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03.07.18 EAB PacketCITY OF BOULDER ENVIRONMENTAL ADVISORY BOARD MEETING AGENDA DATE: March 7, 2018 TIME: 6 pm PLACE: 1777 West Conference Room, 1777 Broadway 1. CALL TO ORDER 2. APPROVAL OF MINUTES A. The February 7, 2018 Environmental Advisory Board meeting minutes are scheduled for approval. 3. PUBLIC PARTICIPATION 4. PUBLIC HEARING ITEMS 5. DISCUSSION ITEMS A. Updates to the Integrated Pest Management Policy and Associated Programs (Rella Abernathy) B. Urban Forest Management Strategy (Kathleen Alexander) 6. OLD BUSINESS/UPDATES A. CU Environmental Board Attendance (Karen Crofton) 7. MATTERS FROM THE ENVIRONMENTAL ADVISORY BOARD, CITY MANAGER AND CITY ATTORNEY A. Preparing for the Joint Council/EAB Study Session (Board) B. Goodbye and Thank You to Brad Queen 8. DEBRIEF MEETING/CALENDAR CHECK A. The annual retreat is scheduled for Wednesday, April 4, 5-8 pm. 9. ADJOURNMENT For more information call (303) 441-1931. Board packets are available after 12 pm the Thursday prior to the meeting, online at www.bouldercolorado.gov. 1 CITY OF BOULDER ENVIRONMENTAL ADVISORY BOARD MEETING GUIDELINES CALL TO ORDER The board must have a quorum (three members present) before the meeting can be called to order. AGENDA The board may rearrange the order of the agenda or delete items for good cause. The board may not add items requiring public notice. PUBLIC PARTICIPATION The public is welcome to address the board (three minutes* maximum per speaker) during the Public Participation portion of the meeting regarding any item not scheduled for a public hearing. The only items scheduled for a public hearing are those listed under the category PUBLIC HEARING ITEMS on the agenda. Any exhibits introduced into the record at this time must be provided in quantities of eight to the Board Secretary for distribution to the board and admission into the record. DISCUSSION AND STUDY SESSION ITEMS Discussion and study session items do not require motions of approval or recommendation. PUBLIC HEARING ITEMS A Public Hearing item requires a motion and a vote. The general format for hearing of an action item is as follows: 1. Presentations • Staff presentation (15 minutes maximum*) Any exhibits introduced into the record at this time must be provided in quantities of eight to the Board Secretary for distribution to the board and admission into the record. • Environmental Advisory Board questioning of staff for information only. 2. Public Hearing Each speaker will be allowed an oral presentation (three minutes maximum*). All speakers wishing to pool their time must be present, and time allotted will be determined by the Chair. Two minutes will be added to the pooled speaker for each such speaker’s allotted time up to a maximum of 10 minutes total. • Time remaining is presented by a green blinking light that means one minute remains, a yellow light means 30 seconds remain, and a red light and beep means time has expired. • Speakers should introduce themselves, giving name and address. If officially representing a group please state that for the record as well. • Speakers are requested not to repeat items addressed by previous speakers other than to express points of agreement or disagreement. Refrain from reading long documents, and summarize comments wherever possible. Long documents may be submitted and will become a part of the official record. • Any exhibits introduced into the record at the hearing must be provided in quantities of eight to the Board Secretary for distribution to the board and admission into the record. • Interested persons can send a letter to the Community Planning and Sustainability staff at 1739 Broadway, Boulder, CO 80302, two weeks before the Environmental Advisory Board meeting, to be included in the board packet. Correspondence received after this time will be distributed at the board meeting. 3. Board Action Board motion. Motions may take any number of forms. Motions are generally used to approve (with or without conditions), deny, or continue agenda item to a later date (generally in order to obtain additional information). • Board discussion. This is undertaken entirely by members of the board. Members of the public or city staff participate only if called upon by the Chair. • Board action (the vote). An affirmative vote of at least three members of the board is required to pass a motion approving any action. MATTERS FROM THE ENVIRONMENTAL ADVISORYBOARD, CITY MANAGER, AND CITY ATTORNEY Any Environmental Advisory Board member, City Manager, or the City Attorney may introduce before the board matters which are not included in the formal agenda. ADJOURNMENT The board's goal is that regular meetings adjourn by 8 p.m. Agenda items will not be commenced after 8 p.m. except by majority vote of board members present. *The Chair may lengthen or shorten the time allotted as appropriate. If the allotted time is exceeded, the Chair may request that the speaker conclude his or her comments. 2 CITY OF BOULDER, COLORADO BOARDS AND COMMISSIONS MEETING SUMMARY NAME OF BOARD/COMMISSION: Environmental Advisory Board DATE OF MEETING: February 7, 2018 NAME/TELEPHONE OF PERSON PREPARING SUMMARY: Sandy Briggs, 303-441-1931. NAMES OF MEMBERS, STAFF AND INVITED GUESTS PRESENT: Environmental Advisory Board Members Present: Brad Queen, Karen Crofton, Christina Gosnell and Jason Vogel. Community Member Present: Chris Crandell Staff Members Present: Yael Gichon, Kimberlee Rankin, Brett KenCairn and Sandy Briggs. MEETING SUMMARY:  RECs The board made the following comments and suggestions: • There are two separate issues on the table – compliance with GHG reporting requirements relating to Boulder-specific accuracy and tracking reduction progress against city goals. • “Reverse engineer” the requirements from the goals. • “Undilute” and “re-concentrate” Xcel’s data to create Boulder-specific numbers. • Selling RECs is currently necessary for the financial viability of some projects. Can this be changed? • The concept of additionality could create loopholes. • Stimulate individual action by educating the public about adding value to the community and reaching its goals. Show that individual actions matter. • Don’t equate RECs with environmental good as they are only an accounting system. • Current protocols aren’t accounting for what’s being done locally. • Illuminate the issue by sharing the math involved with including renewables. • Provide options for contributing towards community goals. • Allow businesses and individuals to voluntarily buy in to the Energy Impact Offset Fund. • A separate, Boulder-specific inventory is not necessary until there is a more measurable difference. • Maximize the number and scope of projects anywhere. 1. CALL TO ORDER Environmental Advisory Board Chair, B. Queen, declared a quorum and called the meeting to order at 6:00 pm. 2. APPROVAL OF MINUTES On a motion by K. Crofton, seconded by J. Vogel, the Environmental Advisory Board voted 3-0 (C. Gosnell abstained) to approve the January 3, 2018 meeting minutes. 3 3. PUBLIC PARTICIPATION None. 4. PUBLIC HEARING ITEMS None. 5. DISCUSSION ITEMS A. RECs (Gichon and Rankin) Energy Strategist, Y. Gichon, and Sustainability Coordinator, K. Rankin, presented the board with information about greenhouse gas emissions protocols, renewable energy certificates and renewable energy in the City of Boulder. They asked for feedback and recommendations about the current system for reporting and calculating emissions, whether RECs are necessary in the overall accounting for city purposes and a proposed hierarchy of renewable energy in the city for code compliance and voluntary participation. They also asked for the board’s opinion about how RECs matter in reaching city goals via the current system of GHG inventory accounting. The board’s comments are captured in the Meeting Summary. 6. OLD BUSINESS/UPDATES None. 7. MATTERS FROM THE ENVIRONMENTAL ADVISORY BOARD, CITY MANAGER AND CITY ATTORNEY A. Preparing for the Joint Council/EAB Study Session (Board) B. KenCairn informed the board that the available dates for meeting with City Council are Tuesday, November 27 or Tuesday, January 8, 2019, and that staff is requesting two hours of the three-hour meeting. He suggested the board focus on process and structure of the meeting until the new members are seated in April, and proposed the following topics for the agenda: • Review of Current Status o 2017 GHG inventory o Target tables – progress, trends and gaps • Strategy Review o Energy o Ecosystems o Just transition o Preview of 2019 (Resources, with a focus on circular economy) B. CU Environmental Board Participation (Board) K. Crofton volunteered to attend a meeting to determine if it would be mutually beneficial for an EAB member to participate. If so, the board suggested they could rotate and attend semi-regularly. C. Greenways Board It was brought to the board’s attention that since the EAB’s Greenways Board representative resigned, a new representative is needed. J. Vogel volunteered to become the new representative. 4 D. Energy Future Public Engagement Working Group The board discussed the emergence of this new working group and whether an EAB member should apply to participate. It was decided participation was not directly necessary, but hearing from a member of the group upon conclusion of the scheduled meetings would be valuable. B. KenCairn will inform the Energy Future team of the EAB’s request and report back. 8. DEBRIEF MEETING/CALENDAR CHECK A. The next EAB meeting is scheduled for Wednesday, March 7, 6-8 pm. All members are expected to attend. B. The annual retreat is scheduled for Wednesday, April 4, 5-8 pm. All continuing members are expected to attend, with the possible exception of J. Vogel, who might have a conflict. He will inform S. Briggs as soon as possible one way or the other. 9. ADJOURNMENT The Environmental Advisory Board adjourned at 7:49 pm. Approved: ________________________________________________________________ Chair Date 5 TO: Environmental Advisory Board FROM: Kathleen Alexander, City Forester SUBJECT: Urban Forest Strategic Plan and Emerald Ash Borer Update DATE: March 7, 2018 EXECUTIVE SUMMARY The Parks and Recreation Department manages Boulder’s urban forest through the forestry workgroup and extensive coordination with the community to ensure the long-term sustainability of the urban canopy. While Boulder has one of the most successful forestry programs along the Front Range, many threats exist with Boulder’s trees which require careful management strategies and effective long-term planning including invasive pests such as the Emerald Ash Borer (EAB), climate change and individual severe weather events and development. Similarly, to be prepared and plan for future threats and resource impacts, staff is finalizing an Urban Forest Strategic Plan (UFSP) that will outline long-term goals and action plans to effectively and sustainably managing Boulder’s urban forest. The purpose of the memo and presentation are to provide a brief update on EAB and an overview of the UFSP process key findings and next steps. Emerald Ash Borer (EAB) Forestry staff collaborated with multiple state and federal agencies, leading EAB experts from across the U.S. and Canada and a city interdepartmental team to develop a long-term EAB Strategy. The long term EAB Strategy was presented to City Council and received unanimous support in September 2015. Since then, staff have been implementing the management actions included in that document to successfully respond to EAB including: A. EAB Multi Agency Response B. Quarantine C. Public Education / Outreach D. Tree Plantings E. Tree Removals F. Pesticide Applications G. Biocontrols H. Wood Utilization I. Enforcement J. Collaborative Research Projects Despite these efforts, the reality is that Boulder is now entering the phase of the infestation where many trees are dying, becoming unsightly and, more importantly, safety risks to our 6 community. Additionally, staff continue efforts to ensure the community is informed of the impact of EAB on Boulder’s trees and the reality of losing thousands of trees in the coming years on private and publicly-owned parcels. At the October 2017 City Council Study Session (see Attachment A), staff highlighted the following areas: Tree Removals Staff has detected heavily infested, symptomatic ash throughout Boulder. Observations indicate it takes approximately 3 years to progress from only a few dead ash trees in an area to the point where all ash trees were dead, dying or removed. Forestry staff has also observed that ash trees killed by EAB dry out, become brittle and start to fail within 1 year after mortality. This is consistent with observations across the Midwest. Allowing trees to reach the point of failure is unacceptable from the standpoint of public safety. Therefore, as untreated public ash trees start to decline in an area, all untreated ash along the street will be removed at the same time to reduce tree removal and traffic control costs and minimize community inconvenience. Public Outreach Education and outreach are critical components of response to an invasive tree pest. Since the initial detection in 2013, Boulder Forestry, in collaboration with the statewide multi-agency EAB Response Team, has utilized multiple methods to education the public on EAB including: • Websites • News Releases • EAB Workshops • Public Open Houses • HOA Meetings • Doorhangers to residents with symptomatic ash trees in highly infested neighborhoods • Hosting informational tables at Farmers Markets and McGuckin’s • Direct contact with property owners living adjacent to public street trees being treated by the city; • TreeOpp program • Tree Giveaways in 2017 (and planned for 2018) Despite these efforts however, the degree of awareness is still much less than desired. In 2018 and beyond, the team will widen messaging and proactively engage in ‘Community Building’ as methods of addressing not only EAB but the sustainability of Boulder’s Urban Tree Canopy. Initiatives explored by the department will include additional awareness efforts, community- collaborative tree plantings, environmentally sensitive methods of dealing with wood debris, and efforts that create investments in tree care and/or replacement over time. Efforts will include: • Notify via postcard those property owners whose trees will be removed within the next few years; • Meet with property management companies and Boulder Area Rental Housing Association (BARHA) to reach rental property owners; • Collaborate with the Climate Commitment team on community event calendars and events during the Year of the Ecosystems; 7 • “Trees Across Boulder “Tree Sale planned for 2018 to provide 15-gallon trees to the public for less than wholesale cost; • Continue to provide milled ash wood to ReSource for public purchase; and • Host 2nd Arbor Day Foundation Tree Recovery program - will give away 250+ trees to Boulder residents to encourage planting and tree diversity Council Feedback Generally, City Council supported staff in the EAB response strategy and the current practices in place to mitigate the impacts of EAB in Boulder. Council had several questions about specific aspects of the EAB challenges related to safety, costs of tree removal, impact on canopy and community engagement. Council members also showed interest and concern in how staff are communicating with the community and making sure neighbors are aware of the safety risks of EAB as well as the financial costs of tree removal. Council members also expressed an understanding and stressed the importance of the urban tree canopy role in overall climate strategies and sustainability within the city. Urban Forest Strategic Plan (UFSP) Since 2016, a staff team has been working with two consultants, Davey Resource Group (technical) and Two Forks Collective (outreach) on a comprehensive Urban Forest Strategic Plan (UFSP) that will outline a long-term approach to ensure the sustainability of Boulder’s urban tree canopy. Steps to develop the Urban Forest Strategic Plan included: 1. Community Engagement: The complete list of engagement activities to date includes: a) Stakeholder Long Form Survey b) Interviews with stakeholders, forestry experts and city officials c) Tree story stations d) Community Short Form Survey e) Public Open House (1) f) Technical Working Group Meetings (3) g) Feedback from the Youth Opportunities Advisory Board (YOAB). h) Young children tree preferences from Growing up Boulder, Boulder County Head Start and Boulder Journey School. 2. Public Tree Inventory 3. Emerald Ash Borer long term strategy (implementation on-going) 4. Urban Forest Resource Analysis 5. Urban Tree Canopy Assessment 6. Consultant On-Boarding and Background Review 7. Plan Development (See Attachment B for Draft Final Plan) Developing the Plan Upon review of the current forestry program and input from the community and other stakeholders, the UFSP team established an overarching goal to maintain 16% urban tree canopy within Boulder. Four themes of sustainable urban forestry including Plan, Manage, Protect and Engage were developed to communicate the goal to the public. Detailed goals and objectives were developed within this structure to guide the future management of Boulder’s urban forest. 8 Plan Urban forestry is an important part of Boulder’s resilience strategy. Increasing the resilience and sustainability of the urban forest directly supports the resilience of the community. 1. Develop and implement a 20-year Planting Plan for public trees to support the 16% urban tree canopy cover by 2037. 2. Create an Urban Forest Emergency Response Plan for city-wide coordination to ensure appropriate coverage and minimize risk to the public. 3. Participate in inter-departmental Urban Ecosystems Management Strategic planning to integrate ecosystem protection and monitoring across urban, agricultural and wildland systems Manage Boulder has an exceptional Forestry program and already implements many industry best management practices. Further refinements and increased funding is needed however to match community expectations. 1. Establish a dedicated, sustained funding source beyond the departmental budget for Boulder Forestry operations to increase the level of service to meet the community’s high standards. 2. Shift management responsibility for all trees in public street rights-of-way and around public buildings under Boulder Forestry to maximize advantages in expertise and scale. 3. Expand the Public Tree Planting program to support efforts toward the goal of 16% canopy by 2037. 4. Increase investment in proactive, preventative maintenance by exploring options to increase the frequency of pruning events for public street trees. 5. Refine the Integrated Pest Management (IPM) Program to improve tree health while minimizing cost and negative impacts to ecosystems and the public. 6. Explore the expansion of the Commercial Tree Program beyond the immediate downtown area to maintain urban tree canopy, protect property and better manage public safety issues. 7. Continue to explore all wood utilization options to improve resiliency to increased cost or disappearance of any single waste stream. 8. Transition to a new Asset Management System to allow efficient forestry business processes across city workgroups and provide essential baseline data for strategic forest management. 9. Streamline the Tree Safety Inspection Program to manage risk and minimize City exposure to claims but reduce the financial and logistical costs on forestry operations. 10. Continue implementation of the Emerald Ash Borer response strategy to maintain public safety, ecosystem services and forest function in the face of unprecedented canopy loss. 11. Develop a staff succession plan within Forestry to encourage continual professional development and facilitate transitions in leadership to minimize disruption to operations. 12. forest stakeholders and the public. Protect The urban forest represents an asset, one which must be nurtured and protected. This is accomplished through municipal code, policies, and design and construction standards that support tree planting and longevity. 1. Strengthen Boulder Forestry’s role in all city CIP projects to minimize damage to tree assets and canopy loss. 9 2. Strengthen existing city requirements for trees on Public Property to increase tree protection, improve site preparation and strengthen tree species diversity requirements to maintain the urban tree canopy and increase forest resiliency. 3. Strengthen existing city requirements for Private Property to increase tree protection, improve site preparation and strengthen tree species diversity requirements to maintain the urban tree canopy and increase forest resiliency. 4. Revise licensing requirements for all tree care companies performing tree work in Boulder to improve public safety and tree health. Engage The Boulder community places a high value on environmental stewardship. Connecting with and educating the community with the most current information on the urban forest will mobilize activists and facilitate policy implementation. In the development of the UFSP, many stakeholders also expressed a desire for a community-based urban forest advocacy group to promote, protect, and enhance Boulder’s urban forest. 1. Provide the community with balanced and objective information to assist them in understanding the problems, alternatives and options to achieve the Boulder urban tree canopy goal. 2. Develop and expand opportunities for community involvement in the commitment to achieve the UTC goal. 3. Involve the public on the analysis, alternatives and recommendations for further urban forestry related planning processes and potential code changes. 4. Partner with the community on projects to broaden knowledge, support and funding for the Boulder urban tree canopy goal. NEXT STEPS • Staff will continue to respond to the EAB challenge through the many ongoing strategies as outlined within this memo and provide regular updates to the community, Parks and Recreation Advisory Board, Environmental Advisory Board and City Council. • Staff is hosting a second UFSP Public Open House on Saturday March 10 at Upslope Brewery from 1 p.m. – 3 p.m. to present the plan and options for public involvement. • The team will seek final acceptance of the plan from the Parks and Recreation Advisory Board in April 2018. • In May 2018, staff will provide a comprehensive information packet to City Council outlining the full process and outcomes of the UFSP and include the final plan. ATTACHMENTS Attachment A: City Council Study Session memo, October 24, 2018: Urban Forest Management Update Attachment B: Boulder Urban Forest Strategic Plan – Final Draft 10 STUDY SESSION MEMORANDUM TO: Mayor and Members of City Council FROM: Jane S. Brautigam, City Manager Mary Ann Weideman, Deputy City Manager Yvette Bowden, Director, Parks and Recreation Jeff Haley, Parks Planning, Design and Community Engagement Manager Kathleen Alexander, City Forester DATE: October 24, 2017 SUBJECT: Urban Forest Management Update EXECUTIVE SUMMARY The Parks and Recreation Department manages Boulder’s urban forest through the forestry workgroup and extensive coordination with the community to ensure the long-term sustainability of the urban canopy. While Boulder has one of the most successful forestry programs along the Front Range, many threats exist with Boulder’s trees which require careful management strategies and effective long-term planning. One of the most recent threats involves the Emerald Ash Borer (EAB). In 2015, Council provided unanimous approval of the department’s EAB Strategy, since then, staff have been implementing the management actions included in that document, to successfully respond to EAB. Despite these efforts, the reality is that Boulder is now entering the phase of the infestation where many trees are dying, becoming unsightly and, more importantly, safety risks to our community. Additionally, staff continue efforts to ensure the community is informed of the impact of EAB on Boulder’s trees and the reality of losing thousands of trees in the coming years on private and publicly-owned parcels. Similarly, to be prepared and plan for future threats and resource impacts, staff are currently developing an Urban Forest Strategic Plan (UFSP) that will outline long-term goals, and action plans to effectively and sustainably managing Boulder’s urban forest. The purpose of the study session is to discuss with City Council the progress to date on the implementation of the Emerald Ash Borer (EAB) Long Term Strategy through public education, planting, tree removals, limited pesticide applications, innovative biocontrol and collaborative research projects. This session will also allow staff to provide City Council with an overview of the UFSP process key findings and next steps. Specifics related to Boulder’s EAB response may be found in this document on pages 3-14 while the Urban Forestry Strategic Plan developments can be found on pages 15-20. 11 Questions for Council Emerald Ash Borer Strategy 1. Does council have any comments or questions related to the status of the EAB response, outcomes to date or strategy moving forward? 2. Does council support the scope and extent of community engagement to ensure the public’s awareness and involvement in the EAB impacts on Boulder’s trees? Urban Forest Strategic Plan 1. Does council have any questions or comments related to the UFSP process to date and key findings through the planning process? 2. Does Council support staff's recommendation to finalize the UFSP through PRAB approval? IV. FEEDBACK FROM ADVISORY BOARDS Staff has provided periodic updates to both the Parks and Recreation Advisory Board (PRAB) and the Environmental Advisory Board (EnvAB) since our community’s original EAB detection in 2013. The role of the boards is not to approve each phase of the strategy but rather to provide overall feedback and guidance on the aspects of the strategy and the outcomes. Staff will continue to engage the boards through the EAB response to ensure alignment with the various response strategies and other city policy/practices. Related to the draft UFSP, staff have engaged PRAB and EnvAB throughout the planning process and will provide a comprehensive overview of the process to the boards this month, October 2017. Feedback on pertinent topics will also be solicited from Planning Board, the Downtown Management Commission and the Water Resources Advisory Board throughout late 2017 and early 2018. BACKGROUND Forestry staff directly maintains a total of 50,725 public trees; 13,013 in city parks and 37,712 in street rights-of-way with a total appraised value of over $110 million 1. The workgroup administers the following programs for public trees: tree planting, tree safety inspections, commercial tree program, rotational pruning for trees in city parks and along public street rights- of-way, tree removal, integrated pest management, arborist licensing, tree-related emergency response, enforcement for tree protection codes, and development review for parks, transportation and private projects. The workgroup indirectly manages the estimated 600,000 trees on private property through the enforcement of diseased and dangerous tree codes and the arborist licensing program. Urban forestry staff includes seven FTEs: one city forester, one forestry field operations supervisor, three assistant foresters and two forestry field technicians supplemented by qualified nonstandard employees and contractors as appropriate. This figure reflects a transition of number of non-standards to standard positions implemented in 2017. 1 Urban Forest Resource Analysis, Boulder, Colorado, 2015; Davey Resource Group 12 Boulder’s extensive urban forest reflects a legacy largely created by the tree planting and stewardship efforts of previous generations. Except for trees native to the streamside corridors, Boulder’s trees were planted and tended by residents who valued the trees shade and beauty. The city’s urban forest is one of the few city assets that appreciate over time. Trees are not just a luxury for the City of Boulder; they are part of the city infrastructure. Boulder’s urban forest provides nearly $5.2 million in annual environmental, economic, and social services benefits ($50.39 per capita, an average of $102.48/tree). These beneficial services include air quality improvements, energy savings, stormwater runoff reduction, atmospheric CO2 reduction, and aesthetic contributions to the social and economic health of the community. With an established tree population in overall good condition, a high percentage of young trees, and authorized diversification tree canopy (including 237 different species), the community’s urban forest will continue to be a vital asset to the city and neighboring communities. Boulder’s urban forest reduces electric energy consumption by 3,909 MWh and annual natural gas consumption by 137,736 therms, for a combined value of $442,432 annually. In addition, these trees are removing 17.2 tons of pollutants from the air, including ozone (O3), nitrogen dioxide (NO2), sulfur dioxide (SO2), and particulates (PM10) for an overall annual air quality benefit of $66,282. The urban tree canopy from the public tree population covers 651 acres. This canopy reduces annual stormwater runoff by more than 30.6 million gallons and protects local water resources by reducing sediment and pollution loading. To date, community trees have sequestered 36,892 tons of carbon (CO2). They continue to sequester an additional 2,254 tons of CO2 each year for an annual net benefit valued at $43,084.2 The amount and distribution of leaf surface area is the driving force behind the urban forest’s ability to produce benefits for the community (Clark et al, 1997). As canopy cover increases, so do the environmental services and socio-economic benefits. Urban tree canopy (UTC) is the layer of leaves, branches, and stems of trees and other woody plants that cover the ground when viewed from above. Understanding the location and extent of tree canopy is critical to developing and implementing sound management strategies that will promote the smart growth and resiliency of Boulder’s urban forest and the invaluable services it provides. The City of Boulder encompasses 27.3 square miles (17,473 acres). Tree canopy covers approximately 4.3 square miles (2,773 acres) for an average canopy cover of approximately 15.9%. As a comparison, the UTC in Portland, OR is 30%, Denver is 16%, Fort Collins is 10%, Longmont is 9% and Broomfield is 8%. The annual investment (cost) to maintain publicly-owned trees is approximately $1.17 million. For every $1 invested in the community urban forest, Boulder receives $4.46 in benefits. The fact that Boulder’s benefit–cost ratio of 4.46 exceeds ratios reported for five comparable cities (3.09 in Bismarck, ND, 2.41 in Glendale, AZ, 2.18 in Fort Collins, 2.09 in Cheyenne, WY, and 1.37 in Berkeley, CA) indicates that the program is not only operationally efficient, but capitalizing on the functional services its trees can produce.3 2 Urban Forest Resource Analysis, Boulder, Colorado, 2015; Davey Resource Group 3 City of Boulder, Colorado Municipal Tree Resource Analysis, US Forest Service, 2005 13 Threats to the Urban Tree Canopy The three largest threats to urban forests across the country are: 1) invasive insect and disease pests, 2) climate change and individual severe weather events and 3) development. Invasive Pests The impacts from invasive pests can be both environmentally and economically devastating. Invasive pests are not new to the Boulder landscape. Dutch elm disease (DED) was introduced into Colorado in the 1970’s and first discovered in Boulder in 1978. Over the past 40 years, more than 1,000 American elms have been removed in the city and approximately 30,000 elms across the state have been eradicated due to the disease. Other pests that have caused tree mortality in Boulder over the past ten years, or are expected to cause tree mortality, include: thousand cankers disease of walnut, drippy blight of northern red oak, Japanese beetle, pine wilt nematode, Douglas-fir tussock moth, ips beetle in spruce and mountain pine beetle. Emerald ash borer was most likely introduced to the U.S. in the mid-to late 1990’s through wooden shipping or packaging materials originating in China. It was first detected in 2002 and since then, has moved across the country to 31 states and two Canadian provinces. Although EAB spreads short distances (.5 to 6 miles) annually through the flight of adult beetles, long distance spread occurs mainly through the movement of infested material. North American ash trees have shown little resistance to EAB and hundreds of millions of ashes trees across the Midwest have died from this pest since the initial introduction. It is assumed that EAB was brought to Boulder in infested firewood approximately 6-7 years ago. In late September 2013, City Forestry staff discovered an EAB infestation within the city. The beetles were detected by staff when sampling a dead ash tree prior to its removal. This was the first detection of this insect in Colorado and is the western-most occurrence of this invasive pest in North America. The subsequent delimitation survey showed EAB was well established at the time of discovery within a corridor in central Boulder. In terms of invasive forest pests, EAB may well represent the worst-case scenario. EAB management primarily differs from other invasive tree pest management strategies in four ways: 1. Mortality of susceptible hosts: There is very little resistance to EAB in North American ash species. Researchers have found almost 100% mortality in most species of ash especially green ash which is the prevalent ash species across Colorado. EAB also kills ash trees quickly; at high EAB populations EAB can kill mature trees in 1-2 years. 2. Scale of infestation: There are more trees susceptible to EAB than any other invasive pest to date. Dutch elm disease in Colorado killed approximately 30,000 American elm trees over a 40-year period and threatened 200 million elms across the U.S. EAB threatens 1.45 million ash trees in the metro Denver area alone and threatens an estimated 7.5 billion ash trees across the U.S. Ash is one of the most abundant tree species in Colorado comprising approximately 15% of all deciduous trees in many urban areas and approximately 12% in the City of Boulder.4 4 Urban Forest Resource Analysis, Boulder, Colorado, 2015; Davey Resource Group 14 There are an estimated 1.45 million ash trees in the Denver metro area alone. The 2013 U.S. Forest Service (USFS) Metro Denver Urban Forest Assessment Report estimates there are 656,000 trees in the City of Boulder with an appraised value of $1.2 billion.5 The 2015 inventory update indicated there are 50,725 total city park and public street rights-of-way trees; 6,016 (11.9%) are either green or white ash trees with an appraised value of $14.6 million. Assuming a similar percent of ash on private property, the estimated number of public, private, and naturalized ash in Boulder is over 70,000 trees. 3. Difficulty in detection: Dendrochronological evidence indicates EAB is typically established in an area for 3-8 years before discovery. The difficulty is because beetles attack in the upper canopies first; at low beetle populations, trees often do not show symptoms until several years after initial infestation; there is no available pheromone for trapping purposes; and EAB symptoms are like those of other insect pests and environmental problems. 4. Speed of infestation within community: EAB populations expand exponentially. Mated female beetles produce 40-70 eggs on average but can produce more than 200 eggs. Populations can therefore expand quickly before detection. Midwest cities report that without the use of pesticides, all ash within a community are dying after just 10-12 years after introduction. Climate Change Urban forests can help mitigate for the impacts of climate change yet urban forests are also at risk from a changing climate. Boulder’s extreme weather will continue to impact the species of trees that can successfully establish and thrive in Boulder. Climate change will continue to be a factor due to changes in precipitation seasons and type (rain, ice, or snow), temperature fluctuations outside historic patterns, and changes in regional temperature norms. These changes blur the lines of established plant hardiness zones and the species that can be grown in each region. Research indicates that healthy trees can mitigate a range of environmental impacts, including stormwater runoff, poor air quality and temperature extremes. Trees also provide significant energy use reductions associated with both cooling and heating. The density and placement of trees in an urban environment is typically measured by the percentage of area covered by the trees during full foliage—the UTC). Cities with higher UTCs are typically able to reduce temperature extremes—often referred to as the “urban heat island” effect. These reductions can be significant. Climate change is beginning to exacerbate the stresses urban trees are already facing, including temperature extremes, drought stress, infestation and disease, adding to the urgency to create effective protection and restoration strategies. Effects of climate change include: • Hotter summers are stressing young trees and increasing external watering needs. • Prolonged drought can cause summer defoliation and tree mortality; • Milder winters enable a proliferation of pests and increase susceptibility to premature budburst and subsequent freeze damage to new growth. 5 2013 Metro Denver Urban Forest Assessment Report, US Forest Service 15 • Extreme temperature fluctuations can stress or kill trees. During 2014, a November temperature drop from 64° to -11° in 48 hours created substantial local damage and tree mortality. • Increased water stress will also make trees more susceptible to a wide range of insects and disease that attack low vigor trees. • Snow buildup on branches during early fall or late spring snowstorms can cause excess weight on branches, which break or form internal cracks that further weaken branches • Warmer winter temperatures may alter dormancy requirements. Development In many communities across the US, land development threatens urban tree canopy, especially when parcels include high-quality established trees. One of the biggest challenges to tree preservation is site management on construction projects. Tree preservation of private mature trees, although a priority for city staff is not necessarily a priority for private developers. As a result, long term survival for these trees is often not attained. When trees of appropriate species are found in good health and condition, developers are encouraged to retain them. However, barriers to tree preservation exist, including: • clearly defining trees as an asset; • early inclusion in the inventory and analysis design phase; • adequate and timely installation of tree protection fencing on construction sites; • coordination and understanding of grading impacts to tree roots and soil volume requirements; • consistent irrigation throughout the planning and construction process; and • general lack of site management and communication of standards. Undeveloped lots without trees or lots with trees that are in poor condition, or with unsuitable species provide an opportunity to enhance the urban forest. Development and the irrigated landscapes that accompany new structures can contribute to an increase in the healthy, long-lived trees that make up a sustainable urban forest. This is often the case in Boulder where developments include a mix of removal and preservation. However, there are problems such as: • Improper placing of young trees on development sites; • Lack of specialized care for young, newly planted trees; • No requirements for on-going maintenance to ensure private trees reach a mature size and structure; • Irrigation systems are not maintained; or • Dead trees are not replaced. ANALYSIS Forestry staff collaborated with multiple state and federal agencies and with leading EAB experts from across the U.S. and Canada to develop a short-term emergency response to EAB. Informational memos outlining the emergency response were submitted to City Council in February and April 2014. An Interdepartmental EAB Strategic Team was formed and developed the long-term strategies presented in this memo to manage EAB on a citywide scale and ensure consistency across departments. The long term EAB Strategy was presented to City Council and received unanimous support in September 2015. 16 The Forestry Division has six main themes for EAB management in Boulder: • Protect public safety and minimize liability; • Maintain a healthy, diverse and sustainable urban forest; • Maintain or increase the urban tree canopy to maximize the environmental, social and economic services provided to Boulder; • Minimize risks to non-target organisms from pesticide applications; • Minimize costs; and • Minimize disruption to other forestry operations. The strategy includes the following response measures further described below: A. EAB Multi Agency Response B. Quarantine C. Public Education / Outreach D. Tree Plantings E. Tree Removals F. Pesticide Applications G. Biocontrol H. Wood Utilization I. Enforcement J. Collaborative Research Projects A. EAB Multi Agency Response After the initial discovery of EAB in Boulder, the USDA Animal and Plant Health Inspection Service (APHIS), the agency responsible for the federal EAB quarantine, declared EAB in Colorado as an “incident” similar to a wildfire and instituted the Incident Command System (ICS). The ICS allowed all affected agencies to share communication while developing mitigation and management strategies and outreach materials for EAB in Colorado. Goal presented to City Council: Continue staff participation in the inter-agency EAB working group. Continue dialogue with leading national EAB researchers and the interdepartmental EAB Strategic Team. 2014 - 2017: The EAB ICS was in place from September 2013 through April 2015, when it transitioned to the Colorado EAB Response Team. Agencies participating in the EAB ICS and in the Colorado EAB Response team include: APHIS, Colorado Department of Agriculture (CDA), City of Boulder, Boulder County, University of Colorado (CU), Colorado State Forest Service (CSFS), and Colorado State University (CSU). Boulder Forestry staff has participated, assisted with development of outreach material and hosted multiple EAB tours to teach green industry staff from six states about EAB. 2018 and beyond: Boulder Forestry will continue participation in the Colorado EAB Response Team. 17 B. Quarantine Exotic and native forest pests such as EAB and Asian long horned beetle disperse various distances through multiple pathways including movement of nursery stock and firewood. EAB is a federally quarantined pest. There are federal and state quarantines in effect that prohibit the movement of firewood and other ash wood materials outside quarantined areas. Goal presented to City Council: Collaborate with state and federal agencies on the EAB quarantine and adhere to all restrictions. 2014 - 2017: The CDA imposed a quarantine on the movement of all ash tree products and hardwood firewood out of Boulder County. Small portions of Jefferson and Weld Counties were also included to gain access to two landfills within the quarantine area to allow disposal of some infested material. The state quarantine took effect on November 12, 2013 and a federal quarantine was enacted in April 2014. Enforcement capabilities by CDA are limited however. 2018 and beyond: Once EAB is detected within the Denver metro area, the entire six county region at a minimum will be quarantined. CDA will continue to regulate movement of materials between counties through compliance agreements. Eventually, a large enough portion of the state will be considered infested and if the federal EAB quarantine is still in place, the entire state will be quarantined and APHIS will then regulate movement of materials between Colorado and other states. APHIS is however considering “delisting” EAB and ending the federal quarantine completely due to lack of success in stopping this pest. Such an action may end quarantine restrictions in Colorado. C. Public Education / Outreach / Engagement Education and outreach are critical components of response to an invasive tree pest. Emerging Pests in Colorado (EPIC) statewide working group was formed in 2009. Participants included staff from the CDA, CSFS, CSU, APHIS, and foresters from several cities including Boulder, Denver, and Fort Collins. Since 2009, the agencies have collaborated to raise industry and public awareness about the threat of EAB and other invasive pests. 2014 – 2017: Efforts include those as part of the CO EAB Response team and as the city of Boulder. Highlights of the multi-agency efforts include: • Websites: CDA has posted educational material about EAB on their website: www.EABColorado.com. • News Releases: The CO EAB Response Team and City of Boulder have distributed over 25 news releases since the initial detection. • EAB Workshops: City Forestry hosted a series of EAB Identification and branch peeling workshops in 2013, 2014 and 2015 then a series of EAB Van Tours in 2016 and 2017. The interagency group has trained over 550 foresters, arborists, and landscape professionals from six states on EAB symptoms and branch peeling techniques. • Educational material produced included: Emerald Ash Borer Quick Guide, EAB Decision Matrix, Revised Edition of Insecticide Options for Protecting Ash Trees from Emerald 18 Ash Borer, Colorado specific EAB FAQ’s, EAB identification cards, utility billing inserts, and RTD bus advertisements. • Launch TreeOpp program –Community awareness/engagement wood utilization program repurposing ash wood into lumber, art, furniture in partnership with BLDG 61, Bridge House and ReSource. • HOA Meetings: Meeting with over 20 local HOA groups to discuss EAB management; • Hosting three open houses for the public in 2014 and staffing information tables at Farmers Market and McGuckin’s. • Websites: A website was created for Boulder specific EAB information at: www.EABBoulder.org and a hub to engage the community specifically on EAB and resiliency was created at www.resilienttogether.org/emerald-ash-borer. • News Releases: Collaboration on the CO EAB Response team news releases since the initial detection and response to over 75 media requests since the EAB discovery. • EAB presentations to Parks and Recreation and Environmental Advisory boards and the Downtown Management Commission. • Reaching out to individual downtown commercial business owners as opportunities arise to replace declining public ash trees. • Launched first annual Boulder Tree Recovery Program with support from National Arbor Day Foundation – gave away ~250 1-5gallon trees to residents to plant on private property. • Seedlings for BVSD 5th graders: Each spring Boulder Forestry provides a short educational presentation to BVSD 5th graders on the importance of our urban tree canopy, the potential impacts of EAB and explains how they can make a difference. Each student also receives a seedling tree to plant for future generations to enjoy. • Hosted 5 community volunteer planting events at locations around city. • Partner with the PLAY Boulder Foundation to launch a Tree Trust. 2018 and beyond: Consistent with the Master Plan themes, the department will continue to implement strategies that ‘Take Care of What We Have’ and proactively engage in ‘Community Building’ as methods of addressing the sustainability of Boulder’s Urban Tree Canopy. Initiatives explored by the department will include additional awareness efforts, community-collaborative tree plantings, environmentally sensitive methods of dealing with wood debris, and efforts that create investments in tree care and/or replacement over time. To be proactive and prepare the public for the increasing tree removals, Parks & Recreation Forestry staff has developed an outreach plan that will align with similar efforts through the Urban Forest Strategic Plan. Steps to date include: • Developed an online pesticide notification form so the public can easily request authorization for pesticide applications to street trees; • Updated all information on the Urban Forestry website; and • Developed an EAB Story Map to tell the city EAB story including upcoming plans for EAB removals. In 2018, staff will: 19 • Notify via postcard those property owners whose trees will be removed within the next few years; provide option for them to notify Forestry via on-line form if they are treating the tree(s); • Continue presentations and seedling giveaway to BVSD 5th graders about importance of the UTC and impacts from EAB; and • Collaborate with the Climate Commitment team on a spring “Tree Festival” for the Year of the Ecosystems. • “Trees Across Boulder “Tree Sale planned for 2018: Longmont Forestry hosted a successful “Tree Sale” in spring 2017. The city sold 120 - 15-gallon trees to residents for $60/tree in a diversity of species for a discounted cost. The tree cost was subsidized through a grant. Boulder Forestry plans to sell 150 trees total of 16 different species in spring 2018. • Continue to provide milled ash wood to ReSource for public purchase • Host 2nd Arbor Day Foundation Tree Recovery program - will give away 300+ trees to Boulder residents to encourage planting and tree diversity D. Tree Plantings To adequately maintain the urban tree canopy, it is imperative that new trees are planted in anticipation of losses. Newly planted trees are significantly smaller than most removed trees and contribute less environmental services on a per tree basis than mature trees. Therefore, trees should be replaced at a minimum 1:1 ratio (trees planted: trees removed). It has been difficult however to maintain a 1:1 ratio in some years due to a high number of tree removals from various factors and constraints on tree planting due to budget, staffing, and irrigation limitations. The following chart in represents only those trees planted through city Forestry and through parks development projects since 2000. This chart does not reflect those trees planted through development or transportation projects during the same period. 20 As pests and severe weather events continue to impact trees, maintaining and increasing tree diversity over time is key to a resilient urban tree canopy. Boulder is fortunate to have better soils than most other Front Range cities and can therefore grow a larger diversity of tree species. The latest tree inventory shows there are 237 distinct tree species on public property in Boulder. Goal presented to City Council: Plant 500 trees annually by city Forestry; it is expected however that as the number of ash removals increases, the number of trees planted may decrease as staff remains focused on safety-related, priority removals. 2014 - 2017: Forestry staff planted an average of 480 trees annually in city parks and along street rights-of-way. Additional trees were planted on public property through Parks, Transportation and private development projects. Each year, a minimum of thirty-five species were represented with over 85% large maturing tree species to maximize environmental services provided. 2018 and beyond: The goal for 2018 is to plant 500 trees. The current inventory analysis will help identify species distribution across the city and help achieve future diversification goals. One goal of the upcoming urban tree canopy assessment and Urban Forest Strategic Plan is to identify areas in need of additional tree planting heighten tree planting prioritization. 21 E. Tree Removals Goal presented to City Council: The approximately 4,500 untreated public ash trees will be removed as they decline. There are additional public ash in natural areas that are not included in the above number. It is recommended the city proactively remove ash trees that have been identified as being in poor or very poor condition. Phase out ash trees when possible through private development, Transportation, Parks and Recreation and UHGID capital improvement projects. 2014 - 2017: Over 1300 public ash trees have been removed to date. Forestry staff has fallen slightly behind on ash removals however due to the need to remove dead Siberian elms impacted by the 2014 November freeze (over 500 dead public Siberian elms removed since spring 2015) and the emergency response to the two snowstorms in spring 2016. Hundreds of private ash trees were symptomatic during surveys in 2014-2017; many have been removed but exact numbers are not known. 2018 and beyond: Staff has detected heavily infested, symptomatic ash throughout Boulder. Observations indicate it takes approximately 3 years to progress from only a few dead ash trees in an area to the point where all ash trees were dead, dying or removed. Because EAB populations expand exponentially, the number of annual public ash tree removals is not expected to remain constant or predictable. In the absence of pesticide use, cities in the Midwest, for example, have lost most of their ash trees within 5-6 years of detection. Boulder Parks & Recreations’ Forestry group has observed that ash trees killed by EAB dry out, become brittle and start to fail within 1 year after mortality. This is consistent with observations across the Midwest. Allowing trees to reach the point of failure is unacceptable from the standpoint of public safety. Staff will survey each July and create a list of ash trees to be removed. Larger removals and stump grinding will then be contracted during the winter months when costs are typically lower. Forestry staff will continue to remove smaller diameter ash trees. The central Boulder neighborhoods (East Boulder, Table Mesa, Keewaydin) are at or beyond the peak of the EAB “death curve” and EAB populations and the number of dying ash in several of the older neighborhoods (Whittier, Goss/Grove, University Hill) increased significantly in 2016- 2017. As untreated public ash trees start to decline in an area, all untreated ash along the street will be removed at the same time to reduce tree removal and traffic control costs and minimize community inconvenience. F. Pesticide Applications EAB infestation is almost 100 percent fatal to North American species of ash trees, therefore pesticides are an important component of EAB management programs as they can: • Preserve ash trees long term; • Reduce community-wide EAB populations and therefore slow the progression of EAB; • Spread the tree removal and replacement costs over a longer time; • Lower risk and public safety concerns associated with large numbers of dying trees; and 22 • Spread the loss of the urban tree canopy and the subsequent loss of the environmental and economic services provided by the urban tree canopy over a longer period. Goal presented to City Council: Treat approximately 25% of public ash long term with the trunk injected in TREE-äge (emamectin benzoate) to slow the progression and preserve healthy public ash trees. Forestry staff is currently treating 1339 public ash (22%) predominantly with trunk injections of TREE-äge on a 3-year rotation. 2014 - 2017: Forestry staff evaluated thousands of park and public street right-of-way ash trees and chose 1,339 (22%) ash trees that met the criteria for long term preservation. Those trees were treated on a 3-year rotation with TREE-äge (emamectin benzoate). A few trees in environmentally sensitive areas are being treated annually with TREEAzin. To meet the criteria, trees must be: • In good health • Free from any major structural defects • At least 10” in diameter • In a good location (e.g. not under power lines, causing significant hardscape damage) • Irrigated (systemic pesticides require water to be taken up internally within the tree). Based on the criteria for treatment, ash trees on the Pearl Street Mall were not good candidates for treatment. A short term, phased replacement plan is in place for the mall. More than 25% of Boulder’s public ash trees meet the criteria for EAB treatment. Some property owners have requested to treat public street right-of-way ash trees not treated by the city. Per B.R.C. Chapter 6 Protection of Trees and Plants, 6-6-5 Spraying and Pruning, homeowners are only allowed to treat public street right-of-way trees adjacent to their property with the permission of the City Manager. This authority has been delegated to Forestry staff. Permission shall be granted if the: • Public ash tree is worthy of long term preservation; • Applicator is a state licensed pesticide applicator; • Tree care company is a city licensed certified arborist; and • Only TREE-äge or TreeAzin is applied. All requests for pesticide applications are being tracked by Forestry staff. In 2015, city staff collaborated with Bee Safe Boulder members on a resolution banning the use of neonicotinoid pesticides on city owned properties. This resolution was later adopted (Resolution 1159) by City Council. The resolution requires a formal exemption process if any neonicotinoid is used for either research studies or application to control a tree pest. 2018 and beyond: Continue pesticide application on a 3-year rotation. In 2018 the pesticide application rates will be decreased following recommendations from EAB researchers in the Midwest. It is anticipated the number of ash trees treated each cycle will decrease due to factors other than EAB (i.e. storm damage, vandalism, etc.). 23 G. Biocontrol EAB’s native range is Asia where several predators, pathogens, and host tree defenses keep it from becoming a major pest. Although the ability of Asian trees to resist infestation provides protection from EAB, there are numerous natural enemies, notably various species of parasitic wasps, and together this combination effectively limits EAB so that it rarely causes serious damage in Asia. Current research has and continues to be conducted by federal agencies to identify Asian parasites of the EAB. Four of these have been found suitable for introduction and were released in EAB outbreak areas in the Midwest and in many cases, have proven capable of establishing and reproducing. Goal presented to City Council: Release 4 species of non-stinging, parasitic wasp on-going; USDA APHIS rears the EAB biocontrol at their Michigan facility and provides the biocontrol at no cost to cities. Local APHIS staff applied for the permits necessary to release four biocontrol in Boulder. 2014 - 2017: Forestry staff collaborated with CO Department of Agriculture (CDA) and APHIS to release all 4 species of wasp in multiple locations along Boulder Creek Path and on OSMP property south of Chautauqua Park. CDA branch peeling and trapping indicates at least two of the species are successfully reproducing. The wasp species, number of releases and number of wasps is as follows: • Tetrastarches planipennisi: 108 releases, 10,606 wasps • Oobius agrili: 74 releases, 5,600 wasps • Spathius agrili: 41 releases, 2,235 wasps • Spathius galinae: 21 releases, 1,718 wasps 2018 and beyond: Continue wasp releases per APHIS guidelines. H. Wood Utilization Throughout the U.S. large amounts of urban forest residues (UFR) including wood chips, brush, logs and leaves, are generated by homeowners, municipal tree care operations, landscape maintenance, and tree care companies because of managing urban forests. The utilization and/or disposal or UFRs has been problematic across the country even prior to the introduction of emerald ash borer (EAB). There are obstacles to the utilization of UFRs including wood quality, wood quantity, utilization plans, and community support. Within urban settings, trees tend to grow around nails, fences, and cables, potentially decreasing the wood quality and damaging wood processing equipment. Many urban trees also lean over homes and other hardscapes, posing safety concerns during tree removal operations prompting tree care companies to remove smaller (and less marketable) sections of wood. A 2008 Colorado State University (CSU) study found that 60% of UFR from Fort Collins, Greeley, and Loveland was used to create mulch while the remaining 40% was most likely deposited into landfills. With a resource that is 100% recoverable if markets are established, there is great potential to utilize UFR in a more sustainable manner and to extend the life of nearby landfills. 24 Most cities across the Midwest have realized there is no one long term solution for this issue due to the volume created and supply and demand from various markets. Multiple options must therefore be developed to utilize the product sustainably and to minimize costs. All UFRs generated from Boulder Forestry pruning and removal operations are brought back to the city’s Forestry log yard. Forestry strives to conduct wood utilization efforts in a sustainable and community appropriate way toward minimizing UFR entering landfills. Since 2000, only two truckloads of wood infected with Dutch elm disease were diverted to the Erie landfill. All other UFR was successfully diverted utilizing a variety of options. Goal presented to City Council: Collaborate with other agencies on options for finding sustainable options for wood debris moving forward. Continue to divert all wood debris from the landfill. 2014 - 2017: Identified several options for wood debris but obstacles still exist. The amount of wood debris will increase as the number of ash removals increase over the next several years. Options currently being utilized: a. Launch TreeOpp program utilizing EAB affected ash wood to create high-end furniture and art products to sell and educate the public in partnership with BLDG 61 Boulder Library Makerspace and Bridge House. b. Pilot partnership with ReSource to test market viability and financial sustainability of ongoing milling through sale of milled lumber. c. MOU with Boulder County for biomass to heat two of their county buildings d. Confluence Energy turning logs into wood pellets for BBQ grills e. OSMP utilizing logs that meet their size requirements for bank stabilization projects f. Grind remaining wood into chips; trucked to A-1 Organics to be utilized as compost g. Utilize trunks as park improvement infrastructure and some mulch for new tree plantings in city parks 2018 and beyond: Continue considering all available and appropriate options. I. Enforcement Research indicates that ash trees killed by EAB dry out and start to fail within a few years after tree mortality posing a public safety risk. Discussions with the City Attorney’s office (CAO), Risk Management, and Boulder Police Department (BPD), indicate the city has a duty to enforce city regulations for dead ash trees located on private property but have the potential to threaten public property. The city is not proposing to implement enforce efforts on private property where the trees only pose a threat to neighboring private property. Goal presented to City Council: Enforce as needed for private trees that threaten public property. 2014 - 2017: Forestry staff, in cooperation with BPD and CAO, has enforced removal of dead ash trees as needed. As expected, the numbers are increasing as EAB spreads through the city: • 2014 – 13 • 2015 – 9 25 • 2016 – 85 • 2017 - 118 (as of 9/30/2017) The ordinance used for enforcement is B.R.C. 6-6-2(b) Removal of Dead, Diseased or Dangerous Trees which reads: “If the city manager finds that there exists on any private property in the city dead trees or overhanging limbs that pose a danger to persons or property, the manager will notify the owner, lessee, agent, occupant, or other person in possession or control of the property upon which the condition exists of the duty to remedy the condition within fifteen days from the date of the notice or such shorter time as the manager finds appropriate in view of the nature and extent of the condition.” Recently, local tree care companies have also experienced significant increases in requests for work, they have also been unable to remove trees within the 15 days required by ordinance. In many cases, it has taken 30+ days to get these dying/dead ash trees removed increasing public safety concerns. 2018 and beyond: It is anticipated that current staffing levels, even as supplemented by contractors, will not be sufficient to support enforcement efforts as EAB reaches its peak. To prevent further public safety issues, Forestry staff will enforce on private property ash trees with less than 50% crown symptoms. Removing symptomatic ash while still green should also lower costs as ash trees that exhibit >50% crown symptoms must be removed with specialized equipment that further increases removal costs. Ash trees along Greenways pose another concern. Green ash is naturalized (to various degrees) along all creeks and ditches in Boulder. Due to the proximity of bike paths, tree removal or enforcement should be expected (depending upon whether public or private property) as these trees die. J. Collaborative Research Projects Colorado is the westernmost state with EAB. Here, the weather patterns and ash tree growth differ from the Midwest where most EAB research has occurred to date. Several research projects are underway in Boulder. Some were initiated by Forestry staff while others are in collaboration with CSU, APHIS or the CFS. Current and past EAB projects include: • In 2014, assisted the CFS with a project to test a new EAB pheromone. • In 2014, assisted APHIS with testing new EAB trapping protocols. • Each year, Forestry staff is tracking emergence of EAB adults to track first and peak emergence of EAB. • Research into effects of wounding from trunk injected pesticides on ash trees in Colorado at Columbia Cemetery (ash trees grow more slowly in Colorado and receive less rainfall than in Midwest so wounding may have bigger impact than elsewhere in US). • Research to determine feasibility of multi-year control with TreeAzin. • Research to determine feasibility of longer term control with different formulations of emamectin benzoate pesticide products (at Flatirons Golf Course). 26 Urban Forest Strategic Plan (UFSP) Staff are working with Davey Resource Group and Two Forks Collective on a comprehensive Urban Forest Strategic Plan (UFSP) that will outline a long-term approach to ensure the sustainability of Boulder’s urban tree canopy. The UFSP has provided a comprehensive community-wide discussion of the following topics: • Establishment of a baseline figure for urban tree canopy and long-term canopy goals; • Tree diversification goals; • Urban heat island mitigation; • Prioritization of tree planting, maintenance and pruning activities; • Pesticide use guidelines for public trees and Appropriate pesticide use guidelines for private property owners treating public street trees; • Placement and selection of tree species that are compatible with optimizing rooftop solar capture capacity; • Coordination with vegetation management • Public outreach and education regarding the benefits of the urban canopy. Steps to develop the Urban Forest Strategic Plan include: Community Engagement The team developed a phased outreach process to determine residents’ views about current needs, trends and attitudes about urban forestry programs as well as assist in the development of relationships for long-term stewardship of Boulder’s urban forest. The public engagement process included qualitative methods such as stakeholder interviews, tree story stations and working group sessions coupled with a quantitative survey. The complete list of engagement activities includes: 1. Stakeholder Long Form Survey 2. Interviews with stakeholders, forestry experts and city officials 3. Tree story stations 4. Community Short Form Survey 5. Public Open House (1) 6. Working Group Meetings (2) 7. Feedback from the Youth Opportunities Advisory Board (YOAB). 8. Young children tree preferences from Growing up Boulder, Boulder County Head Start and Boulder Journey School. These outreach activities follow an evolution of engagement that begins with expanding the public’s awareness and understanding of the urban forest and the role of Boulder’s forestry department, and moves towards encouraging the public to become advocates, acting to help preserve and maintain their urban forest. The results from these activities will help inform the recommendations, priorities and implementation strategies for the Boulder Urban Forest Strategic Plan (UFSP) and will also inform a marketing plan focused on cultivating long-term stewardship of Boulder’s urban forest. For a complete summary of the outreach and outcomes, see (Appendix A – Summary of UFSP Community Engagement). 27 Public Tree Inventory (completed) The first step towards an UFSP was to identify the existing public tree resource. In winter 2014 - 2015, Forestry staff contracted with Davey Resource Group to update the tree inventory. The data was imported into tree inventory and asset management software to track not only EAB related maintenance moving forward, but all tree maintenance for public trees in city parks and in street rights-of-way. Tree benefit and value information in the background section of this memo is from the draft 2015 Urban Forest Resource Analysis report from Davey Resource Group. Emerald Ash Borer long term strategy (implementation on-going) Forestry staff collaborated with multiple state and federal agencies and with leading EAB experts from across the U.S. and Canada to develop a short-term emergency response to EAB. Informational memos outlining the emergency response were submitted to City Council in February and April 2014. An Interdepartmental EAB Strategic Team was formed and developed the long-term strategies presented in this memo to manage EAB on a citywide scale and ensure consistency across departments. The long term EAB Strategy was presented to City Council and received unanimous support in September 2015. Urban Forest Resource Analysis (completed) In fall 2015, Forestry staff contracted with Davey Resource Group to analyze Boulder’s urban forest resources. Davey’s analysis describes the current structural characteristics of Boulder’s community urban forest resource, using established tree sampling, numerical modeling, and statistical methods to provide a general accounting of the benefits. The analysis provides a “snapshot” of this resource at its current population, structure, and condition. The analysis provides baseline data to better understand the status of the urban forest population and is a starting point for determining new maintenance and management policies and procedures, as well as future budgetary needs. Urban Tree Canopy Assessment (completed) To establish baseline figures for urban tree canopy and assist in long term planning, the city participated in a collaborative Urban Tree Analysis project with Digital Globe and Trimble, partners of the Rockefeller Foundation’s 100 Resilient Cities (100RC) initiative. The analysis showed Boulder had an UTC of approximately 4.3 square miles (2,773 acres) for an average canopy cover of 15.9% in 2013. This was prior to much die-off from EAB and the November 2014 freeze that killed hundreds of trees across the city. Consultant On-Boarding and Background Review (completed) Phase I of the process included a comprehensive review of the history of Boulder’s urban forest including establishment, management and regulatory policies, as well as interviews with key internal and external stakeholders. In addition, DRG examined organizational structure along with staffing, equipment and funding resources. The information gathered in Phase I helps inform the development of the UFSP, specifically identifying and discussing the existing urban forest resource and management structure, including: • Structure and condition of urban forest resources; • Environmental and socio-economic benefits of the urban forest; 28 • Ordinances, regulations and policies, • Community vision and priorities; • Staffing and funding; and • Stakeholder input. Conclusions reached throughout the Phase I analysis determined that Boulder has a robust City Forestry program with proactive pruning cycles, annual tree inspections, tree risk evaluation and integrated pest management. The report indicated that staff has a high level of expertise and are supported in their ongoing education and professional development. In recent years, cost of living increases, mounting service delivery expectations and limited organizational budgets have created some gaps between public expectations and service capacity. Changes in climate, emerging urban forest threats and community growth are obstacles to maintaining the high level of service expected by Boulder residents. In many cases, these challenges can be viewed as opportunities for development and increased efficiency. Ongoing adaptive management and monitoring success are cornerstones to building a more resilient urban forest for future generations. Staff and the consultant team continue to develop the long-term strategy and road map for managing the city’s urban tree canopy. The development of the UFSP requires an understanding of the shared community vision for the urban forest combined with technical data and best practices. Boulder’s urban forest includes approximately 50,800 inventoried street and park trees managed by Boulder Parks & Recreation’s Forestry group. These trees are a subset of the overall urban forest that also includes tens of thousands of trees on public and private property and naturalized along the creeks and ditches. As the urban forest has grown, challenges and opportunities have emerged that require a proactive management approach and a long-term planning strategy to preserve the health, sustainability and benefits of trees and canopy cover. In 2016, the city contracted with the Davey Resource Group (DRG) to develop a strategic plan to specifically address the unique challenges and opportunities Boulder’s urban forest will face over the next twenty years. Developing the Plan Upon review of the current forestry program and input from the community and other stakeholders, the UFSP team established five keystones of sustainable urban forestry to communicate the goals to guide the management of the urban forest, including both public and private trees. Connect The Boulder community places a high value on environmental stewardship. Connecting with and educating the community with the most current information on the urban forest will mobilize activists and facilitate policy implementation. Specific priorities include: • Connect Boulder Forestry partners through a single vision. • Utilize latest urban forestry research and assist with pertinent CSU and CU research projects to further advance urban forestry operations. • Update the Boulder Forestry website and develop outreach material for the public and contractors such as updated door hangers. 29 • Develop specific outreach materials for new plan components (drought, landscaping, EAB) Engage In the development of the UFSP, many stakeholders expressed a desire for a community-based urban forest advocacy group to promote, protect, and enhance Boulder’s urban forest. Priorities to engage the community are: • Communicate UFSP goals. • Establish a partner non-profit urban forest foundation (already established as a PLAY Boulder Foundation priority). • Encourage public and private participation in urban forest management through volunteerism. • Diversify funding sources and partners. • Implement a coordinated and comprehensive outreach and education campaign. • Facilitate private property tree plantings and maintenance. • Continue to pursue maximized wood utilization (potentially through continuation of ReSource coordinated efforts or TreeOpp programming beyond grants-funded pilot program period) • Explore opportunities for local food forests. • Expand youth education and engagement. Manage Boulder has an exceptional Forestry program and already implements many industry best management practices. Management priorities for the UFSP explore: • Match funding levels to desired level of service for urban forestry management. • Consolidate urban forestry responsibilities within city. • Provide a more consistent, efficient contracting operating procedure. • Improve and streamline asset management. • Provide method for public to easily request authorization to perform appropriate tree care, such as pesticide applications, to public trees. • Update tree risk program to ensure sustainability long term. • Update public tree inventory and urban tree canopy analysis every 10 years. • Ensure urban forestry environmental, social and economic services for future generations through a sustainable public tree planting program. Plan Urban forestry is an important part of Boulder’s resilience strategy. Increasing the resilience and sustainability of the urban forest directly supports the resilience of the community. The priorities of this goal include: • Achieve a no-net-loss canopy goal in 20 years. • Develop planting initiatives to increase trees on public and private property. • Increase species diversity on both public and private property through planning and planting efforts to further improve resiliency. • Update codes to improve site preparation, growing conditions and on-going maintenance for urban trees to improve and ensure long term achievement of tree canopy goals. 30 • Develop a Green Infrastructure Management Plan to integrate and align urban forestry practices and stormwater management efforts. • Develop specific Emergency Response and Drought resiliency plans and continue implementation of EAB strategy. • Develop Parks Design and Construction Standards (DCS) ensuring alignment with City DCS. • Continue and expand integration of urban forestry management and stewardship into all city project planning. • Integrate urban forestry goals into other City guiding documents. Protect The urban forest represents an asset, one which must be nurtured and protected. This is accomplished through municipal code, policies, and design and construction standards that support tree planting and longevity. The priorities of this goal include: • Align code with community vision for protection of both public and private trees to achieve urban tree canopy goals and ensure environmental, social and economic services long term. • Continue proactive urban forest pest monitoring to maximize control options if needed. • Ensure tree preservation during all projects is a high priority. • Explore alternative funding options to provide for tree planting and maintenance long term (i.e. expanding options for tree mitigation). • Update Arborist Licensing requirements to better protect the urban tree canopy. • Develop assistance program for private property owners for tree removal. BUDGET AND STAFFING The Parks and Recreation Department’s approved 2017 Capital Improvement Program (CIP) Budget included $220,000 for EAB response. Additionally, the department’s proposed 2018- 2022 CIP Budget includes: • 2018 - $350,000 • 2019 - $500,000 • 2020 - $500,000 • 2021 - $500,000 • 2022 - $500,000 TOTAL = $2,350,000 The EAB CIP funding provides for a variety of measures including: 1. Tree Planting The Forestry Division’s goal is to plant 500 trees annually. Some trees will be planted by in- house Forestry staff and the remaining trees by contracted services. Funding for tree plantings is allocated from three sources: • Tree Planting account • Tree Mitigation Funding • EAB Parks and Recreation CIP 31 2. Tree Removals Using tree removal cost averages from the past 10 years, the estimated contracted removal costs for the 4,500 untreated public ash trees (per 2015 inventory numbers) is expected to equal approximately $1.64 million. Costs may be reduced if private property owners choose to treat additional significant public trees and if the Forestry crew is able to perform more ash removals (versus priority service request pruning, storm response, etc.) 3. Pesticide Applications Pesticide applications are only needed every three years; the strategy is to treat 1/3 of the 22% of public trees annually with TREE-äge: • Total cost = $150,000 • Annual cost = $50,000 4. Wood Disposal Wood disposal costs are variable depending upon success of the existing biomass agreement with Boulder County and viability of other utilization options. Staffing Staff must prioritize EAB over other forestry related work due to the large number of trees that will be impacted over the next decade, the documented rate at which EAB populations build and kill trees, and the potential liability from the large number of standing dead ash trees. Since the EAB detection in 2013, city Forestry services have been impacted significantly and deferred maintenance will become an issue as staff time is further directed to EAB management and control. While funding has remained somewhat stable since 2014, EAB response and recent weather events have also required managers to reallocate maintenance budgets to respond to these emergencies and reduce their impacts on public safety. As a result, pruning rotations have been extended beyond the previous interval of eight years (park trees) to ten years (street trees). Costs for contracted tree work have also risen significantly since 2013 further contributing to the increase in pruning rotation. For example, tree removal costs for trees < 15” diameter have risen an average of 75% and 36% for trees > 16” diameter since the EAB detection. As more money is allocated towards higher priority tree removals and storm damaged trees, less is available for pruning trees. Finally, Boulder Parks & Recreation transitioned two prior nonstandard positions in its Forestry group to full-time standard positions in 2017. NEXT STEPS • Staff will continue to respond to the EAB challenge through the many ongoing strategies as outlined within this memo and provide regular updates to the community, PRAB and City Council. • Throughout the remainder of 2017, staff will work with the community, various advisory boards and the Technical Working Group to review the draft UFSP and focus on the goals, recommendations and implementation priorities to ensure alignment of the draft plan. 32 • Based upon the outcomes from the late 2017 engagement, the team will prepare the final UFSP in early 2018 and seek review and consideration from the community and advisory boards with PRAB having final acceptance of the plan likely in the first quarter of 2018. • Within the second quarter of 2018, staff will provide a comprehensive information packet to City Council outlining the full process and outcomes of the UFSP and include the final plan. VIII. CONCLUSION The City of Boulder’s urban forest and ecosystems are an integral part of its infrastructure. The city has over 650,000 trees, approximately seven trees per capita. However, given the significant open space in the community, this results in a canopy cover of approximately 16 percent. The city has also recently been impacted by a combination of factors that have dramatically impacted the city’s trees. Extreme weather events including huge temperature swings, floods, late snowstorms and the expected loss of approximately 25 percent of the canopy due to the Emerald Ash Borer, all contribute to a loss of canopy closure that the city must recover from over the next decades. Returning to current levels of canopy cover will require enormous action—both public and private. The current levels of tree planting—approximately 500 per year—will need to more than double to restore and increase urban tree cover. This will take unprecedented levels of collaboration between public land managers, private landowners and planners working on how we will respond and adapt to a climate change. For example, all untreated ash trees on both public and private property and naturalized areas along the creeks and ditches will likely die from EAB in the short term. Ash trees contribute more to the urban tree canopy on an individual tree basis than many other tree species as ash trees are large maturing, long-lived, and have large canopies. EAB will cause a loss of approximately 12% of Boulder’s trees (equal to approximately 25% of the urban tree canopy) over the next few years and will have a significant impact on the many environmental, aesthetic, and economic services provided by the urban tree canopy. However, EAB is not the only threat to Boulder’s urban forest. Other invasive insect and disease pests threaten the urban tree canopy as do individual severe weather events, overall climate change and development. The inevitable loss of ash trees also provides an opportunity to replace impacted trees with species that will be well suited to the hotter local conditions now expected due to climate change. Many EAB-related impact factors such as tree diversity, pesticide use, and wood utilization are also not unique to the current infestation and are applicable for other tree species and pests. To turn this loss into an opportunity to engage the public, Over the next few years, EAB management, including tree removal, tree replacement, wood disposal, and pesticide treatments is anticipated to have a significant direct budgetary impact to the City of Boulder and private residents. Additionally, the transforming tree canopy will have considerable economic, social, and environmental impacts for decades. EAB and the inevitable loss of many of the community’s ash trees has provided the city with an opportunity to create a more diverse urban forest over the long term through the development of a broader scope Urban Forest Strategic Plan (UFSP). The good news is that UFSP has allowed staff and the community to strategically create a path forward that will allow for a long-term sustainable urban forest by outlining many recommendations and implementation strategies that allow staff and the community to work together in these solutions. 33 ATTACHMENTS Appendix A – Summary of UFSP Community Engagement 34 MEMORANDUM TO: Environmental Advisory Board FROM: Planning, Housing and Sustainability Department: Lesli Ellis, Comprehensive Planning Manager Valerie Matheson, Urban Wildlife Conservation Coordinator Rella Abernathy, Integrated Pest Management Coordinator DATE: March 7, 2018 SUBJECT: Update on the City’s Ecologically-Based Integrated Pest Management Program ________________________________________________________________________ Background: Environmental stewardship is a core value of the City of Boulder. The city’s Integrated Pest Management (IPM) program uses an ecologically-based approach for the management of public lands and facilities. As ecosystems are becoming more and more stressed from climate change and declines in species, the IPM program is focusing less on direct control methods of individual undesirable species and more on enhancing biodiversity and ecosystem balance to utilize the natural processes that keep populations of undesired species low. These changes are reflected in the revised IPM policy, in the development of new programs and in the update of existing programs. IPM Policy: The city’s first IPM policy was adopted in 1993 and last updated in 2002. The IPM policy is currently being revised to incorporate program improvements, council direction and to place a stronger emphasis on ecosystem protection. The proposed revisions are included in the attached city council Information Packet memo (Attachment A of the attached memo). Pollinator Programs: The city is promoting pollinator protection and conservation through two citywide programs. One is Pollinator Appreciation Month, declared each September, that hosts a variety of events, including native seed collection on OSMP properties, guided hikes, pollinator habitat plantings, films, lectures, workshops and a large children’s festival, the Bee Boulder Family Festival. City staff across departments, including the Boulder Public Library, local NGOs, local companies, the University of Colorado and many volunteers work together to educate the public about the importance of pollinators for native plants and local food production. The city recently launched a new program, the Boulder Pollinator Garden Project, which will be promoted during Earth Week in April. These programs emphasize the importance of both urban and natural lands for pollinator conservation. Mosquito Management Program: The city is currently updating the mosquito management program, which was developed in 2003 in response to West Nile virus arriving in Colorado. The program was initially focused only on the mosquito species that can potentially transmit West Nile virus to people and was 35 designed to decrease the risk to people, while protecting the city’s wetlands as much as possible from the impacts of mosquito control. In 2007, the city expanded the program to treat limited areas for nuisance mosquitoes—or mosquitoes that present no health risk to people. This was in response to complaints from patrons at city recreational facilities and concerns about lost revenue. Some neighborhoods were added to the program in 2009. The mosquito program is currently being reviewed by ecologists and scientists from Parks and Recreation, Open Space and Mountain Parks, the Comprehensive Planning Division, and an environmental consultant. The assessment will include an analysis of the mosquito program data, and a scientific literature review of the efficacy and environmental impacts of mosquito control programs. This project is occurring in two phases and the full review of the program is expected to be completed in April 2019. More information is included in the attached February 1, 2018 Information Packet memo. Next Steps: • Staff will present the results of the first phase of the mosquito management program review to city council on April 3, 2018. • The final IPM policy revisions will be included in the April 3 council memo and then provided to the city manager for approval in May. Questions for EAB: 1. Does EAB have any feedback about the revisions to the IPM policy or the overall approach of the IPM program? 2. Does EAB have any particular issues, concerns or suggestions that you would like to be addressed during the mosquito program review? Attachment: Information Item: Ecologically-Based Integrated Pest Management: Policy Revision, Mosquito Program and Pollinator Initiatives 36 INFORMATION PACKET MEMORANDUM To: Mayor and Members of Council From: Jane S. Brautigam, City Manager Jim Robertson, Executive Director of Planning, Housing and Sustainability Maureen Rait, Executive Director of Public Works Tracy Winfree, Director of Open Space and Mountain Parks Yvette Bowden, Direct or Parks and Recreation John Potter, Open Space and Mountain Parks Resources and Stewardship Manager Jeff Haley, Parks and Recreation Planning Manger Lesli Ellis, Comprehensive Planning Manager Don D’Amico, Open Space and Mountain Parks Ecological Systems Supervisor Valerie Matheson, Urban Wildlife Conservation Coordinator Will Keeley, Open Space and Mountain Parks Wildlife Ecologist Joy Master, Parks and Recreation Conservation Ecologist Rella Abernathy, Integrated Pest Management Coordinator Date: February 1, 2018 Subject: Information Item: Ecologically-Based Integrated Pest Management: Policy Revision, Mosquito Program and Pollinator Initiatives EXECUTIVE SUMMARY The purpose of this memo is to provide city council with an update for the city’s Integrated Pest Management (IPM) program within the context of a citywide ecosystems protection strategy, including 1) a draft of the proposed IPM policy revisions and a timeline for program components that are underway; 2) information about pollinator protection programs; and 3) a preview of a major update to the city’s mosquito management program. Most of these items are informational, except for the updates to the IPM policy and the mosquito management plan. Staff will be seeking advisory board input during February and March for the IPM policy changes and the mosquito management program review. Staff will provide this feedback to council on April 3, 2018, and will include a final revision of the IPM policy, the analysis for the first phase of the mosquito program review and seek direction for the second phase, which will take place over the next year and include a communications and public engagement strategy. Staff will then return in April 2019 with the results of the mosquito management program analysis with options and a staff recommendation for council consideration and direction. 37 FISCAL IMPACT The 2017 contract for mosquito control services was $252,516. Due to increasing costs, mosquito contracting services are projected to be $259,586 for 2018, with annual increases expected in future years if the program is continued as it’s currently structured. The mosquito management program review and analysis is requiring significant staff time and re-prioritization of work plan items. The ecological consultant fees are estimated to be approximately $50,000. COMMUNITY SUSTAINABILITY ASSESSMENTS AND IMPACTS • Economic: IPM-related programs create beautiful, safe and award-winning athletic facilities, parks, streetscapes, urban forest, natural lands, local food production, and recreational and outdoor activities, that provide revenue for the city and businesses, and generates tourism. Ecosystem services are more difficult to monetize, but protection and enhancement of healthy ecosystems supports a sustainable economy and saves money and resources by mitigating the impacts of climate change and reducing the costs from extreme weather events. • Environmental: Protection of plants, wildlife and biodiversity reduces reliance on chemical pesticides and enhances overall environmental quality. Pesticides are implicated in widespread species decline and are associated with health issues in people, particularly children. The city’s IPM program improves the health of the community and the surrounding lands and waterways by reducing chemical inputs, utilizing ecologically-focused management, and restoring and protecting healthy ecosystems. • Social: A healthy and safe environment encourages the public to go outdoors and participate in recreational and athletic activities, interact with nature and improves overall well-being. BACKGROUND Boulder has a long history of environmental stewardship and a legacy of protecting its land and resources for future generations by forward-thinking, scientifically-based and cutting-edge approaches. The city’s Integrated Pest Management (IPM) program has exemplified these principles since its inception in the late 1980’s, when open space employees began exploring methods for non-chemical management of weeds due to concerns about the overuse of herbicides. This led to a citywide IPM program with an ecologically-based approach as its foundation. History of IPM IPM was first developed in response to the problems that arose from the post-World War II use of pesticides. The insecticide, DDT (dichloro-diphenyl-trichloroethane), was a game-changer during the war and prevented the deaths of soldiers from insect-borne diseases like typhus and malaria. DDT was extremely toxic to insects and seemingly safe for people. This led to widespread use after the war in every sector of society, including agricultural and urban areas, in home gardens, inside houses and on people. However, the downsides became apparent when DDT lost its effectiveness as mosquitoes became resistant to it and agricultural pest populations exploded from resistance or from the removal of pest predators that were susceptible to DDT. From Rachel Carson’s “Silent Spring,” the public and the government became aware of how DDT was contaminating the entire food chain, resulting in catastrophic environmental problems and threatening birds and other animals with extinction. 38 The IPM methods developed in the late 1950’s sought to reverse the damage caused by the widespread use of DDT and other pesticides, and focused on restoring the natural function of the food web by rebalancing biodiversity, and applying pesticides only after pests reached a “threshold,” where natural factors weren’t sufficient to keep pests in check and pest damage caused economic loss. When preventive principles are used, such as crop rotation, building healthy soils, and providing floral resources for pollinators and natural predators, pesticide intervention is often unnecessary. IPM in Boulder Boulder’s IPM program is based on the principles that were developed by the scientists who pioneered IPM in the 1950’s. IPM is a dynamic, decision-making process that is based on the best available science, and relies on observation and knowledge of the target organism and the ecosystem where it lives. This fact sheet summarizes the city’s approach to IPM. The city defines IPM as: A decision-making process that selects, integrates, and implements a combination of suitable and compatible strategies to prevent, deter, or manage pest populations within established thresholds. IPM uses a "whole systems approach,” viewing the target species as it relates to the entire ecosystem. Management strategies are chosen that minimize impacts to human health, the environment, and non-target organisms, and protect overall biodiversity and ecosystem health. Relevance of IPM Today When the unintended consequences of DDT became evident, it was banned in 1972. DDT is highly persistent and it and its breakdown products are still found today in the environment and in our bodies. New pesticides were developed to replace DDT, and as problems arose with those products, new families of pesticides were developed. At the time, each of these types of pesticides were considered a big improvement over the previous generation of products. But each new group of insecticides—the organophosphates, carbamates, pyrethroids, and more recently, the neonicotinoids—have created their own ecosystem-wide issues that are contributing to global declines in pollinators and all other animals. Pesticide contamination is found throughout the earth from the artic to the oceans. These chemical stressors in combination with habitat loss from expanding agriculture, urbanization, mineral and fossil fuel extraction, other human-based activities, and climate change have led to extensive losses of biodiversity. The 2016 Living Plant Report from the World Wildlife Federation shows that between 1970 and 2012, 58 percent of mammals, birds and fish populations were lost, with the biggest decline in freshwater species, which dropped by 81 percent. In addition to the precipitous decline of pollinators, all other insects around the world are in steep decline. The current rate that species are undergoing extinction is altering the planet, the consequences of which are not yet understood. A diversity of organisms is crucial for functioning ecosystems. All life on the planet is sustained by the “ecosystem services” that healthy ecosystems provide, such as food and fiber, clean air and water, and climate regulation. 39 (©Peter Burgess, True Value Metrics) Ecosystem Services and Climate Change With changing climate, there are winners and losers among the different species that make up our ecosystems. Some will adapt and remain, some will migrate to new locations and some will go locally extinct. The invasion of exotic and invasive species compromises these already stressed systems, altering or degrading ecosystem services, and requires a thoughtful and cautious approach for managing invasive species without inadvertently causing more harm to desirable organisms and their interactions with other species of the ecosystem community. City Programs Staff across city departments are working together to develop programs and practices that protect and maintain ecosystem function in open space, agricultural and urban areas. The role of urban ecosystems is often overlooked. Urban ecosystem habitats within cities are now recognized to be increasingly important in supporting populations of plants and wildlife, as well as providing corridors for migrating species. Ecosystems also sequester carbon and are a critical element in efforts to mitigate and lower greenhouse gases. A recent study suggests that the world’s wetlands, forests and grasslands could provide up to a third of the carbon sequestration required to keep global temperature rise within 2°C by 2030. But equally important is the role that diverse, highly-functioning ecosystems serve in providing resilience from the unpredictable conditions of extreme weather and natural disasters that are expected to increase as a result of global warming. Therefore, protection of ecosystems and the creation of high-quality habitat is crucial for a comprehensive and successful climate action plan. 40 In 2018, a cross-departmental team of environmental planners are working on the development of an integrated ecosystems management strategy that can address increasing environmental threats and build on opportunities to enhance ecosystems and ecosystem services in and around the city. IPM is a crucial part of this strategy, since all city properties from streets, parks and bikeway landscaping to restoration and protection of natural properties and agriculture are managed using IPM. The following section will provide information about IPM programs and current work within this context. A major update is underway for the city’s mosquito management program, and detailed information is included as preparation for this project. ANALYSIS I. IPM 1. IPM Policy This year marks the 25th anniversary of the city’s IPM policy. The city first adopted a formal IPM policy in 1993 and updated the policy in 2002. The IPM policy is currently being revised to incorporate program improvements and council direction since the 2002 update. The impetus for the developing the original IPM policy in 1993 was reducing, and where possible, eliminating pesticides, and requiring an ecologically-based approach for managing target species. That language was retained in the 2002 policy, and is also kept in the 2018 revision. The IPM policy provides guidance for the management of all city properties, including landscape, natural area, agricultural and facilities. It also directs staff to provide education and outreach to the public regarding best practices that protect ecosystems, such as IPM, pesticide reduction strategies, and pollinator protection. A proposed revision of the IPM policy is attached, including strike-out and clean versions, along with the rationale for changes (Attachment A). The major changes that occurred in 2002 and are proposed for 2018 are listed below. Past and Current Changes to IPM Policy: 2002 IPM Policy Revisions: • IPM coordinator role added; • Reporting responsibilities specified; • Contractor requirements strengthened; • Department head approvals required for most toxic EPA pesticide categories; and • Departmental IPM plan deadlines incorporated. 2018 IPM Policy Proposed Revisions: • A comprehensive, citywide IPM operations manual replaces individual department or work group IPM plans; • Incorporate pesticide assessment and approval process; and • Language is strengthened to emphasize ecosystems/biodiversity protections. 2. IPM Program Improvements IPM Operations Manual The 1993 and 2002 IPM policies required each department or division to develop an IPM plan. This requirement was never fully achieved and also has the potential to lead to silos among 41 workgroups that manage properties/facilities with similar practices. A comprehensive IPM operations manual incorporates the information contained in individual IPM plans and will encourage collaboration, problem-solving and innovation. This document will provide the background, information and direction for all city IPM strategies and procedures. It will serve as a guide for IPM staff, contractors and lessees. It will also provide information and links for other environmental programs and master plans. The IPM operations manual is currently being developed by staff. The first phase will be posted on the city’s website by the end of 2018. It will be a living and dynamic document that will be updated regularly with new information and procedures. Pesticide Assessment Process The pesticide assessment process will be included in the IPM operations manual. Staff only considers the use of a pesticide as a last resort after following the IPM process. If a pesticide is used, it must be on the approved pesticide list or undergo a screening process that complies with the IPM policy. Pesticides are assessed using regulatory data from the U.S. and other countries, as well as relevant studies in the academic literature. Pesticides are evaluated for potential impacts to human health, non-target organisms and environmental fate (e.g. persistence in soil and water, ability to leach, breakdown products of concern, etc.). Products are then ranked with criteria that places them in a “hazard tier” from least toxic to most toxic. In addition, usage guidelines are developed to minimize the impact of any chemical application. II. Pollinator Programs Approximately 80-95 percent of the plants in natural areas require pollination. These plants are the foundation of food webs and pollination is an essential ecosystem service. Colorado is home to over 950 species of wild bees and more than 550 species live in Boulder County. Native bees come in all shapes and sizes and live in a range of environments from grassland to alpine forests. Most are solitary ground-nesting species and others live in hollow twigs, logs and snags. Little is known about the fate of the majority of these species, but experts who study population trends are seeing steep declines in the majority of bee species. Bees need safe, pesticide-free flowers of different types that bloom all season long. The city officially banned the use of neonicotinoids on public properties in 2015 due to the comprehensive body of scientific literature that conclusively shows harm to pollinators, aquatic insects and other animals from their use. Staff across departments are creating pollinator gardens, collecting native plant seed, restoring habitat, offering workshops and providing education to the public about pollinator protection. 1. Pollinator Appreciation Month The city has declared September as Pollinator Appreciation Month annually since 2015 to celebrate the importance of pollinators and provide information to the public. The city partners with the University of Colorado, local NGOs and volunteers to offer a variety of events, culminating in the Bee Boulder Family Festival, which is attended by hundreds of children, who learn about the importance of pollinators with fun and creative activities. 42 2. Boulder Pollinator Garden Project The Boulder Pollinator Garden Project is a new program to encourage the creation of high quality pollinator habitat throughout Boulder, both on public and private properties. The city will be mapping pollinator habitat in parks, open space and other city-owned properties and reaching out to other public entities to share and map their habitat. Home and business owners and other residents are encouraged to map their yards and gardens. The long-term goal for this program is to coordinate the efforts of local organizations and individuals to create pollinator pathways and connections to open space that will establish Boulder as a pollinator haven that supports bees, butterflies, beetles, hummingbirds and other pollinators and native wildlife. III. Mosquito Management Program This section contains more information than the other sections in this memo to prepare staff, advisory boards, council and the public for the update to the city’s mosquito management program. The city’s mosquito management program was progressive, innovative and cutting edge at the time it was developed. It changed mosquito industry practices and risk estimates for West Nile virus (WNv). Therefore, when evaluating the program and determining the next steps, a review of the history of the program is important for understanding the initial objectives and how the program can be improved in alignment with current city goals and policies. A. Current Program West Nile Virus Prior to 2002 when West Nile virus (WNv) first arrived in Colorado, the city didn’t have a mosquito control program. WNv was first reported in New York in 1999 and then quickly spread across the country, arriving in Colorado in 2002. By 2003, Colorado had the highest number of human WNv cases and deaths in the county. Since that time, WNv human cases have decreased significantly, but the disease is now endemic across the country and present at some level every year. When the city created its first mosquito management plan to address WNv, the mosquito industry standards were not compatible with the city’s IPM policy and ecologically-based principles for management of natural lands, where the majority of mosquito larval sites on city- owned land occur. Instead of a mosquito control contractor, the city hired an ecological consultant with expertise in aquatic entomology and wetlands ecology to develop a plan that would protect public health and address the risk from WNv, while protecting the city’s ecosystems and wetlands as much as possible. Industry vs. City’s Approach The mosquito control industry uses a wide range of pesticides to attack every stage of the mosquito lifecycle – the larva, pupa and adult. Adulticides target the adult mosquito and are broad-spectrum insecticides that are applied to vegetation where adult mosquitoes rest, by truck through city and neighborhood streets or by airplane or helicopter. Studies show that very little of the product actually reaches the target mosquito, and only reduces a portion of the mosquito population, which can quickly rebound. These products, however, harm non-target insects such as pollinators and other animals, and are associated with human health problems. 43 City’s Program Changed Industry Standards In 2002, CDC (Center for Disease Control) and the mosquito control industry standards recommended spraying adulticides if mosquito traps caught a certain number of mosquitoes regardless of whether the species of mosquito could transit disease or if they were infected with WNv. While the city was under pressure from the CDC, state and county authorities to spray city streets during the peak of the WNv epidemic, the grid of adult mosquito traps located throughout the city indicated that there were not enough mosquitoes infected with WNv to warrant fogging city streets. The city chose not to spray, based on data and risk analysis. The industry and the CDC eventually adopted the city’s approach of using the appropriate mosquito species and disease infection rate before making recommendations to spray for WNv. During the design of the city’s WNv management plan, the consultant created the Vector Index, which was developed from 2003 City of Boulder data. The Vector Index provides an early warning tool for estimating elevated risk of WNv transmission to people. The Vector Index has since been adopted around the country as the standard method for assessing WNv risk to the public. The city manager and staff used fact-based information to inform decisions that protected the public from needless pesticide exposure. Focus on Larval Control The city also developed a more environmentally-sound approach for controlling mosquito larvae. Accurate mapping of mosquito breeding sites—where the female mosquitoes lay their eggs and the larvae develop—is an important component of large-scale mosquito management programs. There are a number of larvacides—products that are targeted towards the larval stage of the mosquito life cycle. They range from nonselective oils that affect all aquatic organisms, to growth regulators that affect all insects, to products that are specific to mosquito larvae and closely-related species. Even the most targeted product, which the city uses, Bacillus thuringiensis israelensis or Bti, is not benign. It will kill all species of mosquitoes, whether or not they are disease carriers or human pests. Bti also kills non-target midges and blackflies, all of which are important members of wetland ecosystems. During the larval stage, mosquitos are filter feeders with an important ecological niche in wetlands. They eat decaying organic matter, bacteria, fungi, and other microorganisms. They are also important food sources for predatory insects, fish, amphibians and other animals. Greatly reducing a major wetland food source, can have cascading impacts to other organisms in the wetland community. Adult mosquitoes are food sources for bats, birds, reptiles and amphibians. Mosquitoes feed on flower nectar and some act as pollinators. Disturbances, alterations to naturally-occurring biodiversity from insecticides and other inputs into wetlands harm ecosystem health. Fully- functioning wetland ecosystems naturally lower mosquito populations, and can lower the risk for disease. Highly-functioning wetlands provide important ecosystem services that sequester carbon and help to buffer the impacts from flooding and extreme weather events. To limit the impacts of Bti to city wetlands, the city developed a monitoring protocol for the 2006 WNv mosquito management plan where mosquito larvae are examined in the field, and the site is only treated with Bti if vector species are present— species that can potentially transmit disease. By targeting only vector species, it decreases the amount of Bti applied to city wetlands. 44 The Role of the Public in Reducing West Nile Virus Risk The species of mosquitoes that can potentially transmit WNv commonly breed in urban areas and peoples’ yards—often in non-natural areas, like clogged gutters, containers, bird baths, over- watered areas in yards, old tires and poorly-drained depressions. The city, county and state authorities provide education about the crucial role that the public plays in reducing WNv risk by removing breeding sites from their own properties. Education also emphasizes the importance and personal responsibility for avoiding mosquito bites by using mosquito repellents. B. Reviewing and Updating the City’s Mosquito Program 1. Mosquitoes that Potentially Transmit Disease The city’s West Nile virus (WNv) management plan was created in 2006 when WNv was new to the area. The objectives for the 2006 plan were to reduce the risk for WNv to the public, while protecting wetlands and ecosystem health as much as possible. Since 2006, the public health risk from WNv is better understood and multiple studies have been published by independent scientists that examine a range of issues that pertain to mosquito management, human health and the impacts of mosquito treatments on ecosystem health. This literature will be reviewed to determine the pros and cons of different approaches to mosquito control. 2. Nuisance or Non-Disease Carrying Mosquitoes In 2007, a pilot nuisance control mosquito program was launched due to complaints of patrons at city recreational facilities. Neighborhoods with high mosquito activity requested to be included and some areas were added to the program. Due to concerns from additional Bti application to wetlands, a threshold was established for non-disease carrying/nuisance mosquito species to reduce the number of treatments and impacts to wetlands. Council directed staff to continue the nuisance program in 2011, using an adaptive management strategy. Nuisance mosquitoes were not initially included in the city’s program, because they pose no public health threat, are integral components of the food chain, and it allowed some portion of the city’s wetlands to be left undisturbed from larvicide impacts. Many nuisance mosquito larvae were already controlled through the WNv program when they live in the same larval breeding sites as vector larvae. The objectives for initiating a program for the treatment of nuisance mosquitoes were: 1. Reduce complaints from patrons at recreational facilities, including the ball fields, golf course and the reservoir; 2. Address concerns of specific neighborhoods that experience high mosquito activity; and 3. Reduce insecticide fogging by Boulder County in neighborhoods adjacent to city-owned natural properties with mosquito breeding sits When the nuisance program began, there were concerns at the time about potential revenue loss from fewer patrons using city facilities due to high mosquito activity. Another concern was the health and environmental impacts from Boulder County’s mosquito control program that applies adulticides for nuisance mosquitoes in unincorporated neighborhoods that are adjacent to city open space properties. The county agreed to raise the threshold for spraying from 100 mosquitoes in a trap to 250 in certain areas if the city would agree to treat nearby larval sites for nuisance mosquito larvae. Besides the exposure of the public to adulticides, the city had concerns 45 about insecticide drift onto open space properties that could contaminate water and harm non- target species. C. Mosquito Program Evaluation, Analysis and Timeline The city has a rich dataset stretching back to 2003, which includes larval density at all mapped larval breeding sites for two categories of mosquito larva - vector (species that can potentially carry and transmit WNv) or non-vector or nuisance/floodwater species. The city also has adult mosquito trap data, WNv mosquito infection data and a large number of ecological studies conducted on Open Space and Mountain Parks and Parks and Recreation natural areas. A staff team of ecologists, wetland biologists, entomologists and wildlife experts from Open Space and Mountain Parks, Parks and Recreation, and Planning, Housing and Sustainability, and an ecological consultant, OtterTail Environmental, will work together to over the next year to evaluate the current mosquito management program. The team will: • Review and analyze the city’s larval and adult mosquito data; • Collect data from the county and state for mosquito population and WNv patterns; • Conduct literature reviews; • Consult with expert scientists; • Assess the efficiency and efficacy of both the WNv and nuisance mosquito control programs; • Assess the environmental impacts of the programs, particularly in light of the city’s climate action and resilience goals; • Determine if original program objectives have been met; and • Provide recommendations for updates to field protocols and program objectives. The work will be conducted in two phases. Phase I will address items that need to be in place before the 2018 field season begins. Phase II will complete the analyses and recommendations for updating the program. PROJECT TIMELINES I. IPM Policy and Program Feedback from advisory boards, relevant city working groups and public input will be gathered through the end of March. The final IPM policy revisions will be included in the April 3 council memo and then provided to the city manager for approval by April 15. Staff will post the first phase of IPM Operations Manual, including the pesticide approval process, by the end of 2018. Work will continue on individual program areas during 2019. II. Pollinator Programs The Boulder Pollinator Garden Project is being promoted through Earth Week events in April. Staff are coordinating with the University of Colorado and NGOs to develop outreach and neighborhood organizing efforts to create and map pollinator gardens on private property, and map city and other public land pollinator habitat. 46 City inter-departmental staff, partners and volunteers are planning Pollinator Appreciation Month events, including the Bee Boulder Family Festival, which will take place on September 29, 2018 in Central Park. III.Mosquito Program Update The mosquito management program will be reviewed in two phases with the following items: Phase I (January – April 2018): •Describe the process for monitoring and treatment of mosquito larval breeding sites in wildlife closures; •Evaluation of the threshold and treatment protocols for non-vector (nuisance) mosquitoes for the 2018 season; and •Develop a WNv outbreak emergency response plan Phase II (April 2018 – April 2019): •Data analysis for WNv and non-vector mosquito management programs for efficacy and ecological impacts; •Review and options for larval site management procedures and review of current site categories for monitoring and treatment; •Adaptive management approach to address challenges from climate change; •Implementation of communications and public engagement plan; •Options and staff recommendation for changes to mosquito management plan; and •Report and presentation to city council in April 2019 to provide results of program assessment and determine direction for the city’s mosquito management program. NEXT STEPS •The team reviewing the city’s mosquito management plan will complete Phase I components and provide this information to council on April 3, 2018. •The Open Space Board of Trustees (Feb. 14, 2018), Parks and Recreation Advisory Board (Feb. 26, 2018), and Environmental Advisory Board (March 7, 2018) will be provided with the information included in this memo and board feedback will be included in the April 3 memo to council. •Staff will solicit feedback on the proposed IPM policy revisions and the final revisions will be included in the April 3 memo. ATTACHMENTS Attachment A: Proposed Integrated Pest Management Policy Revisions 47 Attachment A: 2018 Integrated Pest Management Policy Revision A draft of the proposed revisions to the IPM policy with the changes incorporated is included. A version with track changes is also attached, which includes comments with an explanation for substantive changes. Major revisions include: 1. Since 2002, the city has implemented a pesticide approval process (IPM Task Force and more recent council direction to implement hazard tier list). This direction is incorporated into relevant sections and obsolete language is removed. 2. The word, “control” is replaced with “management” in most instances throughout the document to better represent the city’s holistic ecosystem management approach and IPM practices vs a pest-centric approach. 3. Departmental IPM plans are replaced with a citywide IPM Operations Manual. The Operations Manual provides a framework for entire IPM Program. Specific IPM practices of city departments will be incorporated. 4. Some sections are clarified by simplifying or re-organizing wording. 5. “Short and long-term” is added to emphasize importance of considering full impacts of decisions. 6. The “interdepartmental IPM Review Group” is changed to “Interdepartmental IPM Team” since this describes more accurately how the city IPM team functions. 48 CITY OF BOULDER *** POLICIES AND PROCEDURES INTEGRATED PEST MANAGEMENT POLICY EFFECTIVE DATE: April 15, 2018 _________________________ Jane S. Brautigam, City Manager I. SCOPE AND APPLICATION This Integrated Pest Management (IPM) policy applies to all pest management activities conducted by all city staff, contractors and lessees, which includes all monitoring, non-chemical pest management practices and any pesticide use in buildings and related facilities; grounds and open space; and other property owned or managed by the City of Boulder. II. PURPOSE The purpose of this policy is to provide guidelines for implementation of the most environmentally- sound approaches for landscape, natural area, agricultural and facilities management and to reduce and eliminate, where possible, the volume and toxicity of chemical pest control treatments. The overarching goal is for all city IPM practices to be carefully assessed for the potential impacts to human health, water quality, non-target organisms, and the preservation and/or enhancement of biodiversity, particularly federal endangered and threatened species, and state, county and local species of concern. As a result, ecologically-based IPM approaches will be developed that promote the stability of desirable species and discourage pest populations, while sustaining the natural balances within the ecosystem. 49 III. DEFINITIONS A. Integrated Pest Management (IPM): a decision-making process that selects, integrates, and implements a combination of suitable and compatible strategies to prevent, deter, or manage pest populations within established thresholds. IPM uses a "whole systems approach," viewing the target species as it relates to the entire ecosystem. Management strategies are chosen that minimize impacts to human health, the environment, and non-target organisms, and protect overall biodiversity and ecosystem health. B. Pest: broadly, a pest is an organism that interferes with or reduces the availability or quality of desirable plants and other resources; impacts human or animal health; damages structures; or harms some component of the ecosystem. Whether or not an organism is considered a pest can depend on the setting, rather than the particular species. A pest may be an insect, rodent, nematode, fungus, weed, or any other form of terrestrial or aquatic plant or animal life or virus, bacteria, or other micro-organism (except viruses, bacteria, or other micro-organisms on or in living man or other living animals). C. Pesticide: any substance or mixture of substances intended for killing or repelling any pest. This includes without limitation fungicides, insecticides, nematicides, herbicides, and rodenticides and any substance or mixture of substances intended for use as a plant regulator, defoliant, or desiccant. In addition to applications of pesticides, products that have been pre-treated with pesticides are subject to this policy. Plants that have been genetically modified to incorporate pesticides or are resistant to pesticides are prohibited unless an exception has been granted by the city manager. The following products are not pesticides: 1. Deodorizers, bleaching agents, disinfectants and substances for which no pesticidal claim is made in the sale or distribution thereof, and 2. Fertilizers and plant nutrients. D. Reasonable Alternative: a feasible option for pest management, which takes into account the short and long-term economic, social, and environmental costs and benefits of the proposed choices. IV. CITY IPM COORDINATOR The city manager has determined that a central staff person will coordinate the IPM efforts of city departments. The IPM coordinator’s responsibilities include, but are not limited to the following: • Coordination with city departments on weed and pest management issues and integrating IPM principles with other environmental policies and plans; • Publication of IPM reports; • Coordination of an interdepartmental IPM team; • Development of a city weed management plan, in accordance with state law; 50 • Development and maintenance of pesticide approval process(es) and pesticide reduction guidelines; • Coordination of the development and update of an IPM operations manual; • Research and recommendations for IPM strategies; • Development and administration of the city’s mosquito management policy and program; • Assistance to city departments with staff training needs; and • Outreach to residents regarding IPM, pollution prevention and pesticide reduction strategies, pollinator protection and natural lawn and gardening practices. A. IPM Reports. The city IPM coordinator will compile the data from all participating city departments from the information listed in Section V, Departmental/Divisional Obligations. This information will be provided in reports and/or posted on the city’s website. Comprehensive reports will be submitted to the city manager and city council and will include IPM-related data, a review of new IPM strategies, arising challenges, IPM program or departmental accomplishments, and IPM program coordination with other city programs and initiatives. B. Interdepartmental IPM Team. This team will be coordinated by the city IPM coordinator and will include department IPM coordinators, managers and other key city staff. The team will meet at least quarterly and meetings will include development of city IPM goals and strategies, review and evaluation of the IPM operations manual, as well as opportunities for information exchange, education and collaboration. This team will also review interdepartmental issues, and make policy recommendations that advance the objectives of the IPM policy and reduce reliance on chemical pest control. V. DEPARTMENTAL/DIVISIONAL OBLIGATIONS All departments/divisions that conduct pest management operations and/or use or potentially use pesticides are required to fulfill the obligations of this section. A. IPM Operations Manual. The IPM operations manual (manual) will serve as a guide for all pest management operations and will provide rationale and procedural guidelines for the implementation of the IPM policy. All persons conducting pest management within the scope of this policy are required to follow the manual. Departments or divisions will provide information to the city IPM coordinator and the IPM interdepartmental team to contribute towards the creation, review and update of the manual. The manual will be reviewed annually and a record kept of any revisions. Departments will designate at least one staff member as the departmental/divisional representative who will be responsible for providing information and input concerning the manual. 51 B. Record-keeping and Evaluation. Each department, division or work group must keep accurate records and results of all IPM treatments. Information on all treatments (including non-chemical) will include how, when, where and why the treatment was applied and the name of the applicator. This information will be compiled for IPM reports. The city IPM coordinator will review pest management strategies with city departments and the IPM interdepartmental team to evaluate results, share information with other staff and improve the IPM program. Application records will be made available to the public upon request in accordance with all applicable state laws governing public access to information. C.Contractor Notification. Every department bidding out contractual work for pest management must inform all bidders about the requirements of the IPM policy and incorporate its guidelines in bid specifics. If pesticides are applied, only those products may be used that are part of the approved pesticide list and adhere to its use guidelines OR are in accordance with a pesticide assessment and selection process approved by the city manager in compliance with the protocols and guidance of the IPM operations manual and/or are reviewed and have prior approval by the department and its division representative and the city’s IPM coordinator. The city will inform pest management contractors of the city’s IPM Policy and operations manual and provide a written copy of this policy and other relevant documents as appropriate. Project managers, departmental IPM representatives, or the city IPM coordinator must approve all pest management treatments. VI. IPM PROCEDURE The city assumes that all pesticides are potentially hazardous to human and environmental health and will take measures to avoid any non-essential use. Therefore, reasonable non-pesticide alternatives will be given preference over chemical application by following the IPM procedure. City staff will evaluate alternatives to chemical treatments, including the cost-effectiveness of the treatments. For all pest control activities, the IPM procedure outlined below must be followed. A.Initial Data Collection, Mapping and Monitoring. Each department or division considering management of a target species should first collect baseline data on the pest ecosystem(s) to determine if the organism is truly a pest that warrants treatment. This data includes the pest population(s) occurrence, size, density and presence of any natural enemy population(s); gather information on pest biology and site ecology, and different control techniques available; and document sensitive areas and conditions that may limit control options. Data should be collected in a standardized manner that is repeatable. 52 For structural pests, inspection and monitoring should be conducted to determine and eliminate route of entry, potential food and water sources, and nesting sites. This information should be logged. Ranking, inventory, mapping, monitoring and evaluation are methods used for determining pest management priorities. Maps and inventories depict infestations in terms of pest species, size, location and threats to resources. Departments/divisions must monitor infestations or pest populations and evaluate treatments over time to assess the effectiveness of various treatment strategies and their effects on target and non-target organisms, the overall biodiversity of each site and the desired management objectives. These objectives should be reevaluated over time as the range and distribution of different species is altered from climate change and other anthropogenic factors All monitoring methods and data must be specified in departmental or divisional IPM procedures and included in the IPM operations manual, systematically recorded, and available for review. Departments should coordinate and utilize standardized mapping and data recording protocols, if possible. B. Establishing Threshold Levels. To determine if treatment is warranted, an acceptable threshold level of treatment for each target species and site should be established based on the ecology of the pest and either its density that creates environmental, aesthetic or economic damage or based on a measurement of the damage resulting from the pest. Departmental IPM procedures will include the threshold levels for common pests, determined by individual work groups, and may be developed in consultation with the city IPM coordinator and interdepartmental team. In some cases, a threshold, such as eradication, suppression, or containment may be required by federal or state law. C. Management Selection Criteria. Upon determining that management for an undesirable species is necessary, the following criteria should be used to help select the appropriate IPM treatment strategy: 1. Least-disruptive of naturally occurring controls; 2. Least-hazardous to human health; 3. Least-toxic to non-target organisms; 4. Least-damaging to the general environment, surface and ground water, and overall ecosystem function and stability; 5. Most likely to produce a permanent reduction in the environment's ability to support target pests; and 6. Economic and environmental cost-effectiveness in the short- and long-term. 53 D.Management Strategies and the IPM Hierarchy. Each department or division, in consultation with the city IPM coordinator, IPM team and/or guidelines of the operations manual, will make its own determination about appropriate and effective management approaches, based on site-specific requirements and condition. Commitment to the most environmentally-sound approach is expected, relying primarily on non-chemical methods. Prevention, cultural control, mechanical control, biological control and chemical control are the techniques used in the hierarchy of integrated pest management. In general, a combination of compatible treatments is more effective than a single approach. Department and division staff are encouraged to seek out and experiment with innovative IPM treatments (and combinations of treatments) and share this information at the interdepartmental IPM team meetings. The following treatments are listed in the order in which they should be executed: 1. Prevention. This is the most effective and important pest management strategy and is the foundation of IPM. By reducing the capacity of the ecosystem to support target pest populations through design and appropriate management, the opportunities for pest establishment can be reduced to tolerable thresholds or eliminated. Some examples are: a)Strategies that reduce the preferred harborage, food, water or other essential requirements of pests; b) Promoting healthy soils and ecosystems to withstand pest infestations; c)Weed-free materials and equipment for road and trail construction and maintenance. d) Landscape and structural design that is appropriate to the specific habitat, climate and maintenance the area will receive; and e)Project design that considers the potential impacts of pests and mitigates through the use of appropriate landscape design (plant choice, soil preparation, water requirements, weed barriers, etc.). 2. Cultural. Cultural control is the use of management activities that can prevent pests from developing or keep them below tolerable levels by enhancement of desired conditions. Examples include: a)Selection and placement of materials that provide life support mechanisms for pest enemies and competitors; b) Modification of pest habitat by reducing pest harborage, food supply and other life support requirements; c)Vegetation management including irrigation, mulching, fertilization, aeration, mowing height, seeding, pruning and thinning; d) Waste management and proper food storage; e)Barriers and traps; f)Heat, cold, humidity, desiccation or light applied to affected regions; and g)Prescribed burning or grazing. 54 3. Mechanical. Mechanical control is accomplished by using physical methods or mechanical equipment to control pest infestations, such as: a) Mowing or weed-whipping; b) Prescribed burning; c) Hand-pulling of weeds; d) Hand-removal of pests (e.g. insect or invasive amphibian egg masses). 4. Biological. Biological controls include the introduction or enhancement of natural enemy populations to target pests. Introduction of non-indigenous organisms has an associated risk factor and should be thoroughly evaluated prior to implementation in consultation with the city IPM coordinator and the interdepartmental IPM team. Biological methods include a) Conservation and augmentation of the pest's natural enemies; and b) Introduction of host-specific enemy organisms 5. Chemical. Chemical control of pests is accomplished by using chemical compounds registered as pesticides. All pesticides shall be assumed to be potentially hazardous to human and/or environmental health. The type, methods and timing of any chemical treatment will be determined after consideration has been given to protection of non-target organisms (including threatened or endangered species), the impact on biodiversity, protection of water quality, pest biology, soil types, anticipated adverse weather (winds, precipitation, etc.) and temperature. Only those pesticides that have been evaluated and approved for use on city properties by a process approved by the city manager may be applied. Application of any pesticide must follow the guidelines for that particular product, which will be provided to staff, contractors or lessees and include information pertaining to target pests, application methods and any other restrictions. All pesticides must be applied in conformance with label specifications and all applicable federal, state and municipal laws, regulations and ordinances, as well as any additional restrictions provided in city guidance documents. All pesticide applications must comply with the appropriate pre and post-notification requirements, according to the City of Boulder’s Pesticide Ordinance (Section 6-10-1 B.R.C. 1981). For all city pesticide applications, notification will be posted at the site at least 24 hours in advance, remain on site for at least 24 hours, and posted on the city’s hotline. This includes soil and trunk injections, spot spraying, hand-wicking and broadcast spraying on all city lands or property. E. Education. Education is a critical component of an IPM program. The city IPM coordinator will include IPM information on the city’s website. Information will include IPM reports, the IPM operations manual and pesticide assessment processes, recommendations for the most ecologically-sound pest management for residents, and IPM-related events and educational opportunities across the city. 55 VII.CONTRACTOR REQUIREMENTS The City periodically enters into contracts that authorize pest management, such as for building maintenance, project construction and maintenance, and weed and insect control. When the city signs a new contract or extends the term of an existing contract with a contractor that conducts IPM-related work, including the application of pesticides, the department must ensure that the work is in compliance with existing IPM guidelines or consult with the city IPM coordinator to develop procedures that comply with the IPM policy. The contractors must comply with appropriate pre and post-notification requirements, according to the City of Boulder’s Pesticide Ordinance (Section 6-10-1 B.R.C. 1981) and relevant internal city protocols, such as providing timely information to post the application on the city’s pesticide hotline. VIII.CONSTRUCTION AND INTERPRETATION Employees who have questions concerning possible conflict between their interests and those of the city, or the interpretation and application of any of these rules, should direct their inquiries to their department director. The department director may refer the matter to the city manager for final resolution. IX.EXCEPTIONS/CHANGE This policy supersedes all previous policies covering the same or similar topics. Any exception to this policy may be granted only by the city manager. This policy may be reviewed and changed at any time. Adopted 1993, updated April 2018. 56 CITY OF BOULDER *** POLICIES AND PROCEDURES INTEGRATED PEST MANAGEMENT POLICY EFFECTIVE DATE: April 15, 2018 April 24, 2002 _________________________ Ronald A. SecristJane S. Brautigam, City Manager I. SCOPE AND APPLICATION This Integrated Pest Management (IPM) policy shall applyapplies to all pest management control activities conducted by all city staff, contractors and lessees, which includes all monitoring, non- chemical pest management practices and any pesticide use in buildings and related facilities; grounds and open space; and other property owned or managed by the City of Boulder. and conducted by city staff or contractors. City officers, employees, and contractors are required to follow this policy. Departments that have employees monitoring or treating pest problems or managing any contractors who monitor and/or treat pest problems will receive a copy of the Integrated Pest Management policy. All pest control contractors will receive a copy of this policy. II. PURPOSE The purpose of this policy is to provide guidelines for implementation of the most environmentally- sound approaches for landscape, natural area, agricultural and facilities management and to reduce and eliminate, where possible, the volume and toxicity of chemical pest control treatments. The overarching goal is for all city IPM practices to be carefully assessed for the potential impacts to human health, water quality, non-target organisms, and the preservation and/or enhancement of biodiversity, particularly federal endangered and threatened species, and state, county and local species of concern. As a result, ecologically-based IPM approaches will be developed that promote the stability of desirable species and discourage pest populations, while sustaining the natural balances within the ecosystem. Commented [AR1]: Simplify and make more succinct. Commented [AR2]: Remove the word “control” in most instances to emphasize ecological approach of managing ecosystems. Commented [AR3]: Re-ordered to simplify and emphasize ecosystem protections. 57 The policy is intended to provide a basis for pest and vegetation management that will protect public health, as well as water quality, federal endangered and threatened species, and state, county and local species of concern. The goal of the city’s IPM policy is to utilize the most environmentally sound approaches to pest management, and to reduce and eliminate, where possible, the volume and toxicity of chemical pest control treatments. The objectives of this policy are to • require planning and development of an IPM program for all departments and • provide procedural guidelines for implementation. • 58 III. DEFINITIONS A. Integrated Pest Management (IPM): a decision decision-making process which that selects, integrates, and implements a combination of suitable and compatible strategies pest control strategies to prevent, deter, or manage control pest populations within established thresholds. Integrated Pest ManagementIPM uses a "whole systems approach", viewing looking at the target species as it relates to the entire ecosystem. In choosing control Management strategies are chosen that minimize , minimal impacts to human health, the environment, and non-target organisms, and protect overall biodiversity and ecosystem health are considered. B. Pest: broadly, a pest is an organism that interferes with or reduces the availability or quality of desirable plants and other resources; impacts human or animal health; damages structures; or harms some component of the ecosystem. Whether or not an organism is considered a pest can depend on the setting, rather than the particular species. .A pest may be an any insect, rodent, nematode, fungus, weed, or any other form of terrestrial or aquatic plant or animal life or virus, bacteria, or other micro-organism (except viruses, bacteria, or other micro-organisms on or in living man or other living animals) which the Administrator of the EPA declares to be pest under section 25(c)(1) [7 USCA 136w(c)(1)]. C. Pesticide: any substance or mixture of substances intended for destroying or repelling any pest. This includes without limitation fungicides, insecticides, nematicides, herbicides, and rodenticides and any substance or mixture of substances intended for use as a plant regulator, defoliant, or desiccant. In addition to applications of pesticides, products that have been pre-treated with pesticides are subject to this policy. Plants that have been genetically modified to incorporate pesticides or are resistant to pesticides are prohibited unless an exception has been granted by the city manager. The following products are not pesticides: 1. Deodorizers, bleaching agents, disinfectants and substances for which no pesticidal claim is made in the sale or distribution thereof, and 2. Fertilizers and plant nutrients. D. Reasonable Alternative: a feasible option for pest control management, which takes into account the short and long-term economic, social, and environmental costs and benefits of the proposed choices. IV. CITY IPM COORDINATOR The city manager City Manager has determined that there should be a central staff person will to coordinate the Integrated Pest ManagementIPM efforts of city departments. The IPM cCoordinator’s shall be in the Office of Environmental Affairs in the City Manager’s Office and responsibilities shall include, but are not limited to, the following items: • Coordination with city departments on weed and pest control management issues and Commented [AR4]: Key aspects of IPM included in definition – combination of strategies, establishing thresholds and additional language for ecosystem and biodiversity protections. Commented [AR5]: The purpose of this sentence is to convey that all organisms fit into the natural world and whether or not it’s considered a pest depends on context – e.g. native range, whether it’s interfering and competing with a human need or desire (perfect yard, nuisance mosquitoes, unblemished produce), etc. The “pest” needs to be considered within the ecological/broader context. Commented [AR6]: This would include insecticide-coated seeds and pre-treated plants, as well as organisms that have been genetically modified to incorporate pesticides into the plant or plants engineered with traits to resist pesticides. 59 integrating IPM principles with other environmental policies and plans; • Publication of the annual IPM reports; • Coordination of the an iInterdepartmental IPM team; Review Group • Development of a city weed management plan, in accordance with state law; • Development and maintenance of pesticide approval process(es) and pesticide reduction guidelines; • Coordination of the development and update of an IPM operations manual; departmental IPM plans • Research and recommendations foron IPM strategies; • Development and administration of the city’s mosquito management policy and program; • Assistance to city departments with staff training needs; and • Outreach to citizens residents regarding IPM, pollution prevention and pesticide reduction strategies, pollinator protection and natural lawn and gardening practices. A. IPM Reports. The city IPM coordinator will compile the data from all participating city departments from the information listed in Section V, Departmental/Divisional Obligations. This information will be provided in reports and/or posted on the city’s website. Comprehensive reports will be submitted to the city manager and city council and will include IPM-related data, a review of new IPM strategies, arising challenges, IPM program or departmental accomplishments, and IPM program coordination with other city programs and initiatives. A. Annual IPM Report. The City IPM Coordinator will compile data from all participating city departments and submit an annual report to City Council and the City Manager. The report will detail the previous year’s IPM efforts and shall contain information listed in Section V, Departmental/Divisional Obligations. Each department using pest control methods shall submit their information through their department IPM coordinator to the City IPM Coordinator. The report will include a review of new IPM strategies as well as trends in IPM techniques over time. B. Interdepartmental IPM Team Review Group. This group team will be coordinated by the cCity IPM cCoordinator and will include department IPM coordinators, managers and other key interested city staff. The teamGroup shall will meet at least quarterly and meetings will include development of annual Ccity IPM goals and strategies, review and evaluation of the IPM operations manualof each department or division plan, as well as opportunities for information exchange, education and cooperationcollaboration. The This Interdepartmental IPM Review Group shallteam will also review interdepartmental issues and make policy recommendations that advance the objectives of the IPM policy and reduce reliance on chemical pest control. V. DEPARTMENTAL/DIVISIONAL OBLIGATIONS The followingAll departments/divisions that conduct pest control management operations and/or that use or potentially use pesticides are required to fulfill the obligations of this section.: • Downtown and University Hill Management Division (including Parking Services) • Fire • Housing and Human Services Commented [AR7]: Staff is working on a process to gather IPM data consistently across departments for annual reporting. Staff is also assessing new formats to provide a digital living document that can replace a formal paper report and be more accessible to the public. 60 •Open Space/Mountain Parks •Parks and Recreation (including Athletics, Boulder Reservoir, Environmental Resources, Flatirons Golf Course, Forestry, Recreation Centers and Urban Parks) •Public Works (including Airport, Facilities and Asset Management (FAM), Greenways, Transportation & Utilities Maintenance and Water & Waste Water Treatment Plants) A.IPM Operations Manual. The IPM operations manual (manual) will serve as a guide for all pest management operations and will provide rationale and procedural guidelines for the implementation of the IPM policy. All persons conducting pest management within the scope of this policy are required to follow the manual, Departments or divisions will provide information to the city IPM coordinator and the IPM interdepartmental team to contribute towards the creation, review and update of the manual. The manual will be reviewed annually and a record kept of any revisions. Departments will designate at least one staff member as the departmental/divisional representative who will be responsible for providing information and input concerning the manual. A.Integrated Pest Management Plan. Each of these departments or divisions, and any others using pest control methods in the future, shall use the procedures outlined in this policy to develop a departmental or divisional Integrated Pest Management Plan. This plan shall be submitted to the City IPM Coordinator by January 15, 2003. Plans will be reviewed annually and updated at least every five years. Departments shall designate at least one staff member as the departmental/divisional IPM coordinator or representative to the Interdepartmental IPM Review Group. Commented [AR8]: Department names and divisions change and a list could imply that those not listed don’t have to comply with the policy when the policy applies to the entire city. 61 B. Record-keeping and Evaluation. Each department, division or work group shall must keep accurate records and results of all Integrated Pest ManagementIPM treatments used and the results. Information on all treatments (including non-chemical ones) shall will include how, when, where and why the treatment was applied and the name of the applicator. This information will be compiled submitted to the City IPM Coordinator yearly, as the basis for the Annual IPM ReportIPM reports. It should also be available for review at the Interdepartmental IPM Review Group meetings. The cCity IPM cCoordinator will review pest management treatments strategies with city departments and the IPM interdepartmental team to evaluate results, share information with other staff and improve the IPM program. the successes and failures of the IPM program, and to plan more efficient and effective pest management strategies. The following information shall be maintained: 1. Target pest 2. Pest population levels or injury thresholds for treatment 3. Treatment selection criteria with final treatment decision (IPM hierarchy checklist) 4. Area treated (including type of location and size of area) 5. Pesticide (including product trade name, active ingredient and EPA toxicity category) 6. Quantity of product used 7. Treatment method used (i.e. bait, injection) 8. Location of application 9. Time and date of pesticide application 10. Name(s) and license number(s) of Pesticide Applicator(s) 11. Name of the department contact authorizing work 12. Material Safety Data Sheets (MSDS) and labels for all pesticides used Application records shall will be made available to the public upon request in accordance with all applicable state laws governing public access to information. C. Contractor Notification. Every department bidding out contractual work for pest management must inform all bidders that the City has an Integrated Pest Management Policyabout the requirements of the IPM policy and include incorporate its guidelines in bid specifics. Contractors are encouraged to submit bids that include non-chemical pest control methods. Bids with non-chemical approaches may be given preference. If pesticides are applied, only those products may be used that are part of the approved pesticide list and adhere to its use guidelines OR are in accordance with a pesticide assessment and selection process approved by the city manager in compliance with the protocols and guidance of the IPM operations manual and/or are reviewed and have prior approval by the department and its division representative and the city’s IPM coordinator. The cCity will inform pest management contractors of the cCity’s IPM Policy and operations manual plans and provide a written copy of this policy and other relevant documents as appropriate. (i.e. Commented [AR9]: The paragraph/narrative provides policy direction. The details in the bullet list will be included in the IPM Operations Manual. Commented [AR10]: It’s the responsibility of staff to ensure that RFPs are clear about IPM guidelines and procedures so that that contractors know what’s expected. 62 departmental plans or Best Management Practices). Project managers, departmental IPM coordinators or contactsrepresentatives, or the cCity IPM cCoordinator shall must approve all pest management treatments. VI. INTEGRATED PEST MANAGEMENT (IPM)IPM PROCEDURE The cCity assumes that all pesticides are potentially hazardous to human and environmental health and will take measures to avoid any non-essential use. Therefore, reasonable non-pesticide alternatives willshall be given preference over chemical application controls by following the IPM procedure. City staff will evaluate alternatives to chemical treatments, including the cost- effectiveness of the treatments. For all pest control activities, the IPM procedure outlined below mustshall be followed. A. Initial Data Collection, Mapping and Monitoring. Each department or division considering pest control measures management of a target species shall should first collect baseline data on the pest ecosystem(s) to determine if the organism is truly a pest that warrants treatmentThis data includes the pest population(s) occurrence, size, density and presence of any natural enemy population(s); gather information on pest biology and site ecology, and different control techniques available; and document sensitive areas and conditions that may limit control options. Data shall should be collected in a standardized manner that is repeatable. This information may be included in departmental or divisional IPM plans. For structural pests, inspection and monitoring should be conducted to determine and eliminate route of entry, potential food and water sources, and nesting sites. This information should be logged. Ranking, inventory, mapping, monitoring and evaluation are methods used for determining pest management priorities. Maps and inventories depict infestations in terms of pest species, size, location and threats to resources. Departments/divisions shall must monitor infestations or pest populations and evaluate treatments over time to assess the effectiveness of various treatment strategies and their effects on target and non-target organisms the overall biodiversity of each site and the desired management objectives. These objectives should be reevaluated over time as the range and distribution of different species is altered from climate change and other anthropogenic factors. All monitoring methods and data must shall be specified in the departmental or divisional IPM planprocedures and included in the IPM operations manual, systematically recorded, and available for review. at the Interdepartmental IPM Review Group meetings. Departments should shall coordinate and utilize standardized pest mapping and data recording protocols, if possible. B. Establishing Threshold Levels. To determine if treatment is warranted, an acceptable threshold level of treatment for each target pest and site should be established based on the ecology of the pest and either its density that creates environmental, aesthetic or economic damage or based on a measurement of the damage resulting from the pest.. Departmental IPM procedures plans will Commented [AR11]: Redundant. Stated at end of section. Commented [AR12]: Important to acknowledge that climate change will impact ecosystems and that monitoring is crucial for adaptive management and protection of ecosystem services. Commented [AR13]: This is a simplification of the original language. 63 contain include the threshold levels for common pests, determined by individual work groups, and may be developed in conjunction consultation with the cCity IPM cCoordinator and interdepartmental team. In some instancescases, treatment a threshold, such as eradication, suppression, or containment may be required by federal or state law. The assessment will be based on the following: The tolerable level of environmental, aesthetic and economic damage as a result of the pest population(s) and the tolerable level of risk to human health as a result of the pest population(s); OR The size or density of the pest population that must be present to cause unacceptable environmental, aesthetic and/or economic damage; and the size, density and type of pest population that must be present to create a human health risk. C.ManagementTreatment Selection Criteria. Upon determining that management for an undesirable species treatment is necessary, the following criteria should be used to help select the appropriate IPM treatment strategy: 1.Least-disruptive of naturally occurring controls; 2.Least-hazardous to human health; 3.Least-toxic to non-target organisms; 4.Least-damaging to the general environment, surface and ground water, and overall ecosystem function and stability; 5. Most likely to produce a permanent reduction in the environment's ability to support target pests; 6.Economic and environmental Ccost-effectiveness in the short- and long-term. 64 D. Treatment Management Strategies and the IPM Hierarchy. Each department or division, in consultation with the cCity IPM cCoordinator, IPM team and/or guidelines of the operations manual, shall will make its own determination about appropriate and effective treatmentsmanagement approaches, based on site-specific requirements and condition. Commitment to the most environmentally- sound approach is expected, with relying primarily on non-chemical methods considered first. Prevention, cultural control, mechanical control, biological control and chemical control are the techniques used in the hierarchy of integrated pest management. In general, a combination of compatible treatments is more effective than a single approach. Departments and divisions staff are encouraged to seek out and experiment with innovative IPM treatments (and combinations of treatments) and share this information at the iInterdepartmental IPM Review Groupteam meetings. The following treatments are listed in the order in which they should be executed: 1. Prevention. This is the most effective and important pest management strategy and is the foundation of IPM. By reducing the capacity of the ecosystem to support target pest populations through design and appropriate management, the opportunities for pest establishment can be reduced to tolerable thresholds or eliminated. Some examples are: a) Use sStrategies that reduce the preferred harborage, food, water or other essential requirements of pests;. a)b) Promoting healthy soils and ecosystems to withstand pest infestations; b)c) Use wWeed-free materials for road and trail construction and maintenance. c)d) Use lLandscape and structural design that is appropriate to the specific habitat, climate and maintenance the area will receive;. and d)e) When designing projects, Project design that considers the potential impacts of pests and mitigates through the use of appropriate landscape design (plant choice, soil preparation, water requirements, weed barriers, etc). 2. Cultural. Cultural control is the use of management activities that can prevent pests from developing or keep them below tolerable levels due toby enhancement of desired conditions. Examples include:Specific examples are the following: a) Selection and placement of materials that provide life support mechanisms for pest enemies and competitors;. b) Modification of pest habitat by reducing pest harborage, food supply and other life support requirements;. c) Vegetation management including irrigation, mulching, fertilization, aeration, mowing height, seeding, pruning and thinning;. d) Waste management and proper food storage;. e) Barriers and traps.; f) Heat, cold, humidity, desiccation or light applied to affected regions; and. g) Prescribed burning or grazing. 65 3. Mechanical. Mechanical control is accomplished by using physical methods or mechanical equipment to control pest infestations, such as:. a) Mowing or weed-whipping; b) Prescribed Bburning; c) Hand-pulling of weeds; d) Hand-removal of insect egg massespests (e.g. insect or invasive amphibian egg masses). 4. Biological. Biological controls include the introduction or enhancement of natural enemy populations to target pests. Introduction of non-indigenous organisms has an associated risk factor and should be thoroughly evaluated prior to implementation in consultation with the city IPM coordinator and the interdepartmental IPM team. Biological methods include a) Conservation and augmentation of the pest's natural enemies; and b) Introduction of host-specific enemy organisms 5. Chemical. Chemical control of pests is accomplished by using chemical compounds registered as pesticides. All pesticides shall be assumed to be potentially hazardous to human and/or environmental health. The type, methods and timing of any chemical treatment shall will be determined after consideration has been given to protection of non-target organisms (including threatened or endangered species), the impact on biodiversity, protection of water quality, pest biology, soil types, anticipated adverse weather (winds, precipitation, etc) and temperature. Only those pesticides that have been evaluated and approved for use on city properties by a process approved by the city manager may be applied. Application of any pesticide must follow the guidelines for that particular product, which will be provided to staff, contractors or lessees and include information pertaining to target pests, application methods and any other restrictions. a) b) Initial review of potential chemicals shall begin with the least toxic compounds, i.e. chemicals in EPA Toxicity Categories III and IV. The use of compounds in EPA Toxicity Categories I and II shall be avoided if possible or used in situations where exposure to the active ingredient is limited (i.e. baits or soil/trunk injections). c) If, after a thorough evaluation of alternatives, the only effective or practical chemical control is an EPA Toxicity Category I or II compound, the department or division IPM coordinator shall confer with the City IPM Coordinator, and, if practical, the Interdepartmental IPM Review Group, to review the decision- making process and make a recommendation to the department head for approval. This may be done on a yearly basis for specific pest treatments. The decision-making process and lack of alternatives shall be documented. d) Staff will review the information available on potential chemicals for Commented [AR14]: Most of this section is removed, since it predates the approved pesticide list process. 66 persistence in the soil and the potential impacts from persistence. These factors will be considered along with the potential for more frequent application of chemicals that do not persist in the environment. e) If chemical treatment is warranted in a riparian area, applications will generally be plant specific and limited to wick applications. If broader applications are needed, the department or division IPM coordinator shall confer with the City IPM Coordinator, and, if practical, the Interdepartmental IPM Review Group, to review the decision-making process and make a recommendation to the department head for approval. This may be done on a yearly basis. f) Potential chemical approaches (1) pheromones and other attractants to confuse pests and/or act as bait (2) insecticidal soaps (3) juvenile hormones that arrest pest development (4) repellants (5) allelopathins (6) sterilants or contraceptives to reduce breeding (7) contact, stomach or other poisons (8) fumigants (9) combinations of above (baits with poisons) (10) herbicides, insecticides All pesticides shall must be applied in conformance with label specifications and all applicable federal, state and municipal laws, regulations and ordinances, as well as any additional restrictions provided in city guidance documents. All pesticide applications shall must comply with the appropriate pre and post- notification requirements, according to the City of Boulder’s Pesticide Ordinance (Section 6-10-1 B.R.C. 1981). For all city pesticide applications, notification will be posted at the site at least 24 hours in advance, remain on site for at least 24 hours, and posted on the city’s hotline. This includes soil and trunk injections, spot spraying, hand-wicking and broadcast spraying on all city lands or property. open to the public E. Education. Education is a critical component of an IPM program. The cCity IPM cCoordinator will include IPM information on the city’s Office of Environmental Affairs’ website. Information will include the Annual IPM rReports, departmental IPM plans and other pertinent material. the IPM operations manual and pesticide assessment processes, recommendations for the most ecologically-sound pest management for residents, and IPM- related events and educational opportunities across the city.Individual departments, divisions and work groups may conduct additional specific educational activities. VII. CONTRACTOR RESPONSIBILITIES & REQUIREMENTS All contractors working for the City are required to abide by the City’s IPM Policy. The contractor will return a signed statement to the IPM Coordinator or departmental contact certifying they have read and understand the policy prior to any work being done for the City. The contractor shall Commented [AR15]: Employees have a right to know when pesticides have been applied, so all pesticide applications should be posted. Commented [AR16]: Section simplified, since it’s up to the hiring department to oversee that contractors comply with the IPM requirements. 67 maintain records as listed in Section V, B. The City periodically enters into contracts that authorize pest management, such as for building maintenance, project construction and maintenance, and weed and insect control. When the city signs a new contract or extends the term of an existing contract with a contractor that conducts IPM-related work, including may include or authorize the application of pesticides, the department must ensure that the work is in compliance with existing IPM guidelines or consult with the city IPM coordinator to develop procedures that comply with the IPM policy. the department shall review its IPM plan with the City IPM Coordinator and update the plan to include the pesticide usage of the contractor. Contractors who apply pesticides on City owned or managed property shall submit a plan to the contracting city department and the City IPM Coordinator if the department has not provided a plan. Their plan shall include the following: • Information addressing all the elements listed in Section VI, Integrated Pest Management (IPM) Procedure • Types and estimated rates, to the extent possible, of the pesticides that the contractor may need to apply to City property during its contract • An outline of the actions the contractor will take to meet the City IPM policy • The primary IPM contact for the contractor Contractors will provide background information on the decision-making process for treatment methods to the city upon request. The City department and City IPM Coordinator shall approve the plan before any chemical applications are made. Contractors shall notify their departmental contact when any biological or chemical treatments are conducted. The contractors mustshall comply with appropriate pre and post- notification requirements, according to the City of Boulder’s Pesticide Ordinance (Section 6-10-1 B.R.C. 1981) and relevant internal city protocols, such as providing timely information to post the application on the city’s pesticide hotline. VIII. CONSTRUCTION AND INTERPRETATION Employees who have questions concerning possible conflict between their interests and those of the cCity, or the interpretation and application of any of these rules, should direct their inquiries to their dDepartment dDirector. The dDepartment dDirector may refer the matter to the cCity mManager for final resolution. IX. EXCEPTIONS/CHANGE This policy supersedes all previous policies covering the same or similar topics. Any exception to this policy may be granted only by the cCity mManager. This policy may be reviewed and changed at any time. Adopted 1993, updated April 2018April 2002. 68 69 2018 Environmental Advisory Board Calendar January 3 Meeting Public Hearings Staff Discussion Items/Updates/Matters for the Board Staff Scoping and Planning for 2018 Joint Council/EAB SS Brett KenCairn New Member Recruitment Board Materials due by noon on Wed, Dec 27, emailed to EAB by 4 pm. February 7 Meeting Public Hearings Staff Discussion Items/Updates/Matters for the Board Staff RECs Yael Gichon/Kimberlee Rankin Preparing for the Joint Council/EAB Study Session Materials due by noon on Wed, Jan 31, emailed to EAB by 4 pm. March 7 Meeting Public Hearings Staff Discussion Items/Updates/Matters for the Board Staff Updates to the Integrated Pest Management Policy and Associated Programs Rella Abernathy (60 mins) Urban Forest Management Strategy Kathleen Alexander (30 mins) Preparing for the Joint Council/EAB Study Session Board Goodbye and Thank You to Brad All Materials due by noon on Wed, Feb 28, emailed to EAB by 4 pm. April 4 - Retreat May 2 Meeting Public Hearings Staff Discussion Items/Updates/Matters for the Board Staff/Board Member 6400 Arapahoe Kara Mertz Preparing for the Joint Council/EAB Study Session Materials due by noon on Wed, April 25, emailed to EAB by 4 pm. June 6 Meeting Public Hearings Staff Discussion Items/Updates/Matters for the Board Staff 70 Preparing for the Joint Council/EAB Study Session Materials due by noon on Wed, May 30, emailed to EAB by 4 pm. July 18 Meeting Public Hearings Staff Discussion Items/Updates/Matters for the Board Staff Preparing for the Joint Council/EAB Study Session Materials due by noon on Tues, July 11, emailed to EAB by 4 pm. August 1 Meeting Public Hearings Staff Discussion Items/Updates/Matters for the Board Staff Preparing for the Joint Council/EAB Study Session Materials due by noon on Wed, July 25, emailed to EAB by 4 pm. September 5 Meeting Public Hearings Staff Discussion Items/Updates/Matters for the Board Staff Preparing for the Joint Council/EAB Study Session Materials due by noon on Wed, Aug 29, emailed to EAB by 4 pm. October 3 Meeting Public Hearings Staff Discussion Items/Updates/Matters for the Board Staff Preparing for the Joint Council/EAB Study Session Materials due by noon on Wed, Sept 26, emailed to EAB by 4 pm. November 7 Meeting Public Hearings Staff Discussion Items/Updates/Matters for the Board Staff Preparing for the Joint Council/EAB Study Session Materials due by noon on Wed, Oct 24, emailed to EAB by 4 pm. 71 December 5 Meeting Public Hearings Staff Discussion Items/Updates/Matters for the Board Staff Preparing for the Joint Council/EAB Study Session Materials due by noon on Wed, Nov 28, emailed to EAB by 4 pm. 72