin with on
jobs of the scale impacted by this rulemaking, this
mitigation should have minimal cost impact on the
project.
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of a fugitive dust plan required by the
county and State. Therefore, this may already be
a cost to this scale of project.
Regardless, costs associated with large jobs are
not expected to be much different that smaller
jobs since this BMP is associated with parking
areas.
Operations: Negligible impacts on
operations since speeds are
typically low to begin with on the
scale of jobs impacted by this
specific rule making.
15
Parking Lot
8.3 Mitigation: Restrict Access Comments
8.4 Mitigation: Surface Improvements Comments
Initial Investment: None/Negligible
(limited to signage and potentially
blockades). Could also include
fencing at $1-$3/linear foot. which
will work out to $300-$1000/month,
depending on the size of the
project.
It is typical for areas of projects to have
limited/restricted access for safety concerns;
therefore, it is anticipated that projects already
control access to only necessary project vehicles.
Enforcement is also assumed to be part of jobs
due to safety concerns and not cost specific to this
rulemaking. Note that this may likely result in a
cost already shared for the storm water
requirements of a site.
Large-Scale Job Comments:
Costs will scale with the size of the job. However,
large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
County and State. Therefore, this may already to
Operations: Negligible impact on a cost to this scale of project.
operations since areas are typically
restricted for safety concerns
anyway.
Initial Investment: There is an initial
investment in the installation of the
gravel (or similar materials). The
cost for gravel alone (not including
installation) is around $25,000.
Installation is anticipated to be
Costs are estimated based on a 4 inch think
gravel @ $9.20 per sq. yd. over a 25,000 square
foot area. Costs will increase based on size of the
parking lot.
Large-Scale Job Comments:
Costs will scale with the size of the job. However,
large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
County and State. Therefore, this may already to
a cost to this scale of project. This BMP is likely to
be costly for large projects (Costs 0.5 to 1% of
total job cost).
Operations: Maintenance on the
gravel is estimated to be around
$2,000/year+. Maintenance will be
handled by an outside contractor
outside of business hours and will
not impact the project schedule.
16
Parking Lot
8.5 Mitigation: Sweeping Comments
1 Costs are estimated for a 25,000 square foot area and assume the equipment is all rented.
8.6 Mitigation: Vegetation Comments
Initial Investment: Assuming
rental service, all costs will be
O&M. Potential cost of Vacuum
System (~$1,000, rented1).
Purchasing new skid steer
brooms, which is the most
commonly used broom type,
cost ~$5,000, water system
adds ~$1,500. To purchase a
vacuum type skid steer broom
costs can exceed $10,000.
The effects of this mitigation will depend on
whether or not the company or individual
performing work already has possession of a
vacuum system or wetting system.
If already in possession of the system, and it is
familiar to staff, then negligible initial cost and
added time to use. If not, the project will have to
purchase the equipment and there will be time
training staff in equipment use.
Mitigation might include costs due to wetting as a
form of control. Important to note that there might
be some cost-sharing associated with already
required storm water regulations if this is part of a
construction operation.
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of a fugitive dust plan required by the
county and State. Therefore, this may already to a
cost to this scale of project.
Operations: The cost of renting a
mechanical sweeper is about
$8,000 for a typical job.
Initial Investment: Direct costs
between $800 and $1500/acre for
seeding and mulch plus labor at
approximately $2,000. Water
trucks cost between $85-105/hour
and some contractors have
minimums and/or mobilization
charges.
The purpose of this mitigation technique is to
retain soils or create a wind break by planting
vegetation. Because of this, the area of the work
site will have a big effect on costs. Using
mechanical seeding, cost is around $725 (based
on an area of 25,000 square feet) for seeding and
$375/year of O&M costs.
Large-Scale Job Comments:
This is a state storm water requirement so costs
can be shared with dust mitigation.
Large scale jobs may be required to include this
BMP as part of a fugitive dust plan required by the
county and State and State storm water
requirements. Therefore, this is likely already a
17
Initial Investment: Significant,
depending on the size of the
project. For materials alone on a
wind barrier that is assumed to be
composed of 107 panels at
$430/panel, the cost is around
$46,000. Multiple days and
laborers to install totaling
approximately $10,000.
Parking Lot
8.7 Mitigation: Wet Suppression Comments
8.8 Mitigation: Wind Barrier Comments
Initial Investment: No initial
investment. Assuming the
equipment is rented; the costs will
be all O&M.
Costs are based on the use of a water truck,
which costs $0.89/square yard. Also assumed
was an estimated area of 25,000 square feet
(2,777 square yards) and a frequency of once per
month for a year.
Large-Scale Job Comments:
Costs will scale with the size of the job. However,
large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
County and State. Therefore, this may already to
a cost to this scale of project. This BMP is likely
to be costly for large projects (Costs 0.1 to 0.5%
of total job cost).
Operations: O&M are estimated to
be approximately $30,000/year.
Application of water should not
interfere with normal daily
operations and delay the schedule.
Assuming annual O&M costs are around
$720/year and the materials for the wind barrier
around $46,000 (based on 160 feet per side,
4 sides), the annualized cost of this control
measure is approximately $13,000.
Large-Scale Job Comments:
Costs will scale with the size of the job. However,
large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
County and State. Therefore, this may already to
a cost to this scale of project. This BMP is likely
to be costly for large projects (Costs 0.1 to 0.5%
of total job cost).
Operations: Minimal O&M costs
associated with inspecting the
barrier (<$1,000), unless the
construction of the barrier interferes
with normal daily operations.
18
9. Open Area
9.1 Mitigation: Chemical Stabilization Comments
9.2 Mitigation: Soil Retention Comments
Initial Investment: There will be an
initial cost for the application of the
chemical stabilizers, depending on
the area it’s being applied to.
Approximately $6000-$10,000
which includes rental of the
equipment. Lifespan of an
application is limited but likely
needs to be reapplied each year at
approximately $1700/acre.
Depending on the size of the area, and activity in
the area, the price of chemical stabilization and
the efforts necessary to prevent run-off will have
varying degrees of intensity. Also, due to
exposure time to the elements or increased traffic
usage, this might result in multiple subsequent
applications.
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
County and State. Therefore, this may already be
a cost to this scale of project. This BMP could be
costly depending on size, use and number of
Operations: Expect minimal applications (Costs 0.1 to 0.5% of total job cost).
operations costs after application,
with the exception of preventing
runoff.
Initial Investment: There will be an
initial cost of at least $16,000 plus
$10,000 for application of a
revegetation mat, based on the
assumption of a 25,000 square foot
area.
Soil retention will have varying effects on the
project depending on the areas that require
additional vegetation. Costs will also vary based
on project size; this estimate assumed a 25,000
square foot area (2,777 square yards) and a
revegetation mat cost of $5.70/square yard.
While the vegetation is being established, or for
approx. 30 days (30 days is an irrigated area
most open areas are lucky if vegetation takes
within a month usually it can take 12-24 months
and on occasions 36 months to fully take as it is
weather dependent), the area should remain
inactive, this could impact operations/schedule if
the area is critical to the project.
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
County and State. Therefore, this may already be
a cost to this scale of project. This BMP could be
costly depending on size, and if vegetation
establishes rapidly (Costs 0.5 to 1% of total job
cost).
Operations: Annual O&M costs are
19
Open Area
9.3 Mitigation: Surface Roughening Comments
9.4 Mitigation: Synthetic or Natural Cover Comments
Initial Investment: No initial
investment. Assuming the
equipment is rented.
Values were based on the following assumptions:
1) An area of 25,000 square feet; 2) $995 for
10,000 to 20,000 square feet of tractor surface
roughening; 3) Frequency of once a month for a
year. For a larger area, surface roughening costs
$300-$500/acre.
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of a fugitive dust plan required by the
county and State. Therefore, this may already be
a cost to this scale of project.
Regardless, costs associated with large jobs are
not expected to be much different that smaller
jobs (as a percentage of total cost) since the costs
scale with the size of the area.
Operations: O&M costs are
estimated to be approximately
$15,000/year.
Negligible impact on operations if
the area is one of inactivity.
Initial Investment: There will be an
initial cost associated with the
biodegradable mesh matting of
approximately $1,750. This cost
does not include the cost of
installation.
The purpose of this mitigation is to prevent dust
control during hours of inactivity. The initial costs
were based on an area of 25,000 square feet, and
a cost of biodegradable mesh matting of
$0.63/square yard. When factoring in the cost of
seed prior to installing the blankets, matting can
be as costly as $2.52/square yard average.
Lifespan of the blankets is typically 12-18 months
before needing maintenance or reinstallation.
Replacement after bio- and photo-degradability
will result in replacing the cover material
(applicable to long duration jobs).
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
County and State. Therefore, this may already be
a cost to this scale of project. This BMP could be
costly depending on size, use and number of
applications (Costs 0.5 to 1% of total job cost).
Operations: Annual O&M costs are
estimated to be $5,000. Negligible
impacts on routine operations,
except for the time required to
cover and uncover materials.
20
Open Area
9.5 Mitigation: Vegetation Comments
9.6 Mitigation: Wet Suppression Comments
Initial Investment: Direct costs
between $700 and $800 for
seeding plus labor at
approximately $2,000.
The purpose of this mitigation technique is to
retain soils or create a wind break by planting
vegetation. Because of this, the area of the work
site will have a big effect on costs. Using
mechanical seeding, cost is around $725 (based
on an area of 25,000 square feet) or $800-
$1,200/acre to seed and mulch large areas for
seeding and $375/year of O&M costs.
Large-Scale Job Comments:
This is a state storm water requirement so costs
can be shared with dust mitigation.
Large scale jobs may be required to include this
BMP as part of a fugitive dust plan required by
the county and State and State storm water
requirements. Therefore, this is likely already a
cost to this scale of project.
Operations: None/Negligible effects
on operations (<$500 roughly
$100/AC to mow which is typically
needed 3-4 times/year), except for
perhaps taking care to not
harm/destroy the vegetation. Costs
may be incurred to reseed areas
that did not take on the prior
seeding.
Initial Investment: No initial
investment. Assuming the
equipment is rented; the costs will
be all O&M.
Costs are based on the use of a water truck,
which costs $0.89/square yard or $85-$100/hr.
Also assumed was an estimated area of 25,000
square feet (2,777 square yards) and a frequency
of once per month for a year. Water must be
reapplied daily in dry and/or windy conditions.
Large-Scale Job Comments:
Costs will scale with the size of the job. However,
large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
County and State. Therefore, this may already to
a cost to this scale of project. This BMP is likely
to be costly for large projects (Costs 0.1 to 0.5%
of total job cost).
Operations: O&M are estimated to
be approximately $30,000/year.
Application of water should not
interfere with normal daily
operations and delay the schedule.
21
Initial Investment: Significant,
depending on the size of the
project. For materials alone on a
wind barrier that is assumed to be
composed of 107 panels at
$430/panel, the cost is around
$46,000. Multiple days and
laborers to install totaling
approximately $10,000.
Open Area
9.7 Mitigation: Wind Barrier Comments
Assuming annual O&M costs are around
$720/year and the materials for the wind barrier
around $46,000 (based on 160 feet per side,
4 sides), the annualized cost of this control
measure is approximately $13,000.
Large-Scale Job Comments:
Costs will scale with the size of the job. However,
large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
County and State. Therefore, this may already to
a cost to this scale of project. This BMP is likely
to be costly for large projects (Costs 0.1 to 0.5%
of total job cost).
Operations: Minimal O&M costs
associated with inspecting the
barrier (<$1,000), unless the
construction of the barrier interferes
with normal daily operations.
22
10. Saw Cutting or Grinding
10.1 Mitigation: Equipment & Work Area Clean-up Comments
10.2 Mitigation: High Winds Restriction Comments
Initial Investment: There will be no
initial cost associated with this
mitigation; all costs are assumed to
be O&M.
Much of this mitigation applies to general
housekeeping, which should not have major
effects on the project since it is already integral to
the process. However, renting a 30" head, gas
powered vacuum at a price of $4.55/M.L.F
(assuming a 10,000 square foot area) could cost
upwards of $70,000 (O&M costs) if you are
vacuuming daily for a month.
Large-Scale Job Comments:
Large scale jobs may be required to include this
BMP as part of a fugitive dust plan required by
the county and State. Therefore, this may already
be a cost to this scale of project.
Regardless, costs associated with large jobs are
not expected to be much different that smaller
jobs (as a percentage of total cost) since the
costs scale with the size of the area.
Operations: O&M costs (0 to 0.3%
of the total project costs).
Initial Investment: None/Negligible
An analysis of wind speeds from local sources
shows winds >30 mph on an hourly basis
(maximum) is between 1% and 6% of the time
between 6 am and 6 pm yearly, so assume stop
work 1%-6% of a 40-hour week, based on
location.
Assuming $25/hr/employee, 5 employees and a
6% stop work time, at a minimum, the cost of
using this mitigation would be $300/week, or
$15,600/year.
Large-Scale Job Comments:
Large scale jobs have more employees and
potentially larger costs due to stop work;
however, as a percentage of total job cost, job
scale is less a factor. Regardless, large jobs are
already required to comply with high wind BMPs
under the State and County Rules. Therefore, this
is already a cost to this scale of jobs.
Operations:
Lost work Cost:
$$$$/person/year
Cost due to Schedule delays.
0 to 0.5% of total job cost
23
Saw Cutting or Grinding
10.3 Mitigation: Restrict Access Comments
10.4 Mitigation: Slurry Clean Up Comments
Initial Investment: None/Negligible
(limited to signage and potentially
blockades). Could also include
fencing at $1-$3/linear foot.
It is typical for areas of projects to have
limited/restricted access for safety concerns;
therefore, it is anticipated that projects already
control access to only necessary project vehicles.
Enforcement is also assumed to be part of jobs
due to safety concerns and not cost specific to
this rulemaking.
Large-Scale Job Comments:
Initial cost will be needed for installing or renting
fencing in order to limit and restrict access;
around $300-$1000/month, depending on the
size of the project and required maintenance. It is
of note to mention that this may likely result in a
cost already shared for the Safety and storm
water requirements of a site.
Operations: Negligible impact on
operations since areas are typically
restricted for safety concerns
anyway.
Initial Investment: There will be an
initial cost associated with the
engineering control and some
training. For example, a slurry
clean up vacuum system costs
around $2000, without labor.
Costs were estimated using a work area 50'x50'
(2,500 square feet) with 30 days of work and
project cost at $65,000.
For O&M, assume 30 minutes at the end of each
day for cleanup.
Large-Scale Job Comments:
Operations: Monthly O&M is
estimated to be $500 to use and
maintain the vacuum system.
Otherwise, none/negligible effects
on operations.
24
11. Abrasive Blasting
11.1 Mitigation: Equipment & Work Area Clean-up Comments
11.2 Mitigation: High Winds Restriction Comments
Initial Investment: There will be no
initial cost associated with this
mitigation; all costs are assumed to
be O&M.
Much of this mitigation applies to general
housekeeping, which should not have major
effects on the project since it is already integral to
the process. However, renting a 30" head, gas
powered vacuum at a price of $4.55/M.L.F
(assuming a 10,000 square foot area) could cost
upwards of $70,000 (O&M costs) if you are
vacuuming daily.
Large-Scale Job Comments:
Operations: O&M costs (0 to 0.3%
of the total project costs).
Initial Investment: None/Negligible An analysis of wind speeds from local sources
shows winds >30 mph on an hourly basis
(maximum) is between 1% and 6% of the time
between 6 am and 6 pm yearly, so assume stop
work 1%-6% of a 40-hour week, based on
location.
Assuming $25/hr/employee, 5 employees and a
6% stop work time, at a minimum, the cost of
using this mitigation would be $300/week, or
$15,600/year.
Large-Scale Job Comments:
This category has a negligible effect on
construction and therefore a negligible cost. The
lost time is no worse/different than days lost to
rain or other inclement weather.
Operations:
Lost work Cost:
$$$$/person/year
Cost due to Schedule delays.
0 to 0.5% of total job cost
25
Abrasive Blasting
11.3 Mitigation: Restrict Access Comments
11.4 Mitigation: Slurry Clean Up Comments
Initial Investment: None/Negligible
(limited to signage and potentially
blockades). Could also include
fencing at $1-$3/linear foot which
will work out to $300-$1000/month,
depending on the size of the
project.
It is typical for areas of projects to have
limited/restricted access for safety concerns;
therefore, it is anticipated that projects already
control access to only necessary project vehicles.
Enforcement is also assumed to be part of jobs
due to safety concerns and not cost specific to
this rulemaking. Note that this may likely result in
a cost already shared for the storm water
requirements of a site.
Large-Scale Job Comments:
Costs will scale with the size of the job. However,
large scale jobs may be required to include this
BMP as part of fugitive dust plans required by the
County and State. Therefore, this may already to
a cost to this scale of project.
Operations: Negligible impact on
operations since areas are typically
restricted for safety concerns
anyway.
Initial Investment: There will be an
initial cost associated with the
engineering control and some
training. For example, a slurry
clean up vacuum system costs
around $2000, without labor.
Costs were estimated using a work area 50'x50'
(2,500 square feet) with 30 days of work and
project cost at $65,000.
For O&M, assume 30 minutes at the end of each
day for cleanup.
Large-Scale Job Comments:
None
Operations: Monthly O&M is
estimated to be $500 to use and
maintain the vacuum system.
Otherwise, none/negligible effects
on operations.
26
12. Mechanical Blowing
12.1 Mitigation: High Winds Restriction Comments
12.2 Mitigation: Blowing Techniques Comments
Initial Investment: None/Negligible
An analysis of wind speeds from local sources
shows winds >30 mph on an hourly basis
(maximum) is between 1% and 6% of the time
between 6 am and 6 pm yearly, so assume stop
work 1%-6% of a 40-hour week, based on
location.
Assuming $25/hr/employee, 5 employees and a
6% stop work time, at a minimum, the cost of
using this mitigation would be $300/week, or
$15,600/year.
Large-Scale Job Comments:
Large scale jobs have more employees and
potentially larger costs due to stop work;
however, as a percentage of total job cost, job
scale is less a factor. Regardless, large jobs are
already required to comply with high wind BMPs
under the State and County Rules. Therefore, this
is already a cost to this scale of jobs.
Operations:
Lost work Cost:
$$$$/person/year
Cost due to Schedule delays.
0 to 0.5% of total job cost
Initial Investment: There will be
none/negligible initial costs to
methods alternate to leaf blowing,
such as raking. Assume $30 for a
rake or broom per job.
Switching from a leaf blower to a rake or broom
will increase the amount of time to complete the
work. This will have large impacts to a project and
will depend, on the size of the affected area.
Assume additional O&M costs of $50 to
$100/year per job (multiple additional hours to
rake a 400 square foot yard, once per year at
$15/hour).
Lost efficiency is the cost of using a rake, broom,
or shovel to clean up debris. It is reasonable to
suggest it will take twice as long to complete a job
using mechanical methods as opposed to a leaf
blower. Even at that these costs are likely
negligible.
Large-Scale Job Comments:
Not likely to be applicable to projects greater than
5 acres.
Operations: Activities will take
longer or require additional
personnel. Assume additional O&M
costs of $50 to $100/year.
Fugitive Dust – Draft Training, Outreach and Education Proposal for Option 1
Background: Since 2013, staff has been working with the community and City Council to develop regulations that will prevent, minimize, and mitigate fugitive
dust emissions from 13 dust generating activities, e.g., earthmoving, mechanical blowing, etc. On April 5, 2016, City Council will consider adoption of the
proposed regulations. If Council elects to adopt the Option 1, staff has proposed to delay enforcement to allow for training, outreach, and education on the
Ordinance the accompanying guidance manual. This document outlines the proposed plan for this training and outreach.
Proposal:
Training Element Lead Timeline Audience
May-
June
June-
Aug
Sept/Oct Nov or
1/1/17
City
Inspection
Staff
City Staff that
Generate Dust
City Staff
Generally
Private Sector/
Contractors
General
Public
Develop Training
Materials
ESD X X X X X X
Develop
Enforcement
Materials
ESD X X
Conduct Training
Sessions
ESD X X X X X
Conduct Outreach ESD X X X X X X X
Begin enforcement
(no fines)
Inspection
Staff
X X
Begin official
enforcement
Inspection
Staff
X X
Notes:
• Training materials will include presentations that include a general overview of the changes to the Code, the guidance manual, and requirements of
individual parties. Training sessions will be conducted with a) all City staff, including front line building staff; b) City inspectors; c) Contractors,
developers, etc. (including both City and private sector staff that generate dust).
• Enforcement materials will include draft enforcement worksheet that will be completed by inspectors in the field, the draft spreadsheet for tracking
enforcement, and a Sharepoint site to manage the various inspection documents.
• Outreach is designed to inform the general public about the regulations that have been adopted. Staff intends to develop a communication plan that
includes both traditional notifications, e.g., Utility mailer, as well as social media. Staff will work with the Communications and Public Involvement Office
to craft these materials.
Proposed Enforcement Approach: The proposed approach is as follows:
• Who will enforce? As the activities that generate dust span all types of City inspections, e.g., rights-of-way, developments, building construction, etc.,
the recommendation is that all City inspectors be trained to assist with enforcement in the field. This includes Code Compliance, Erosion Control, ROW
staff, and Building Inspectors, at a minimum.
• What is the proposed enforcement process? With all inspectors trained, it is proposed that whichever inspector is out in the field will address the issue
with the contractor on site (responsible for the action). To reduce duplicate discussions with operators, an email list will be created and after the
conversation in the field, an email notification will be sent to the group informing them that action has been taken. Finally, a spreadsheet will be
developed and stored so that inspectors can log complaints/issues/resolutions on a shared file for all.
• When will training and enforcement begin? Staff proposes that training be completed by April 30, 2016 and that enforcement begin by July 1, 2016.
Between adoption and July 1, the main focus will be on outreach, training and education on the proposed regulations.
• How will we train contractors, City staff, and others affected by the regulations? See opposite page. In addition, trained staff will need to be "sworn in"
by Police to uphold this particular section of the Code.
• Do we have the staff resources to adequately enforce these new regulations? Staff estimates that we have approximately one complaint per month,
with some instances, e.g., the mall, where more frequent complaints come in. It is currently anticipated that enforcement can take place with existing
resources, though it will need to be incorporated into work plans (as well as the training). The tracking spreadsheet of complaints will help us assess if
additional resources are needed for implementation.
Page 1
MINUTES
CITY OF FORT COLLINS
AIR QUALITY ADVISORY BOARD
Date: Monday, January 25, 2016
Location: Conf. Room 1A, 215 N. Mason Street
Time: 5:30–8:00pm
For Reference
John Shenot, Chair
Ross Cunniff, Council Liaison 970-420-7398
Lucinda Smith, Interim Staff Liaison 970-224-6085
Board Members Present Board Members Absent
+John Shenot, Chair
+Rich Fisher
+Robert Kirkpatrick
+Jim Dennison
+Vara Vissa
+Gregory Miller
+Tom Griggs
+Mark Houdashelt
+Chris Wood
Staff Present
+Lindsay Ex, Staff Liaison/Environmental Program Manager
+Dianne Tjalkens, Admin/Board Support
+Lucinda Smith, Director of Environmental Services
+Mike Gavin, Director of the Office of Emergency Management
+Matt Housley, HazMat Team Captain (PFA)
+Ron Gonzalez, Assistant Fire Marshall (PFA)
+Matt Zoccali, Regulatory and Governmental Affairs Manager
+Cassie Archuleta, Environmental Planner
Councilmembers Present
Guests
None
Call to order: 5:34pm
Public Comments: None
…
AGENDA ITEM 2: Fugitive Dust
Lindsay Ex, Environmental Program Manager, explained the fugitive dust regulation options that City staff
intends to present to Council for consideration at a February 9, 2016 work session. The AQAB offered
feedback to staff on the options and discussed whether the AQAB should recommend a particular option to
City Council.
Particulate Matter (PM) impacts are in health, reduced visibility, ecosystem and materials impacts and
nuisance. Have seen increased PM. Air emissions data shows majority of emissions come from construction
and roads. City lacks comprehensive approach to dealing with fugitive dust. State and County have
DRAFT
Page 2
regulations but only state can issue violations. Also lacking upfront guidance on how to comply with
regulations. Looking at series of code changes to make City able to enforce. Dust control manual, training
and support program, and public outreach planned if pass code changes. Have three options that all create an
enforceable ordinance, regardless of size of project. all options require covered loads. Option 1: adopt
ordinance and manual with delayed implementation to allow time for training/education. Option 2: Begin
enforcement immediately. Option 3: Adopt ordinance but do not make mitigation in manual required unless
problem occurs. More typical approach in other communities. Can require a plan upfront. In Option 3
required to prevent dust, but if a problem occurs, must use BMPs from manual. If complying with manual,
then in compliance with ordinance in options 1 and 2. In option 3 violation occurs if dust is leaving site.
Challenges with 1 & 2 are increasing project costs upfront. Challenge with 3 is doesn’t allow training and
outreach, and upfront budgeting if there is a problem. Also, assume Option 3 would generate more dust as no
BMPs required at all times.
Comments/Q&A
Option 3 is most resource intensive in terms of staffing? Have to continue to go back to project if not
in compliance. Greater workload.
o Need to consider more. Other options could have site checks without complaints, so resource
needs for both.
o Cost? To city? To company?
Council will ask as well. Have staff that goes to every construction site in city
biweekly anyway. Not having enforceable ordinance has created more use of staff
time. Any option would streamline.
No option has a cost as well: human health, responses to citizen calls, etc.
Currently going out on calls, but can only issue nuisance violations—very
difficult to do.
o With option 3, over time as people become aware of manual, might get more calls. Also
concerned about definition of “problem.” if code enforcement sees off property transport of
dust, or if citizen complaint, but if windy or saw cutting concrete with no water, buy time get
there wind is down, or project is done. Difficult from that standpoint. If do outreach with
option 3, imagine a few more people would do a little more than now. But many won’t. hard
to know what compliance would be if only enforceable if there is a “problem.” Option 3 is
better than nothing, but not as good as 1 or 2 and cost burdens those who want to do the right
thing. Need to spread cost evenly.
Option 1: hope that it would be done in a way that there is a fixed date that compliance becomes a
requirement, not set after done with training and outreach. clarify that. Option 3: creates a situation
where don’t have to do BMPs, and even if cause a problem, haven’t yet violated the ordinance. If
cause problem, only then have to do BMPs. So, why would I spend anything to do BMPs until
someone says there is a problem?
1 and 2 put primary burden on builders. Option 3 puts burden on City staff to track down violators.
Business owners prefer cost certainty. Options 1 and 2, know what have to do. Option 3 has no
penalty for not using any BMPs. Staged option? With ability to apply for delay or variance.
o Option 2: still talking about education through spring and summer.
Option 2: becomes effective 10 days after reading.
Builders have bid on projects for fall already.
What is impetus for immediate start?
Provide range of options for Council to consider.
Does Council always get options with any ordinance?
o Oftentimes.
o Heard feedback at work session for strategic plans, that going too far and need to look at
what the problem is that trying to solve.
o Option 3 shows not serious about the issue.
Delay for Option 1: implementation only delayed, or training delayed too?
Page 3
o Assuming Council adopts Option 1, would spend couple of months developing training
materials for community and for staff. Then time for actual training and time for inspectors to
notify builders.
o If manual is comprehensive, and there is list of additional practices, why are they not in the
manual?
If over 25 acres, already required to use dust control measures.
Which measures will you accept?
Very prescriptive to comply with the manual.
Option 3, a contractor could be not doing BMPs in manual, and have no dust
generated. Ex: building during rainy season.
Option 1 is one we’ve been considering for two years. Support this option. Have to pass this
ordinance. Talking about it for too long. Has been a problem for 15+ years.
Not much difference, practically, between 1 and 2. With 2, will give people slack on writing
violations for a while. No way people can comply immediately. Option 1 gives realistic time frame.
Bear in mind that this only restrict visible off property transport. These BMPs reduce to point where
can’t see it. Still making dust that is going off property. Not getting to zero.
Hasn’t board already recommended option 1?
o Have yet to recommend adoption of an ordinance. Helpful to Council to recommend one of
the three options.
o Recommend specific calendar date for enforcement.
o First reading April 5.
Would ordinance change if passed Option 3? Current ordinance language directs use of manual.
Greg moved and Tom seconded a motion to strongly recommend adoption of the Dust Control Ordinance
Option 1 with an enforcement date of November 1, 2016.
Motion passed unanimously, 8-0-0. Rich left before vote.
Discussion on motion:
Recommendation does not limit Council’s discussion of options.
o Board will also be able to make additional recommendations to Council.
Would council find it more persuasive to add reasoning for supporting that option?
o In AIS, staff would describe board’s discussion. Council appreciates a letter from the board,
which can be included in a slide or in AIS to Council.
o Public comment at work session?
No. Council and staff. Public comment at hearing.
…
Excerpt - Land Conservation and Stewardship Board
Wednesday, February 11. 2015
Re: Dust Control Manual
Dust Control Manual – Melissa Hovey
Due to an increase in development in the city and more and more complaints about dust City
Council requested the City Environmental Services Division propose code changes to the current
regulations to implement the best practices outlined in the Dust Prevention and Control Manual.
Health and environmental impacts from particulate matter are causing this to be a priority for the
department to close the gap in regulations and enforcement actions. Environmental Services is
seeking LCSB support for the municipal code change, a Dust Guidance Manual and an internal
policy and public outreach effort. No new fees would be implemented; this is using existing
staff in the field to respond to complaints. This is less active than some of enforcement
procedures so it’s mostly based on a complaint and enforcement actions. This does not require
any new permits, additional inspections, extra requirements or additional fees. We are not
expecting zero dust, but the enforcement would address whether or not you are following dust
control guidelines.
Applicable activities that would most affect the Natural Areas Department would be any and all
earthmoving activities, track out/carry out activities, unpaved roads and haul roads. Melissa
listed the site where a dust control survey can be taken by the general public
http://www.fcgov.com/airquality/fugitive-dust.php .
Kelly reported that this issue isn’t going before Council for a year and wanted to know why.
Melissa – I don’t know why, but I did inquire as to whether or not that was accurate and was told
yes. We are hoping that maybe after April that we can bring this issue back.
Kelly proposed it might be brought back to the table after the election.
Melissa reported that there has been much industry push back, specifically with the regulations
because most industry has their own dust control management practices in place and feel the
code to be duplicative of what they are currently doing.
Kathryn – Would it be helpful to have the general public write in to Council supporting the
issue?
Melissa- We are directing the public to go to Fort Collins Access and make an initial record of it
versus just writing a letter.
Kathryn – At what level is dust classified as fugitive and how do you define the term fugitive
and then how do you go about measuring this?
Melissa – The word fugitive means that it does not come from a stack chimney or vent, it’s just
out blowing around. We use EPA guidelines to help us measure it.
Trudy - Would it be helpful to submit a letter, from the board, to Council asking them to put the
item back on the agenda?
Kelly – It seems like there has to be a better way to get people to comply with the regulations
and I understand the goal is compliance, but it’s not punitive.
Melissa – The goal is to get someone from our staff, on the property to enforce the rules.
Kathryn – How do you prove infraction?
Melissa – Basically we are asking if you are doing this type of activity then are you using these
management practices. There is an assumption that dust emissions transferred over the property
line and if that’s the case then dust control measures must be in place.
Kelly – I would really like the LCSB to support this in the strongest way possible. Where is the
push back coming from?
Melissa - The larger guys that have worked out of state understand the regulations, but the
smaller size businesses that have only operated in northern Colorado are unfamiliar with this,
they are fearful of it, it’s new and they are quickly reading a 40 page manual and simply can’t
afford it. We’ve been very successful meeting with these smaller companies. It’s an education
hurdle to overcome but after we talk with them and give them the information they become
supportive of the idea.
Kathryn - I support this because of the health implications, especially for children. The asthma
rate is very high right now and seems to be getting worse.
Edward – Would there be a need to put in the letter what the stakes are, in this, for the Natural
Areas Department or are we just voicing an opinion on this.
Mark – We have a huge stake in this issue. Rick Bachand and Justin Scharton reviewed this as
well because we have some operations that this affects. We do a lot of earth moving projects and
agricultural projects so we certainly have concerns. We didn’t think there was anything in the
manual that we wouldn’t live up to. Those concerns are also listed in the Dust Control
memorandum that was sent out.
Trudy – Wasn’t it clear in the memo you sent out how this affect the Natural Areas Department?
Mark – Yes.
Trudy Haines made a motion to send a letter to City Council recommending the item be
put back on the March agenda and that City Council approve the proposed Code changes
to implement the best practices outline in the Dust Prevention and Control Manual
developed by the Environmental Services Department.. Kathryn Grimes seconded the
motion. The motion was unanimously approved.
Mark agreed to leave the memorandum as is and just add the language to encourage the item to
be placed on the March City Council agenda.
Parks & Recreation Board Meeting – January 28, 2015
Page 1 of 4
BE A GOOD STEWARD: Protect & Respect your Parks, Trails & Recreation Facilities
Call Meeting to Order: Bruce Henderson call the meeting to order 5:34pm.
Agenda Review & Items of Note:
• The newly appointed P&R Board members; Kelly Smith and Kenneth Layton were introduced.
• Craig Foreman shared a photo book showing some of his paintings and the easel he purchased with the gift card
the Board gave him at this retirement.
• Reminder that the Election of Officers will take place at the February meeting.
Citizen Participation
Danny Burdick with Fort Collins Disc Golf Association and Jon Boothe with Northern Colorado Disc Golf stopped in to
introduce themselves to the Board and to show their support disc golf courses in Fort Collins and invite the Board to play.
Approval of Minutes: Discussion: None
Scott Sinn made the motion to approve the Parks & Recreation Board minutes of December 3, 2014, seconded by Brian
Carroll – Minutes approved 5:0 (2 new members abstained as they were not present at the December meeting).
Meeting Summary
• Kurt Friesen, Director of Park Planning & Development presented the Board with the latest draft proposal for the
Southeast Community park design which will be presented to the neighborhood meeting. The schedule for the
process is for final design to be completed by September 2015 with construction to start in January 2016 for a
grand opening in May 2017. The new design has addressed the neighborhood concerns and has incorporated a
theme into the design that reflects the heritage of the land.
• Melissa Hovey, Senior Environmental Planner shared with the Board the proposed new code language to the
Health & Environment Codes to help control fugitive dust. "Fugitive dust" consists primarily of soil particles in
the air caused by wind and human activities such as excavating, demolition, abrasive blasting, and other activities.
Dust causes health problems; safety, visibility, and aesthetic issues; and is a nuisance causing damage to property
and machinery. City staff responds to numerous dust complaints from citizens each year and current codes and
policies do not adequately provide for the prevention and control of dust emissions or the protection of health and
the environment.
PARKS AND RECREATION BOARD MINUTES
Regular Meeting
Wednesday, January 28, 2015
5:30 p.m.
Board Chair:
Bruce Henderson, Chair 2014
bmhender6@gmail.com
Council Liaison:
Gino Campana – gcampana@fcgov.com
Staff Liaisons:
J.R. Schnelzer, 970-221-6301 – jrschnelzer@fcgov.com
Kurt Friesen, 970-221-6618 – kfriesen@fcgov.com
Bob Adams, 970-221-6354 – badams@fcgov.com
Parks & Recreation Board Meeting – January 28, 2015
Page 2 of 4
Full Minutes
AGENDA ITEMS:
Southeast Community Park Plans Update – Kurt Friesen
Kurt Friesen, Director of Park Planning & Development presented the Board with the latest draft proposal for the
Southeast Community park design which will be presented to the neighborhood meeting. The schedule for the process is
for final design to be completed by September 2015 with construction to start in January 2016 for a grand opening in May
2017.
We feel that the neighborhood concerns of:
• All parking located on south side of park
• Parking not distributed around the park
• Traffic concerns with park entrances on Kechter Road
• Preference for park entrance off of Ziegler Road
• Lighted ball and turf fields
• Playground to close to Kechter Road
• Unsightly BMX course highly visible from Ziegler Road
Have been addressed with the new design; parking will now be interior to the park with access off of Ziegler, the ball
fields will remain lighted; but the turf fields will not be lighted, the playground will also be more centralized in the park
and the BMX course will moved to the northeast corner of the park off of Lady Moon just west of the ball fields.
We wanted to keep the identity of the area which used to be a farm with an orchard, so some of the interesting elements
that may be incorporated in the design will include:
• The silos that will be removed from the intersection of Prospect & Timberline, which may be interactive in some
way or may be a lighted feature
• A large harvest table
• An orchard
• A trellis garden as well as a community garden
• And the use of the creek as a water feature for play
In addition, there will be the traditional elements of two ball fields and two multi-purpose turf fields, a dog park, a BMX track, and
some open space areas left in a more natural way to allow for quiet areas away from play areas.
Discussion
Board – It really seems like you’ve addressed the neighborhood concerns in a creative way.
Board – Another way to use the silos might be for music since the acoustics tend to be very good.
Board – Designing with the heritage of the property in mind is great.
Board – Keep pushing the envelope.
Dust Control Manual/Municipal Code Changes
Melissa Hovey, Senior Environmental Planner shared with the Board the proposed new code language to the Health &
Environment Codes to help control fugitive dust.
"Fugitive dust" consists primarily of soil particles in the air caused by wind and human activities such as excavating,
demolition, abrasive blasting, and other activities. Dust causes health problems; safety, visibility, and aesthetic issues; and
is a nuisance causing damage to property and machinery. City staff, in many departments, responds to numerous dust
complaints from citizens each year. Current codes and policies do not adequately provide for the prevention and control of
dust emissions or the protection of health and the environment. Staff in the Environmental Services Department has
constructed a draft approach to address fugitive dust issues that currently includes the following proposed components:
• Addition of a new section to the Municipal Code and minor changes to the Land Use Code
• Council adoption of a Dust Control Manual that includes dust control measures for specific dust generating
activities
Parks & Recreation Board Meeting – January 28, 2015
Page 3 of 4
• A modification to internal Administrative Policies to require compliance with the Dust Control Manual on City
projects
• Training of existing inspection and code compliance staff
• Public outreach and education
For more detailed information about the Code language and the review the Dust Prevention & Control Manual visit:
http://www.fcgov.com/airquality/fugitive-dust.php. There is also a survey you are welcome to take.
Discussion
Board – When will this being going to Council?
Staff – It was scheduled for March 3, for the first reading; but has been now put on the unscheduled work session agenda.
Board – Does this have an impact for Parks with their maintenance?
Staff – To some extent with our leaf blowing and removal; but we’re looking at new equipment. The downtown
maintenance will be a challenge as we look at ways to conform; since we blow off corners at 4:00am.
Board – What if you did this a pilot for one year to allow people/organizations to get new equipment in order to meet
compliance? Will there be a grace period for compliance?
Board – It seems that you may want to wait for a Code change and work on education and outreach so
people/organizations understand what it is and there is some “buy-in” of the need for the new Code language.
STAFF UPDATES
Parks Updates
• Parks is working on a waste reduction program as we work toward zero waste. With that Parks is providing more recycling
options in the parks and has “Recycling Zones” at each of the shops.
• The pavers in Old Town Square will be removed and available for anyone to take; with a minimal fee for stacking and
moving.
Recreation Updates
• ARO – 20 year anniversary celebration to be held on February 4th at the Senior Center from 5:00 – 8:00 PM
• Columbine/UCHealth and City of Fort Collins Partnership Report
o September, October, November
o Total Participation: 970 2013: 1468
o Variety of wellness services provided: 16 2013: 10
o Total Revenue: $7,532.00 2013: $18,177
• Park Planning, The Gardens and Spring Creek and Recreation staff hosted the Senior Center Community Gardens Open House on
February 14.
• This morning at the 8th Annual Breakfast of Champions hosted by CHAMP (Character in Athletics Make it a Priority) one of our
former employee and supporter of Parks and Recreation Keith Griffin (Griff) was the award recipient for the Sonny Lubick Coach
of Character Award.
• Foothills Activity Center has broken ground and plans to be open by mid-November.
• Mike McDonnell’s Retirement Party will be Thursday, February 26. Invites will be sent out.
• The Recreation Area Manager position has been announced.
• Operational Plan Action Item updates where presented at the all staff meeting last Friday, January 23.
o We identified 58 actions for the next 3 years.
o 2015 – we have 30 actions we are trying to accomplish
o Key Highlights
All teams are meeting to discuss action items.
Create a plan to begin a review of the organizational structure of the Division to address current silos,
impending retirements, workloads, cross functioning teams and succession planning.
Park Planning Updates
We have 30 active projects, but a couple to highlight are:
• I-25 Pedestrian Bridge - Park Planning recommends foregoing the construction of the I-25 pedestrian overpass, and instead
working with CDOT to construct the trail crossing at the Poudre River Bridge at the time of the bridge replacement. GOCO grant
money for the construction of the overpass may be used to construct a portion of the Poudre River Trail through the Arapahoe
Bend Natural Area instead.
Parks & Recreation Board Meeting – January 28, 2015
Page 4 of 4
• Avery Park Residence Meeting – There is a meeting scheduled for February 29 regarding the lighting in the area of Avery Park
for safety concerns.
• Fossil Creek Trail Underpass at Trilby – This project will be completed within days.
Bicycle Advisory Board Liaison Update
Explained the P&R Boards participation in the BAC.
Board Work Plan Items
Discussed and assigned members to various work plan items.
• Budget – BOB2 items that focus on P&R are: Gardens on Spring Creek Visitor’s Center Expansion, Southeast
Community Center Outdoor Pool, City Park Train, Club Tico Renovation
• Communications – No Update
• Sustainable Practices – No Update
• Parks – No Update
• Trails –Visited Land Conservation Meeting, so much marries with what P&R does it was an interesting discussion.
• Recreation – Working on the article on the history of Parks &Recreation gave me an opportunity to read “An
Anecdotal History of the Parks & Recreation Department of Fort Collins, CO”, which was written by Jean Helburg,
retired Director of Recreation. I would recommend the Board read her article as it was so interesting
http://www.fcgov.com/recreation/pdf/anecdotal_history.pdf
• Other Projects/Programs – No Update
Schedule of Articles/Calendar
Dawn will get the schedule of dates/articles out to the Board.
March – Archery Range
April – The Farm at Lee Martinez
May – City Park History
Bullet Points
• The Board was updated on the Southeast Community Park Design – Open House February 15
• The Board was updated on the Dust Control Manual & Proposed New Code Language and the Board felt there
needed to be more thought on implementation strategy.
• Introduction of new Board Members
Adjournment: Meeting adjourned 8:070pm
Respectfully submitted,
Carol Rankin
Carol Rankin
Administrative Supervisor Parks
Board Approved Minutes 2/25/15 - 8:0.
Board Attendance
Board Members: Ragan Adams, Brian Carroll, Bruce Henderson, Kenneth Layton, Jessica MacMillan, Scott Sinn, Kelly
Smith, Dawn Theis
Staff: Bob Adams, Kurt Friesen, JR Schnelzer, Carol Rankin, Craig Kisling, Mike Calhoon, Jeff Mihelich, Marty
Heffernan, Gino Campano and Melissa Hovey
Guest: None
Environmental Services
215 N. Mason
PO Box 580
Fort Collins, CO 80522
970.221-6600
970.224-6177 - fax
fcgov.com
MEMORANDUM
NATURAL RESOURCES ADVISORY BOARD
DATE: December 17, 2015
TO: Mayor and City Council Members
FROM: John Bartholow, on behalf of the Natural Resources Advisory Board (NRAB)
SUBJECT: Recommendation on Fugitive Dust Control
The NRAB has twice reviewed draft guidelines for controlling fugitive dust in Fort Collins
prepared by the Environmental Services Department, a problem arising from citizen nuisance
complaints and dutifully addressed by Staff.
We are swayed by the need for, and the multiple benefits of, dust control, both for the health of
our citizens and of our many wetlands and waterways, as well as supplementing ongoing efforts
to darken our nighttime skies.
The guidelines seem appropriate, not overly costly or invasive, and very much in line with
similar nuisance dust guidelines in other areas of the arid west.
We urge Council to put the Fugitive Dust Control elements in place by amending the Municipal
and Land Use Codes, adopting the Dust Control Manual, and approving any other actions
necessary to support this common sense dust control effort.
Respectfully submitted,
John Bartholow
Chair, Natural Resources Advisory Board
cc: Darin Atteberry, City Manager
Susie Gordon, Sr. Environmental Planner
Yes 65.0% 104
No 35.0% 56
Total 160
Total 163
New Summary Report - 03 March 2015
1. Do you support the implementation of dust control measures that are technologically feasible and
economically reasonable to prevent off-property transport of dust emissions?
Yes 65%
No 35%
2. Have you been negatively impacted by dust emissions from activities such as street sweeping, construction
and demolition, leaf blowing, earthmoving, abrasive blasting, or other dust generating activities in Fort Collins?
Yes 52.8%
No 47.2%
Yes 52.8% 86
No 47.2% 77
Total 163
It would have a NEGATIVE impact on me personally. 23.6% 38
It would have a POSITIVE impact on me personally. 51.6% 83
It would have NO impact on me personally. 24.8% 40
Total 161
3. In what way do you think the proposed dust prevention and control requirements would impact you personally?
It would have a NEGATIVE impact on me personally. 23.6%
It would have a POSITIVE impact on me personally. 51.6%
It would have NO impact on me personally. 24.8%
4. In what way do you think the proposed dust prevention and control requirements would impact businesses that
create dust such as landscapers, excavators, sand blasters, and construction related businesses?
It would have a NEGATIVE impact these types of
businesses. 67.3%
It would have a POSITIVE impact on these types of
businesses. 17.3%
It would have NO impact on these types of
businesses. 15.4%
It would have a NEGATIVE impact these types of
businesses.
67.3% 105
It would have a POSITIVE impact on these types of
businesses.
17.3% 27
It would have NO impact on these types of businesses. 15.4% 24
Total 156
Yes 28.8% 47
No 71.2% 116
Total 163
5. Do you have any respiratory or pulmonary issues that are affected by impacts from fugitive dust?
Yes 28.8%
No 71.2%
6. Which choice describes you best with regards to this issue?
I represent the general community in Fort Collins. 66.3% 108
I represent the business or industrial community in Fort
Collins.
19.0% 31
I represent the scientific or medical community in Fort
Collins.
14.7% 24
I do not live, work, or conduct business in Fort Collins 0.0% 0
Total 163
I represent the general community in Fort Collins. 66.3%
I represent the business or industrial community
in Fort Collins. 19%
I represent the scientific or medical community in
Fort Collins. 14.7%
February 9, 2016
Fugitive Dust
Jackie Kozak Thiel, Lucinda Smith, Lindsay Ex
Questions for City Council
2
• What feedback does Council have regarding the proposed options:
1. Adopt Code Changes and Manual, delay enforcement
2. Adopt Code Changes and Manual, begin enforcement immediately
3. Adopt Code Changes only, use Manual as guidance
4. Status Quo
• Does Council suggest any additional outreach before First
Reading?
Presentation Outline
3
• What is the problem we’re trying to solve?
• Initial Approach
• Pilot Project
• Proposed Options
• Feedback to Date
• Discussion
What is fugitive dust?
4
Solid particles (particulate matter) suspended in the air
by wind or human activity that don’t pass through a
stack, chimney, or vent…
Dirt soil leaves
silica asbestos soot
molds fungi pathogens bacteria
manure pollen ash
pesticides heavy metals brake linings
What is the problem?
5
5
Over ¼ of Fort Collins’
households have a
member with respiratory
ailments
• Impacts to the Public – Quality of Life
– Nuisance
– Health Concerns
– Reduces visibility
– Impacts to the ecosystem
• Impacts to the City
– Staff Resources –
• Up to 50-100 complaints/year
What is the problem?
6
• Existing regulations
– State rules apply to stationary
sources and >25 acres
– Larimer County rule applies to land
development >5 acres
• Can respond to complaints, can’t
issue violations
– Existing Fort Collins regulations are
difficult to enforce
Large developments are covered by state
regulations
What is the problem?
7
• Gaps and Issues
– No requirements for projects under 5
acres and certain project types
– Limited state capacity to meet
residents’ expectations
– No entity offers clear and upfront
guidance on how to comply
• Increases project budgets when
addressing issues on a reactive basis
Street cleanup on Horsetooth Road
Initial Approach
8
Code
Changes
Dust Control
Manual
Training and
Support
Public
Outreach
Code Changes
9
• City Code
– Applies to all dust generating activities
– Requires operators to comply with the Manual
• Land Use Code
– References the Manual
– Makes minor changes to the LUC to align with
the City Code changes
Manual
10
• The manual outlines 33 Best Management
Practices to address 12 dust generating
activities
– Example: Earthmoving
• Definition: Site prep, grading, excavating, etc.
• Required BMPs: measures required on every site
• Additional BMPs: if required BMPs do not prevent fugitive
dust, at least one of these BMPs must be applied
Training and Rollout
11
• Develop training materials (May-June)
• Conduct training sessions (June-Aug)
• Conduct public outreach (June-Oct)
• Begin soft enforcement (Sept-Oct)
• Begin official enforcement (Nov 1)
Enforcement
12
• Civil infraction
• Violation if not in compliance with the Manual
– All required BMPs must be in place
– If unsuccessful at preventing off-property
transport, at least one additional BMP
Initial Public Engagement
13
• April 2014 – February 2015
– Met with 6 City Boards and Commissions
– Online Survey – 163 respondents
– Open House – February 2015 (14 attendees)
– Extensive discussions with 8 City Departments
– Specific outreach to the business community:
• Chamber of Commerce,
• Business meetings, and
• A stakeholder meeting with 23 attendees in
December 2014
Project Pilot
14
• In early 2015, Councilmembers directed staff
to conduct a pilot of the program:
– To collect data:
• Impact (do the BMPs mitigate dust?)
• Water
• Time
• Cost
– To engage stakeholders:
• A Fugitive Dust Working Group was formed
Data Collection - Impacts
15
• Field Data Collected this Summer:
– Conducted 46 observations over 20 sites
• 17 (37% of observations) – met the standards
in the Manual
• 31 (67%) – some dust mitigation in place
• 15 (33%) – zero dust mitigation BMPs
– Conducted 8 controlled measurements
• Employing mitigation techniques can reduce
dust generated up to 50-95%
Data Collection - Water
16
• Water
– Difficult to measure
– Some BMPs have minimal water use, e.g., on-tool wet suppression
– Some high higher, wet suppression with a water truck or on a stockpile
– Highest water use likely at sites where a dust control plan is already
required, e.g., Rigden Farm
Data Collection - Cost
17
High
O&M
Low
O&M
Low Capital Costs High Capital Costs
See Attachment 6 for detailed cost estimates for every BMP
Restricting Access
(e.g., Demolition/Renovation)
High Winds
Restriction
(e.g., Earthmoving)
Surface
improvements
(e.g., Parking Lot)
Wind barrier
(e.g., Parking Lot or Open Area)
Note: 9 of the 12
dust generating
activities have a low
capital/low O&M
(operations and
maintenance) option
Data Collection - Cost
18
• Affordability – Private Sector
– Can increase project costs:
• Commercial projects – range from 0.5 – 1.1% of costs
• Single-family homes - range from 0.2 – 3.3% of costs
– FDWG agrees costs will increase and will likely be borne by end users
• Affordability – City
– In general, Departments already follow the BMPs
– Would affect City construction projects, e.g., buildings
Pilot – Outreach
19
• Fugitive Dust Working Group
– Composed of private, public and academic representatives
– Met on a monthly basis
– Provided feedback on the pilot study design and results
– Discussed cost data at three separate meetings
– Provided extensive feedback on the Manual, Draft Code language, and the
proposed enforcement strategy
Pilot – Outreach
20
• Additional Outreach
– Approach outlined has been recommended by 5 City Boards
– Visited with the Chamber LLAC and Northern Colorado Homebuilders
Association
The Options
21
• The Options:
1. Adopt Code Changes and Manual, delay enforcement
2. Adopt Code Changes and Manual, begin enforcement immediately
3. Adopt Code Changes only, use Manual as guidance if problems occur
4. Status Quo
• Similarities of the First Three Options
– All three options create an enforceable Ordinance
– All three options apply to all scales of activities
– All three options require covered loads
Options 1 and 2
22
• Option 1: Adopt Code Changes and Manual
with delayed implementation
– Responds to citizen concerns
– Provides proactive and prescriptive approach to
compliance
– Precedent setting
• Option 2: Adopt Code Changes and Manual,
begin enforcement immediately
– Same as Option 1
– Only difference is enforcement timeline
Option 3
23
• Option 3: Adopt Code Changes, use Manual as
guidance if problems occur
– Creates enforceable Ordinance for all activities
– Less proactive and prescriptive approach to
compliance
• Impacts on residents could be greater
• Does not require up-front budgeting for dust control
– Rewards positive and proactive behavior in the field
without adding prescriptive requirements
Option 3
24
• Precedents – this is a more typical approach by
Colorado Communities
• Denver
– “All persons shall take reasonable
measures…”
– Department can require plan upfront
– Issues – generally addressed after visiting
sites
Option 3
25
• Jefferson County
– References state code, and then requires
reasonable controls for all activities
– If complaints received, may require a plan
• Boulder
– …No person shall fail to use appropriate
measures, such as watering and best
management environmental practices, to
control dust and erosion…
Scenario: Commercial bldg on 1 acre site
26
• Status Quo
– No specific requirements to control dust
– Only the nuisance section of the Code applies
– If fugitive dust occurs, then staff either
• Approaches the general contractor with a request to address
the issue, or
• Contacts Larimer County to help address the situation
– Each site is addressed on a case-by-case basis
Scenario: Commercial bldg on 1 acre site
27
• Options 1 & 2: Adopt Code Changes & Manual
– Project plans for and adheres to Manual’s required
BMPs upfront:
• Construction and Demolition, e.g., winds restriction
• Stockpile, e.g., minimize drop height
• Track-out/carry-out, e.g., remove deposition
– If fugitive dust occurs, additional BMPs apply:
• Cutting and grinding, e.g., on-tool wet suppression
– If operator does not comply with the Manual, a
violation is issued
Scenario: Commercial bldg on 1 acre site
28
• Options 3: Adopt Code Changes, use Manual
as guidance if problems occur
– Project is required to take reasonable
measures to prevent dust from being
transported off-property
– If problems occur, required to develop a plan
(the Manual can be used as guidance)
– If problems cannot be resolved, then a
violation is issued
One-page Comparison of Options
Options Benefits Challenges Violations/ Remedies
Status Quo
• Cannot enforce on this issue
• Inefficient use of staff resources
Only state can enforce
Option 1:
Adopt Code and
Manual, delay
enforcement
• Enforceable Ordinance
• Proactive
• Upfront cost planning
• Delay allows for training and
education
• Does not address 2016
construction
• Prescriptive
• Adds project costs upfront
Violation: if not complying with Manual
Remedy: (1) apply at least one additional
(BMP). (2) If still not in compliance with the
above, issue citation
Option 2:
Adopt Code and
Manual, enforce
immediately
• Enforceable Ordinance
• Proactive
• Upfront cost planning
• Immediate implementation
• Prescriptive
• Adds project costs upfront
• Lacks time to budget for upfront
costs
• Lacks time for training and
outreach
Same as above – only difference is when
enforcement begins
Option 3:
Adopt Code, use
Manual as guidance
• Enforceable Ordinance
• Rewards operators who already
address dust
• Reactive
• More fugitive dust generated
• Does not allow for upfront
budgeting
Violation: if dust leaves the property
Remedy: (1) develop a plan to control dust;
(2) if operator does not take reasonable
measures, issue citation
29
Feedback to Date
30
• Air Quality Advisory Board – Recommend Option 1
– Proactive approach to this issue
– Most cost-certain option
• Fugitive Dust Working Group – Most Support for Option 3
– Option 3 addresses public concerns and acknowledges that many
operators already address dust; focuses efforts on problems
• No one has recommended Option 2
Next Steps
31
• Planned Public Outreach Before First Reading
– AQAB – February 22
– Fugitive Dust Working Group – February 24
– Additional Boards and Commissions (as needed)
• City Council First Reading – April 5, 2016
Questions for City Council
32
• What feedback does Council have regarding the proposed options:
1. Adopt Code Changes and Manual, delay enforcement
2. Adopt Code Changes and Manual, begin enforcement immediately
3. Adopt Code Changes only, Manual only applies if problems occur
4. Status Quo
• Does Council suggest any additional outreach before First
Reading?
February 9, 2016
Fugitive Dust
Jackie Kozak Thiel, Lucinda Smith, Lindsay Ex
estimated at $5,000. Should have
minimal impacts on routine
operations, unless the area being
stabilized is crucial to the project in
some way
cost to this scale of project.
Operations: None/Negligible effects
on operations (<$500 roughly
$100/AC to mow which is typically
needed 3-4 times/year), except for
perhaps taking care to not
harm/destroy the vegetation. Costs
may be incurred to reseed areas
that did not take on the prior
seeding.
additional cost
$-$$
Minor O&M and
initial costs
$$ - $$$
No initial costs
($) but high O&M
($,$$$-$$,$$$)
High Initial Costs
($,$$$-$$,$$$)but
no O&M ($)
High O&M ($,$$$-
$$,$$$) and High Initial
Costs ($,$$$-$$,$$$)
negative,
impact
likely
Very
negative,
impact
expected
• Proposal supports the policy to continually improve air quality
• Proposal supports the policy to strive to protect human health
• Proposal supports water quality and stormwater management
requirements
• Proposal does not support water conservation policy
• Fast-growing cover crops used for re-seeding may be very water
intensive.
provide training and support in preparation for implementation.
• Staff will develop a Public Engagement Plan to provide clear messaging
about the ordinance and that compliance will not always result in zero dust
being transported off site.
• If the ordinance passes, staff will actively engage with the public and
conduct outreach to reach a range of demographics.
fugitive dust.
including, but not limited to, a contractor,
lessee, or other responsible party of an activity,
operation, or land use that is a dust generating
activity or source.
Particulate matter shall mean any material
that is emitted into the air as finely divided solid
or liquid particles, other than uncombined
water, and includes dust, smoke, soot, fumes,
aerosols and mists.
Required best management practices shall
mean specific measures that are required to be
implemented if adust generating activity is
occurring.
Sensitive area shall mean a specific area that
warrants special protection from adverse
impacts due to the deposition of fugitive dust,
such as natural areas (excluding buffer zones),
sources of water supply, wetlands, critical
wildlife habitat, or wild and scenic river
corridors.
Soil retention shall mean the stabilization of
disturbed surface areas that will remain
that creates emissions of fugitive dust or causes
off-property or off-vehicle transport. Dust
generating activity or source shall include a
paved parking lot containing an area of more
than one half (1/2) acre.
Earthmoving shall mean any process that
involves land clearing, disturbing soil surfaces,
or moving, loading, or handling of earth, dirt,
soil, sand, aggregate, or similar materials.
Fugitive dust shall mean solid particulate
matter emitted into the air by mechanical
equipment necessary to meet
the standards of the manual
- Would require training and
outreach to occur
simultaneously with
enforcement
- Same as above, this is the
same as option 1 with the only
difference being when
implementation begins
3. Adopt Code Changes that
prevents off-property transport
of dust, and then if problems
occur, use Manual as guidance
to develop plan
Note: staff would propose that all
loads still be required to be
covered, as outlined in the Manual,
even with this option
- Creates enforceable regulations
- As many dust generating
activities are already addressing
dust, this approach rewards
proactive and positive behavior
without adding additional
requirements
- Reactive approach
- Will be more fugitive dust
- If fugitive dust is generated,
companies will have to
address it reactively and won’t
be able to budget upfront for
controlling dust
Violation: if dust leaves the
property
Remedy: (1) develop a plan to
control dust using the Manual as
guidance; (2) if operator does not
take reasonable measures, issue
citation