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I <br /> I <br /> I <br /> I <br /> I <br /> I <br /> I <br /> I <br /> I <br /> I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br /> <br />FROM: <br /> <br />DATE: <br /> <br />SUBJECT: <br /> <br />MEMORANDUM <br /> <br />BILL GOODRICH, CITY ATTORNEY <br /> <br />MARK BANWART, COMMUNFI'Y DEVELOPMENT DIRECTOR <br />BRU~E HOEKE, FIRE CHIEF <br /> <br />~RU.CE BACON, ENVIRONMENTAL SPECIALIST <br />ISEPTEMBER 19, 1989 <br /> <br />PROPOSED WINTER DISPOSAL BY OPEN BURNING OF BUI 1 ~OZED WINDROWS AT <br />i'F&~ SITE, WEST HIGHWAY 10 <br />iPIN; 29-32-25-21 -0001 <br /> <br />Dear Mr. Goodrich, <br /> <br />A winter open burr1, with snow cover, in pits, addresses only the issue of fire safety. <br />address the rritligaiion of fire hazard at that site: (i.e... <br /> <br />It does not <br /> <br /> 1. Scrl~ped or plowed fire break between the railroad right of way and the existing <br /> pile~, for fall, dry grass running fire hazard abatement. <br /> <br /> 2. , Mitigation of fire hazard in standing dead, standing live remaining plantation, <br /> 'through thinning, crown fire breaks, and removal of dead fuel. <br />PCA Rules: · <br /> <br />7005.0770A~ Furthermore, it does not address the concern of alternative abatement of the <br /> ' corlsiderable volume to be burned, for example, two kinds of equipment would <br /> seem lo permit substantial or complete disposal of the existing windrows of <br /> i material without burning: the SEPPI "wood muicher" or the ROYER "woodsman" <br /> : ar¢ fla~ hammer machines designed to reduce such windrowed material to small <br /> fractured pieces suitable for land spreading and biodegradation. <br />PCA Rules: <br />7005.07'70B: In ~addilion, 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 particulates ("smoke"), carbon monoxide and other by-products of pine wood <br /> ~ cot'nbuslion. 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 />Aisc, I woul¢ submit, because of the proximity to Ramsey Industrial Airport and the proposed <br />volume of wOOd te be disposed of, the smoke hazard makes it prudent that such permit process be <br />approved bylthe fCommissioner (PCA Rules: 7005.0750 (H)). <br /> <br />In short, the vel7 large volume of piled material makes this an extraordinary application. <br />Please notelthal', 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 />