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MEMORANDUM <br /> <br />TO. <br /> <br />FROM: <br /> <br />DATE: <br /> <br />SUBJECT: <br /> <br />BILL GOODRICH, CITY A'Fr'ORNEY <br /> <br />MARK BANWART, COMMUNITY DEVELOPMENT DIRECTOR <br />BRUCE HOEKE, RRE CHIEF <br /> <br />BRUCE BACON, ENVIRONMENTAL SPECIAUST <br /> <br />SEPTEMBER 19, 1989 <br /> <br />PROPOSED WINTER DISPOSAL BY OPEN BURNING OF BU! 1 DOZED WINDROWS AT <br />F&R SITE, WEST HIGHWAY 10 <br />PIN: 29-32-25-21 -0001 <br /> <br />Dear Mr. Goodrich, <br /> <br />A winter open burn, with snow cover, in pits, addresses only the issue of fire safety, it does POt <br />address the mitigation of fire hazard at that site: (i.e... <br /> <br />Scraped or plowed fire break between the railroad right of way and the existing <br />piles for fall, dry grass running fire hazard abatement. <br /> <br />PCA Rules: <br />7005.0770A: <br /> <br />PCA Rules: <br />7005.0770B: <br /> <br />Mitigation of fire hazard in standing dead, standing live remaining plantation, <br />through thinning, crown fire breaks, and removal of dead fuel. <br /> <br />Furthermore, it does POt address the concern of alternative abatement of the <br />considerable volume to be burned, for example, two kinds of equipment would <br />seem to permit substantial or complete disposal of the existing windrows of <br />material without burning: the SEPP1 "wood mulcher" or the ROYER "woodsman" <br />are flail hammer machines designed to reduce such windrowed material to small <br />fractured pieces suitable for land spreading and biodegradation. <br /> <br />In addition, the application for open burning does NOT address the air quality <br />impact of open burning which would emit a substantial and unknown volume of <br />ash padiculates ("smoke"), carbon monoxide and other by-products of pine wood <br />combustion. The large and estimated volume of wood to be burned will impact <br />local air quality contributing to residential elevated health risk, so that a <br />nuisance and potential liability would be created. <br /> <br />Also, I would submit, because of the proximity to Ramsey industrial Airport and the proposed <br />volume of wood to be disposed of, the smoke hazard makes it prudent that such permit process be <br />approved by the Commissioner (PCA Rules: 7005.0750 (H)). <br /> <br />In short, the very large volume of piled material makes this an extraordinary application. <br />Please note that fire hazard abatement at this site would generate additional material to that <br />already piled. Standing dead and live material removed for fire breaks and fuel reduction could <br /> <br /> <br />