HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 03/05/2019 - ITEMS RELATING TO OUTDOOR RESIDENTIAL WOOD BURNINGAgenda Item 16
Item # 16 Page 1
AGENDA ITEM SUMMARY March 5, 2019
City Council
STAFF
Cassie Archuleta, Senior Environmental Planner
Jody Hurst, Legal
SUBJECT
Items Relating to Outdoor Residential Wood Burning.
EXECUTIVE SUMMARY
A. First Reading of Ordinance No. 042, 2019, Amending Chapter 20 of the Code of the City of Fort Collins
Pertaining to Nuisances.
B. First Reading of Ordinance No. 043, 2019, Appropriating Prior Year Reserves in the General Fund to
Increase Staffing for Outdoor Residential Wood Burning Program Support.
The purpose of this item is to modify the current air pollution nuisance Code provision to make it more
enforceable for smoke impacts from outdoor residential wood fires. Changes proposed include
decriminalization, a midnight curfew and a property line setback for outdoor wood burning. Additionally,
resources in the form of an 0.25 FTE increase, are being requested to support education, outreach and
compliance with the code.
STAFF RECOMMENDATION
Staff recommends adoption of the Ordinances on First Reading.
BACKGROUND / DISCUSSION
Over the years, concerns have sometimes been reported to the City or Poudre Fire Authority related to the
health and/or nuisance impacts from wood fires in residential neighborhoods. In May 2017, Council identified
backyard fire pits as a priority issue, prompting efforts to explore policy options to mitigate potential smoke
impacts on air quality and public health as well as improve neighborhood livability.
Wood smoke is considered an air pollutant as it is made up of gases and particles, which can cause health
concerns. For a healthy adult, concerns for short term exposure to high particle pollution levels can include
effects such as eye irritation, sore throat, wheezing and coughing. For more sensitive individuals, including
children, the elderly, and those with existing heart or lung conditions, concerns can be more serious, including
trouble breathing and/or exacerbation of existing conditions such as asthma and Chronic Obstructive
Pulmonary Disease (COPD).
Activities to date and previous Council guidance have included:
• May 2017
o Identified as a Council priority
• October 2017
o Council adopted a 2018 budget revision offer to support work on this topic
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• February 2018 Work Session
o Staff presented, and Council supported, a research and public engagement plan (Attachment
1)
• May - September 2018
o Staff proceeded with policy research and public engagement
• October 2018
o Staff presented policy options and Council provided direction to propose a policy option that
only prohibited residential wood fires with negative impacts (rather than a full ban)
• January 2019
o Staff presented a policy option that would prohibit residential wood fires unless permitted,
where permit conditions required that smoke could not have negative impacts on neighbors
o Council requested staff to instead pursue updates to existing air pollution nuisance
prohibitions to better enable enforcement for residential wood smoke concerns
Air Pollution Nuisance Code
In 1987, the City adopted an air pollution nuisance Code provision that prohibited public nuisances from
pollutants such as smoke, odors, etc. (Municipal Code, Sec. 20-1, air pollution nuisances prohibited). Some
practical limitations in enforcing this Code provision are:
• Residential wood fires are otherwise legal, and there has not been a clear implementation and
enforcement plan to address wood smoke impacts from these types of fires as a public nuisance
• Enforcement of the Code would require collection of evidence demonstrating impacts to the public, as
required for proof of a public nuisance
• A violation would be considered a criminal offense, which would mean a high burden of proof, and a
criminal record for any violations of this Code
At the January 22, 2019 Work Session, Council requested that staff explore modifying the current air pollution
nuisance Code provision to make it more enforceable for smoke concerns from outdoor wood burning fires in
residential areas. Modifications proposed for consideration include:
• Decriminalizing violations
o This will make the offense civil rather than criminal, which staff considers more appropriate for
this type of violation and will reduce the burden of proof required to demonstrate a violation.
• Prohibiting outdoor wood fires between midnight and 7:00 am
o Council had expressed interest in establishing a curfew, and midnight was suggested
• Establishing a setback distance of 15 ft from a property line
o International Fire Code already prohibits fires within 15 feet of a structure or combustible
material (including a wooden fence) for fire safety reasons
o This will add a similar setback for property lines, which will be enforceable by City Code
Compliance Officers
Additional Environmental Outreach and Compliance Support
The ability to enforce air pollution nuisance Code requirements for residential wood smoke concerns will, in
part, be dependent on resources available to provide education and outreach, investigate complaints, and
otherwise substantiate public nuisance violations. In support of this, staff is proposing additional resources (10
hours per week of staff time, or 0.25 FTE) to focus on:
• Increased promotion of awareness of health impacts of wood smoke
• Increased awareness of, and access to, resources to file complaints
• Establishing a robust air quality complaint intake system, to assist environmental compliance staff in
gathering evidence regarding complaints
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• Case-by-case investigative efforts, including information collection in the field, that could support issuance
of a citation for a public nuisance violation
These additional resources will be leveraged by converting an existing 0.75 FTE Environmental Services
Department, Air Quality support position to a full time (1.0 FTE) position. The increased capacity will be in line
with the existing job functions for this position, which include:
• Environmental compliance support for the implementation and support of Fugitive Dust regulations
• Administration of a Memorandum of Understanding (MOU) with Martin-Marietta Materials
• Support for development and administration of air quality outreach and incentive programs (such as
electric lawn and garden equipment rebates)
Additionally, the increased education and outreach support regarding wood smoke will be leveraged as an
opportunity to provide improved public health messaging about the impacts of wildland fire smoke, which is of
increasing concern for climate adaptation efforts.
Incentives
During Work Session discussions, Council expressed interest in exploring implementation of a new incentive
program to discourage wood burning and encourage lower smoke alternatives such as gas-fueled fires pits.
Staff proposes developing an incentive program to be considered as a 2020 budget revision offer.
Considerations include:
• The 2019-2020 budget did not include a $30K/year budget that has previously been used to support indoor
air quality incentives, including a zero-interest loan option for replacing indoor wood fireplaces with gas or
electric alternatives. Staff proposes that a new incentive program would focus on both indoor and outdoor
wood burning.
• Some have expressed concern about the City promoting use of gas-fueled appliances, as the City adopted
a carbon neutral climate goal. Staff will explore options that focus on reducing wood burning without
necessarily promoting gas burning (e.g., rebates to recycle or remove a wood burning appliance).
Program Evaluation
Following the first year of implementation, staff proposes to evaluate effectiveness and limitations of the new
program. Evaluation would include a summary of:
• Number of residential wood smoke complaints
• Specific concerns (e.g., health, nuisance, safety)
• Any incident related health outcomes (e.g., exacerbation of pre-existing conditions, increased medication
use, emergency department visits)
• Distance to property lines (for evaluation of potential changes in setback distances)
• Complaints at Short Term Rentals (STRs) (for evaluation of potential limitations at STRs)
• Ability to address complaints with voluntary compliance
• Any code violations and enforcement action taken
Next Steps
If Code changes and resources are adopted, staff proposes beginning implementation in time for the 2019
outdoor fire season (approximately June-September). Staff will also:
• Provide quarterly updates to Council
• Submit a proposal for an incentive program to be considered as a 2020 Budget Revision Offer
• Evaluate the program after the first season of implementation and return to Council in 2020 with an
evaluation of effectiveness and recommendations
Agenda Item 16
Item # 16 Page 4
CITY FINANCIAL IMPACTS
Adoption of requested resources would require $18,638 per year in ongoing cost for Personnel and Benefit
expenses for the 0.25 FTE position increase. The pro-rated amount for 2019 to be appropriated from General
Fund Reserves is $13,409 to cover the expenses for April through December.
BOARD / COMMISSION RECOMMENDATION
The Natural Resources Advisory Board (NRAB) discussed this item on February 20, 2019, and the Air Quality
Advisory Board (AQAB) discussed this item on February 25, 2019. Recommendation statements provided by
the Boards are listed below.
• The NRAB supports the modifications to the Air Pollution Nuisance Code including decriminalization, the 15
ft setback (or greater), but recommends an earlier curfew (e.g., consistent with the noise ordinance) during
the summer to accommodate use of whole house fans. The NRAB also recommends consideration of
shorter setbacks for lower smoke solid-fuel appliance options, such as smokeless fire pits. A ban on high
pollution advisory days is also strongly recommended, especially during wildfire smoke events. The
additional resources for education, outreach and enforcement are also supported.
• The AQAB recommends Council adopt the proposed Air Pollution Nuisance Code changes, contingent on
the adoption of resources to collect more data, as these changes may not be adequate to address the
issue. Additional resources supported should include monitored particulate levels, assessment of impacts
(health and nuisance), and number of people affected, with a goal of considering a stronger approach after
a year review. Bans on high pollution advisory days are also recommended. One dissenting opinion was
that just the decriminalization of the code adequately addresses the issue.
PUBLIC OUTREACH
Feedback from stakeholders and the broader community regarding impacts and perceptions related to
neighborhood sources of wood smoke was gathered through the following outreach activities:
• Presentations to Air Quality Advisory Board, Natural Resources Advisory Board and SuperBoard meetings
• A scientifically valid survey, which included invitations to 3,000 households. 522 responses were received
• Discussion at the Spring Community Issues Forum, facilitated by CSU’s Center for Public Deliberation,
attended by 55 community members
• Promotion of OurCity public engagement platform through Social media, Coloradoan interviews and the
Nextdoor website
• Emails directly to staff and Council
• Individual phone calls and emails to discuss questions and concerns as necessary.
In addition to broad community outreach, feedback from stakeholders was gathered through the following
outreach activities:
• Quarterly working group meetings, including staff from the Environmental Services Department,
Community Development and Neighborhood Services and Poudre Fire Authority
• Collaboration with CSU’s Political Science Department
• Interview with UCHealth pulmonologist, Dr. Eric Stevens
• Correspondence with the Health District of Larimer County
• Correspondence with Larimer County Public Health and Environment staff
ATTACHMENTS
1. Public Engagement Plan (PDF)
2. Work Session Summary Memos (PDF)
3. Powerpoint presentation (PDF)
PUBLIC ENGAGEMENT SUMMARY
2/1/2018
PROJECT TITLE: OUTDOOR RESIDENTIAL WOOD BURNING
OVERALL PUBLIC INVOLVEMENT LEVEL: Collaborate with key stakeholders to develop new program or
policy recommendations based on community feedback.
BOTTOM LINE QUESTION: What program or policy options does the community support to reduce air
quality concerns and nuisance complaints related outdoor residential wood burning?
KEY STAKEHOLDERS:
Residents who actively participate in residential wood burning activities
Residents living in close proximity to frequent or infrequent residential wood burning activity
Residents sensitive to air quality impacts (e.g., children, the elderly and people with respiratory issues)
Poudre Fire Authority (currently respond to safety concerns related to indoor and outdoor fires)
CDNS staff (currently provide neighborhood outreach regarding residential wood burning concerns)
Environmental Services staff (currently support air quality improvement initiatives)
Larimer County Health Department
Home builders (who install built‐in outdoor wood burning fireplaces)
Businesses that sell outdoor wood burning appliances and/or firewood
General public
WORKING GROUP:
Lucinda Smith, Environmental Services, Director
Cassie Archuleta, Environmental Services, Air Quality Program Manager
Jenna Channel, Environmental Services, Associate Environmental Planner
Eric Keselburg, Neighborhood Services, Compliance Supervisor
Jonathan Nagel, Neighborhood Services, Environmental Compliance Inspector
Justin Moinester, Assistant Fire Marshal – Investigative Services
TIMELINE:
Phase 1: Data Collection and Research
Timeframe: January – May 2018
Key Messages: What is the extent and frequency of the problem, and what type of program and
policies options are available to address the problem?
Tools and Techniques:
Assemble information and data related to current policies and programs, and complaint history.
Collaboration with CSU Political Science Department to assemble a suite of policies, programs
and motivations from other communities.
Statistically valid survey to characterize behaviors and perceptions around wood burning.
ATTACHMENT 1
PHASE 2: Public Engagement and Policy Deliberations
Timeframe: April – August 2018
Key Messages: What program and policy options are supported by the impacted sensitive population,
and the broader community?
Tools and Techniques:
Working group meetings (quarterly)
Expert Panel (e.g., air quality, health, social science and policy experts); filmed for Cable 14
Community Issues Forum, in collaboration with CSU’s Center for Public Deliberation
Boards and Commissions meetings (Air Quality Advisory Board, Natural Resources Advisory
Board, Larimer County Environmental and Science Advisory Board, and SuperBoard meeting)
“Our City” online electronic forum
Meetings conducted by “Neighborhood Connections” neighborhood facilitators
Website updates (www.fcgov.com/airquality/wood-smoke.php)
Social media (e.g., Facebook, Twitter, Nextdoor)
Utility bill mailer (City News)
Press releases
PHASE 3: Develop Recommendations
Timeframe: August – December 2018
Key Messages: What policies and programs are recommended for Council consideration?
Tools and Techniques:
Working group meetings (quarterly)
Triple Bottom Line screening analysis
Boards and Commissions meetings (Air Quality Advisory Board, Natural Resources Advisory
Board)
Council work session
ATTACHMENT 2
1
Outdoor Residential Wood Burning
3-5-2019
ATTACHMENT 3
Staff Recommendations
• Modifications to Air Pollution Nuisance Code to
support implementation for outdoor residential
wood burning
• Additional environmental compliance resources to
support implementation and enforcement
2
STRATEGIC
ALIGNMENT
Neighborhood Livability
• 1.6 Quality of Life
Environmental Health
• 4.4 Air Quality
BUDGET
• ESD 2017-18 Ongoing
Offer
• 2018 revision: $20K
Why We Are Here
3
COUNCIL
PRIORITY
Air Quality
• Residential Wood
Fires
Project Goal
4
• Develop recommendations regarding options to better protect
human health and reduce nuisance from outdoor wood
smoke
Project Goal
Feb 2018
• Work Session
#1
• Public
Engagement
Plan
Mar – Sep 2018
• Public
Engagement
Oct 2018
• Work Session
#2
• Type of
regulatory
option
Jan 2019
• Work Session
#3
• Proposed
regulatory
mechanism
Mar 2019
• Regular
Meeting
• Consideration
of code
changes and
resources
Findings
• Smoke and particle pollution
• Nuisance and/or health
concerns
• Sensitive populations
• Smoke can travel
• Recreational amenity
5
Council Work Session
Council Work Session Feedback
• Modify current Air Pollution Nuisance Code to make it more
enforceable for smoke impacts from woodburning fires
Municipal Code Sec. 20-1: Air Pollution Nuisances
Prohibited
• Smoke, ashes, dust, etc.; which
• Endanger the health, comfort, safety or welfare of the public; or
• Interfere with the comfortable enjoyment of property
6
Proposed Updates
Air Pollution Nuisance Code Limitations
• Criminal offense
• Requires proof of public nuisance
Proposed Updates
• Decriminalize
• Add operational requirements
• Midnight curfew
• 15 foot property line setback
7
• Focus on egregious
offenders
• Limit first responder
resources
Implementation and
Enforcement Goals
Staff Resources
8
Environmental Compliance
Education and Outreach
• Information about potential health
concerns
• Resources for neighborhood
conversations
• How to file a complaint
• Lower smoke burning strategies
Implementation and Enforcement
• Complaint logs
• Warning letters
• Site investigations
• Citations
• Additional 0.25 FTE
•Supplement and
leverage existing 0.75
FTE
•$18K/year (ongoing)
Air Quality
Compliance Support
Smoke
Concern
•Access
resources
•Talk to
neighbor?
•Reach a
compromise?
First Complaint
•Outreach letter
•Recommendations
Additional
Complaints
•Notice of
Violation
•Incident
investigation
•Citation
Complaint and Response Process
9
• Location known?
• Timely response
• Sufficient evidence
Challenges
Program Evaluation and Next Steps
10
2019 - Collect Data
• Number of
Complaints
• Nature of Complaint
• Short Term Rentals?
• Property line distance
• Voluntary compliance
• Warnings, citations
2020 – Evaluation and
Recommendations
• Limitations for Short
Term Rentals
• Increase property line
distance
• High pollution
advisory days
• Permit program?
Incentives
11
Outdoor and indoor wood
burning
• Remove/recycle wood
burning appliance
• Incentivize alternative?
Timing
• Consider for 2020
Budget Revision Offer
2019 Timeline
12
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
COUNCIL ADOPTION
OUTREACH CAMPAIGN
DATA COLLECTION AND
EFORCEMENT
2020 BUDGET REVISION
OFFER (INCENTIVES)
PROGRAM EVALUATION
Also will include: Quarterly memo updates to Council
Board Feedback
13
AQAB NRAB
Code Changes Support Support
Additional
Resources Support Support
Other
considerations
• Air Quality Advisory
Day Ban
• Particulate
monitoring
• Air Quality Advisory
Day Ban
• Greater setback
• Earlier curfew
Staff Recommendations
• Modifications to Air Pollution Nuisance Code to
support implementation for outdoor residential
wood burning
• Additional environmental compliance resources to
support implementation and enforcement
14
-1-
ORDINANCE NO. 042, 2019
OF THE COUNCIL OF THE CITY OF FORT COLLINS
AMENDING CHAPTER 20 OF THE CODE OF THE CITY OF
FORT COLLINS PERTAINING TO NUISANCES
WHEREAS, on December 1, 1987, the City Council adopted Ordinance No. 180,
1987, amending the City Code to include as a public nuisance certain types of air pollutants;
and
WHEREAS, since the adoption of those Code provisions, as scientific knowledge has
grown and citizen concerns have changed, subsequent City Councils have amended the Code
to regulate different types of public nuisances with regard to air pollution; and
WHEREAS, in recent years, concerns have been reported to City Staff regarding
nuisance impacts from wood fires in residential neighborhoods; and
WHEREAS, in May 2017, Council identified backyard fire pits as a priority issue,
prompting efforts to explore policy options to help mitigate potential smoke impacts on air
quality and public health, as well as improve neighborhood livability; and
WHEREAS, wood smoke is considered an air pollutant because it is made up of gases
and particles, both of which can cause health concerns; and
WHEREAS, on December 19, 2006, City Council adopted Ordinance No. 198, 2006,
which decriminalized certain provisions of the Code, including several provisions of Chapter
20, related to public nuisances, and designated many offenses against property as civil
infractions; and
WHEREAS, on further review of Chapter 20, City staff believes violations of the air
pollution nuisance Code should be civil rather than criminal in nature; and
WHEREAS, City staff believes adding requirements to the air pollution nuisance
provision of the Code would help mitigate nuisance effects of wood burning in
neighborhoods; and
WHEREAS, the Council finds and determines that the adoption of this Ordinance is in
the best interest of the City and necessary for the public’s health, safety and welfare.
NOW, THEREFORE, BE IT ORDAINED BY THE COUNCIL OF THE CITY OF
FORT COLLINS as follows:
Section 1. That the City Council hereby makes and adopts the determinations and
findings contained in the recitals set forth above.
Section 2. That Section 20-1 of the Code of the City of Fort Collins is hereby
amended as follows:
-2-
Sec. 20-1. Air pollution nuisances prohibited.
…
(e) No person shall cause or allow the burning of solid fuel outdoors between the hours
of 12:00 a.m. and 7:00 a.m.
(f) No person shall cause or allow the burning of solid fuel less than fifteen feet from any
abutting property line.
(g) The provisions of 20-1(e) and 20-1(f) shall not apply to any of the following:
(1) Solid fuel-burning appliances specifically designed and used exclusively for
outdoor noncommercial cooking of food for human consumption, such as
barbecue grills and smokers; or
(2) Fires, where written approval has been granted by the Fire Code Official.
(h) Any person who violates any provision of Subsection 20-1 commits a civil infraction
and is subject to the penalty provisions of Subsection 1-15(f).
Introduced, considered favorably on first reading, and ordered published this 5th day of
March, A.D. 2019, and to be presented for final passage on the 19th day of March, A.D. 2019.
__________________________________
Mayor
ATTEST:
_______________________________
City Clerk
Passed and adopted on final reading on the 19th day of March, A.D. 2019.
__________________________________
Mayor
ATTEST:
_______________________________
City Clerk
-1-
ORDINANCE NO. 043, 2019
OF THE COUNCIL OF THE CITY OF FORT COLLINS
APPROPRIATING PRIOR YEAR RESERVES IN THE
GENERAL FUND TO INCREASE STAFFING FOR OUTDOOR
RESIDENTIAL WOOD BURNING PROGRAM SUPPORT
WHEREAS, on December 1, 1987, the City Council adopted Ordinance No. 180,
1987, amending the City Code to include as a public nuisance certain types of air pollutants; and
WHEREAS, since the adoption of those Code provisions, as scientific knowledge has
grown and citizen concerns have changed, subsequent City Councils have amended the Code
to regulate different types of public nuisances with regard to air pollution; and
WHEREAS, in recent years, concerns have been reported to City Staff regarding nuisance
impacts from wood fires in residential neighborhoods; and
WHEREAS, in May 2017, Council identified backyard fire pits as a priority issue,
prompting efforts to explore policy options to help mitigate potential smoke impacts on air
quality and public health, as well as improve neighborhood livability; and
WHEREAS, wood smoke is considered an air pollutant because it is made up of gases
and particles, both of which can cause health concerns; and
WHEREAS, on December 19, 2006, City Council adopted Ordinance No. 198, 2006,
which decriminalized certain provisions of the Code, including several provisions of Chapter 20,
related to public nuisances, and designated many offenses against property as civil infractions;
and
WHEREAS, on further review of Chapter 20, City staff believes violations of the air
pollution nuisance Code should be civil rather than criminal in nature; and
WHEREAS, City staff believes adding requirements to the air pollution nuisance
provision of the Code would help mitigate nuisance effects of wood burning in neighborhoods;
and
WHEREAS, enforcing these Code provisions will take additional staff time, as most of
the wood burning does not happen during the general business hours of the City; and
WHEREAS, this appropriation benefits the public health, safety and welfare of the
citizens of Fort Collins and serves the public purpose of mitigating air pollutant impacts to the
citizens of Fort Collins; and
WHEREAS, Article V, Section 9 of the City Charter permits the City Council to
appropriate by ordinance at any time during the fiscal year such funds for expenditure as may be
available from reserves accumulated in prior years, notwithstanding that such reserves were not
previously appropriated; and
-2-
WHEREAS, the City Manager has recommended the appropriation described herein and
determined that this appropriation is available and previously unappropriated from the General
Fund and will not cause the total amount appropriated in the General Fund to exceed the current
estimate of actual and anticipated revenues to be received in that fund during any fiscal year.
NOW, THEREFORE, BE IT ORDAINED BY THE COUNCIL OF THE CITY OF
FORT COLLINS as follows:
Section 1. That the City Council hereby makes and adopts the determinations and
findings contained in the recitals set forth above.
Section 2. That there is hereby appropriated from prior year reserves in the General
Fund the sum of THIRTEEN THOUSAND FOUR HUNDRED NINE DOLLARS ($13,409) for
expenditure in the General Fund for the Outdoor Residential Wood Burning Program.
Introduced, considered favorably on first reading, and ordered published this 5th day of
March, A.D. 2019, and to be presented for final passage on the 19th day of March, A.D. 2019.
__________________________________
Mayor
ATTEST:
_______________________________
City Clerk
Passed and adopted on final reading on the 19th day of March, A.D. 2019.
__________________________________
Mayor
ATTEST:
_______________________________
City Clerk