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HomeMy WebLinkAbout12 - Beach Fire Rings: Repeal of 2013’s Amendments to Rule 444 (Open Burning) 12-1 NEWPORT BEACH City Council Staff Report COUNCIL STAFF REPORT CITY OF March 8, 2016 Agenda Item No. 12 ABSTRACT: Approval of this item would authorize Mayor Dixon to send a letter to the South Coast Air Quality Management District (SCAQMD) Governing Board advocating for a repeal of 2013’s amendments to Rule 444 (Open Burning) relating to beach fire rings. The 2013 amendments generally regulated beach fire rings for the first time. If the Board repeals the amendments and the Coastal Commission later issues a permit to return to the 2013 ring placement, the city’s sixty (60) rings could be returned to their 2013 locations. RECOMMENDATION: Authorize the Mayor to send a letter to the South Coast AQMD Governing Board asking for a repeal of 2013’s amendments to Rule 444 (Open Burning) relating to beach fire rings. FUNDING REQUIREMENTS: The beach fire ring plan under operation now costs about $165,000 per year for a private security firm to monitor fuel use (charcoal versus wood) at the Balboa Pier and CdM State Beach. If the rings were returned to the older placement and the charcoal requirement removed, arguably all of those resources could be saved. DISCUSSION: Please see staff reports from the January 13, 2015 and June 23, 2015 City Council meetings for additional background information. TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: Dave Kiff, City Manager - 949-644-3001, dkiff@newportbeachca.gov PREPARED BY: Dave Kiff PHONE: 949-644-3001 TITLE: Beach Fire Rings: Repeal of 2013’s Amendments to Rule 444 (Open Burning) Beach Fire Rings: Repeal of 2013’s Amendments to Rule 444 (Open Burning) March 8, 2016 Page 2 12-2 Prior to very recent times, the City had sixty (60) beach fire rings at two popular beach areas – Big Corona (27 rings) and the Balboa Pier area (33 rings). Attachment C has exhibits with aerials showing the older footprint of the rings. Generally, wood fuel as well as charcoal was burned in these rings, but there were no restrictions on whether specific rings were reserved for wood versus charcoal. In some but not many instances, fire ring users would burn other materials that were not allowed – such as wood with paint, tables, furniture, and more. The City would attempt to cite persons burning the wrong materials, and could do so on a sporadic basis. About five years ago, then-Council Member Nancy Gardner asked the community and Council if the Council would consider removing all of the beach fire rings, citing the health impacts associated with wood smoke as a reason for concern. A multi-year effort then began, with the following actions:  In February 2012, the Newport Beach Parks, Beaches, and Recreation Commission voted 4-3 to remove the rings.  In March 2012, the Newport Beach City Council approved the Commission’s action, and voted to remove the rings.  Following the March 2012 action, the City staff applied for a Coastal Development Permit (CDP) from the California Coastal Commission to remove the rings. Months went by with the City staff and Coastal staff exchanging letters about the City’s CDP application. In Spring 2013, the City withdrew its permit application in mid-hearing as the Coastal Commission was indicating that it would likely not act o n the City’s permit or would deny it. Some commissioners suggested following then- Commissioner Bill Burke’s suggestion that the South Coast AQMD review the issue by considering amendments to AQMD’s Rule 444 (Open Burning).  In July 2013, the SC AQMD Governing Board, on a 7-6 vote, approved a change to Rule 444 (see Attachment A) that said, generally, that wood-burning beach fire rings that were within 700’ of residences should be spaced 100’ apart, if there were more than 15 rings in any one jurisdiction. The Rule changes exempted charcoal and natural gas fire rings from the distancing requirement. The Rule would take effect March 1, 2014.  In November 2013, the Council adopted a plan that it believed complied with Rule 444, although AQMD later said that the distancing that the City chose (50’ versus 100’) was not compliant with the Rule’s definition of a “contiguous beach unit.”  In January and February 2014, the City Council introduced Ordinance No. 2014-2 relating to Beach Fire Rings. The Ordinance limited the types of fuel that can be used in beach fire rings.  In March 2014, the new Rule 444 took effect. Beach Fire Rings: Repeal of 2013’s Amendments to Rule 444 (Open Burning) March 8, 2016 Page 3 12-3  In June 2014, the Coastal Commission told the City that the changes that the City adopted in early 2014 required a Coastal Development Permit. The City applied for one in arrears in July 2014.  In November 2014, a City Council was elected with a different approach, one that was more supportive of wood-burning fire rings.  As a compromise plan, the Council adopted a Plan in early 2015 that kept some wood-burning and some charcoal rings in Newport Beach, including adding some at Newport Dunes. The plan is shown in the exhibits of Attachment C. Much of the Plan was approved by the Coastal Commission (9-1) on June 11, 2015, but the City does not physically have the permit to implement it in hand.  As it prepared the FY 2015-16 City budget, the City estimated a cost of about $165,000 per year to appropriately enforce the different fuel designations for our fire rings. The City has done so using a private-sector security firm, under a contract administered by the Police Department. It has been somewhat successful, although the fire rings are not supervised at all times. In November 2015, the AQMD Board of Governors had new appointees, including Lake Forest City Council member Dwight Robinson representing Orange County. Council Member Robinson replaced Santa Ana Mayor Miguel Pulido on the Board. The change shifted the governing majority on the Board. In February 2016, Council Member Peotter asked that the Council to consider sending a letter to the AQMD Board asking them to review and repeal the 2013 amendments to Rule 444. Doing so could remove the language that established distancing between fire rings that were within 700’ of residences, and would allow localities like Newport Beach to put the fire rings back into their 2013 footprint. Arguably, doing so would also require an amendment to the City’s June 2015-issued CDP from the Coastal Commission. This agenda item would authorize Mayor Dixon to send a letter to the Governing Board stating that request (see Attachment B for the draft letter). The pros and cons of a repeal of Rule 444’s 2013 amendments are as follows: Advantages  The City could choose its own fire ring configuration and fuel mix (though with the approval of the Coastal Commission).  Significant ongoing City resources (about $165,000 per year) could be saved by avoiding ongoing enforcement expenses for the current plan.  Staff believes that the current plan’s enforcement is costly and generally makes fire ring users unhappy. People who bring wood but cannot use it because the wood rings are all taken just end up being upset. Beach Fire Rings: Repeal of 2013’s Amendments to Rule 444 (Open Burning) March 8, 2016 Page 4 12-4 Disadvantages  Some believe that the current fire ring plan and the provisions of Rule 444 provide for better air quality to beach users and adjacent residential areas than the 2013-era ring configuration.  The South Coast AQMD Board may not wish to reconsider this issue at all, notwithstanding whether or not they’d repeal Rule 444’s amendments. ENVIRONMENTAL REVIEW: Staff recommends the City Council find this action is not subject to the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable ind irect physical change in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the CEQA Guidelines, California Code of Regulations, Title 14, Division 6, Chapter 3. Specifically, the action consists of advising AQMD of the City’s position as to the State’s regulatory program and has no potential for resulting in physical change to the environment, directly or indirectly. Even if advising AQMD of the City’s position is considered subject to CEQA, this action is exempt from CEQA because it has no potential to have a significant effect on the environment, it is an administrative action as described in City Council Policy K-3 and is exempt from CEQA pursuant to Sections 15061(b)(3) (CEQA applies only to projects, which have the potential for causing a significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA.) NOTICING: The agenda item has been noticed according to the Brown Act (72 hours in advance of the meeting at which the City Council considers the item). Additionally, I provided notice of this item in the Insider’s Guide as well as to the Balboa Penin sula Point HOA, the Central Newport Beach Association, and the CdM Residents Association. ATTACHMENTS: Attachment A – Rule 444 – Including Notes About 2013’s Changes Attachment B – Draft Letter to the AQMD Attachment C – Staff Report from June 2015, Showing Ring Footprints Attachment D – Correspondence Attachment A 12-5 Attachment A 12-6 Attachment A 12-7 Attachment A 12-8 Attachment A 12-9 Attachment A 12-10 Attachment A 12-11 Attachment A 12-12 Attachment A 12-13 Attachment A 12-14 Attachment A 12-15 Attachment A 12-16 Attachment A 12-17 Attachment A 12-18 Attachment A 12-19 Attachment A 12-20 12-21 Attachment B – Draft Letter March 9, 2016 Dr. William A. Burke, Chairman South Coast AQMD Governing Board 21865 Copley Drive Diamond Bar, California 91765 Dear Chairman Burke and Members of the Governing Board: This letter is to formally state the City of Newport Beach’s respectful request to you and your colleagues on the Governing Board to reconsider the July 2013 amendments to Rule 444 (Open Burning) that limited beach burning, specifically wood-burning beach fire rings within 700’ of residences. We are aware of the Board’s and staff’s efforts on this issue in 2013, and certainly realize the difficult work that went into adopting the amendments to the Rule. At this point in 2016, the City Council of the City of Newport Beach believes that the Rule should be revisited, and the 2013 provisions repealed. Doing so would allow us greater flexibility in implementing local solutions in concert with local and visitor desires as well as with the California Coastal Commission. Additionally, amending the Rule may also allow us to end a challenging struggle to appropriately enforce the Rule’s provisions as we have implemented them. Regular enforcement of the varying fuels allowed to be burned in our fire rings, which are open to the public from 6:00 a.m. to 10:00 p.m. daily, has been costly and only marginally successful. The City would prefer that the Rule’s provisions return to the language that was used prior to the July 2013 amendments relating to beach burning. If you have any questions about this request, please do not hesitate to ask. Sincerely, Diane Dixon Mayor, Newport Beach cc: Members of the Newport Beach City Council Dr. Barry Wallerstein, South Coast AQMD Executive Officer The Honorable Dwight Robinson, City Council Member of Lake Forest CTY OF F NEWPORT BEACH City Council Staff Report June 23, 2015 Agenda Item No. 28 TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: Dave Kiff, City Manager — (949) 644 -3002, dkiff @newportbeachca.gov PREPARED BY: Dave Kiff, City Manager PHONE: (949) 644 -3001 TITLE: Ordinance No. 2015 -21: Fuel for Beach Fire Rings; Ratification of the California Coastal Commission's Approved Fire Ring Plan for Newport Beach ABSTRACT: The City and its 60 beach fire rings was required to comply with the South Coast Air Quality Management District's (AQMD's) Rule 444 (Open Burning) in March 2014. On June 11th, 2015, the California Coastal Commission gave approval (with conditions) to a plan that included charcoal and wood - burning rings in Newport Beach. The plan also complies with AQMD Rule 444. Staff seeks formal Council ratification of the plan, as well as additional public awareness of it. Additionally, the Commission's approval necessitates small changes to the City's Municipal Code regarding fuel for beach fire rings. RECOMMENDATION: a) Authorize the City staff to implement the fire rings plan as approved by the California Coastal Commission on June 11. 2015: and b) Introduce Ordinance No. 2015 -21, An Ordinance of the City Council of the City of Newport Beach, California, Amending Section 11.08.060 of Chapter 11.08 of the Newport Beach Municipal Code Relating to Beach Fire Rings, and, if approved, pass to second reading onJuly 14, 2015. FUNDING REQUIREMENTS: Funding to implement the plan (about $165,000, which includes $110,000 in new funding) has been included in the FY 15 -16 budget, although some one -time costs for signage and construction of the ADA rings may come from residual fund balance in the FY 14 -15 budget. DISCUSSION: BACKGROUND: Please see the staff report from the January 13, 2015 City Council meeting for additional and detailed background information. Following many months of community input and stakeholder discussion, City staff presented a consensus 28 -1 ATTACHMENT C 12-21 fire ring plan ( "Plan ") to the California Coastal Commission on June 11, 2015. The Plan was a result of discussions with individual Council members representing the districts where fire rings reside (Ms. Dixon and Mr. Peotter), community members, Coastal Commission staff members, representatives of Friends of the Fire Rings, AQMD staff and others. The Plan has also been discussed in the context of settling legal issues between the City and Friends of the Fire Rings. The Plan is shown as Attachment A. The Plan was approved with conditions by the Commission on a 9 -1 vote, although the Commission directed that the City work with the California Department of Parks and Recreation (DPR) to address some of DPR's concerns about aspects of the proposed Coastal Development Permit (CDP) that could carry forward onto DPR's property at Corona del Mar State Beach. The City operates CdM State Beach via an operating agreement with DPR. The Agreement, among other things, requires the City to seek and obtain approval for construction and other projects prior to project implementation at the beach. Staff has proceeded to work with the Coastal Commission staff and DPR's local representatives to address these concerns. The Commission's executive director may approve whatever successful outcome is reached between the City and DPR. This aspect of the Commission's approval does not affect implementation of the Plan at the Dunes or the areas around the Balboa Pier. Following formal Council approval, City staff will continue to move to complete the standard and special conditions that Coastal requires prior to issuing a CDP. With the CDP in hand, we will implement the changes to the fire ring layouts, including constructing the ADA rings, moving rings, installing signage, and securing appropriate vendors and /or vending machines for charcoal and wood. Regarding the proposed ordinance (Attachment B), the code revisions under consideration make small changes to the City's current code on fuel for fire rings. These changes include eliminating a sunset provision that would have made the section expire in 2016 as well as clarifying that the City will designate what fuels can be burned in what rings in accordance with the issued CDP. In closing, the City Manager would like to thank and recognize Ms. Dixon and Mr. Peotter, as well as Doug Swardstrom of Friends of the Fire Rings, Andy Theodorou of the Newport Dunes Resort, Stacy Blackwood of the County of Orange (OC Parks), Brian Ketterer and Todd Lewis of California State Parks, Denys Oberman (a Balboa Peninsula resident), former Council member Mike Henn, Coastal Commission staff especially Ms. Erin Prahler, Ms. Sherilyn Sarb, and Mr. Karl Schwing), AQMD executive officer Barry Wallerstein, City staff such as Scott Watson (GIS), Brenda Wisneski (Community Development), Recreation Director Laura Detweiler, Fire Chief Scott Poster, Police Chief Jay Johnson, City Attorney Aaron Harp, and others who worked hard on this compromise to see it to implementation. It is not perfect, but it respects and recognizes multiple wishes for the fire rings that at one time seemed irreconcilable. ENVIRONMENTAL REVIEW: Staff recommends the City Council find compliance with Rule 444 is not subject to the California Environmental Quality Act ( "CEQA ") pursuant to Public Resources Code Section 21080(b)(1) and CEQA Guidelines Section 15268(a) because the City's proposal to space the fire rings farther apart and convert wood burning rings to charcoal -only rings is mandated by South Coast Air Quality Management District's Rule 444. The City's compliance with Rule 444 is therefore ministerial. Further, based upon the substantial evidence contained herein, spacing wood - burning fire rings farther apart and converting wood burning rings to charcoal -only rings will not cause significant impacts to the environment and therefore exempt from CEQA pursuant to CEQA Guidelines Section 15061(b)(3). In addition, aspects of this project are exempt pursuant to CEQA Guidelines Section 15301, Operation, Repair, Maintenance, or Minor Alteration of Existing Structures or Facilities (Class 1), CEQA Guidelines Section 15302, Replacement or Reconstruction of Existing Structures or Facilities ( Class 2), CEQA Guidelines Section 15303, New Construction, Installation or Conversion of Small Structures, Facilities or Equipment (Class 3), CEQA Guidelines Section 15304, Minor Alterations to Land, Water or Vegetation Class 4), CEQA Guidelines Section 15305, Minor Alterations to Land Use Limitations (Class 5), CEQA Guidelines Section 15311, Construction or Placement of Accessory Structures (Class 11), and CEQA 28 -2 Attachment C 12-22 Guidelines Section 15323, Normal Operations of Existing Facilities for Public Gatherings (Class 23), in that aspects involve a replacement or reconstruction of existing structures, specifically the fire rings, within what is generally the same beach footprint, the addition /modification of signage, and minor modifications to the City's Municipal Code. NOTICING: The agenda item has been noticed according to the Brown Act (72 hours in advance of the meeting at which the City Council considers the item). ATTACHMENTS: Description Attachment A - Plan 17 - Approved Fire Ring Plan Attachment B - Ordinance 28 -3 Attachment C 12-23 ATTACHMENT A 00. r J loo • ` l 4V ` O Main Access Path (415 sf) ADA Concrete Ring (157 sf) ADA Concrete Pad (83 sf) Fire Ring Footprint (17 rings - 332 sf) 0 30 60Feet O Plan 17" West Balboa Pier y t r hp 02 Y^ J M Wood Fire Ring (9) Charcoal Fire Ring (8) atyaf Newpa,tsea,n GIS Division May 12, 2015 rrt: 0 Attachment C 12-24 1. ywt r. h0/ Op. ADA Concrete Ring (157 sf) ADA Concrete Pad (83 sf) Fire Ring Footprint (15 rings - 293 sf) o 0 0 greet r ® 6 C OL x-100 / LG Tower B / Plan 17" East Balboa Pier M Wood Fire Ring (7) 5rv Charcoal Fire Ring (8) City of Newport Beach GIS Division May 12, 2015 Attachment C 12-25 t ff_ v Ji O Main Access Path (365 sf) M ADA Concrete Ring 057 sf) ADA Concrete Pad (45 sf) Fire Ring Footprint (24 rings - 469 sf) 0 to so jUne r 53 , ® Plan 17" CdM State Beach F v LG Tower 3 t• F t h Wood Fire Ring (16) 5 ' Charcoal Fire Ring (8) atr ar Newport aea =h GIS Division May 12, 2015 Attachment C 12-26 WIN Attachment C 12-27 ATTACHMENT B ORDINANCE NO. 2015- AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF NEWPORT BEACH, CALIFORNIA AMENDING SECTION 11.08.060 OF CHAPTER 11.08 OF THE NEWPORT BEACH MUNICIPAL CODE RELATING TO BEACH FIRE RINGS RECITALS WHEREAS, the City of Newport Beach ( "City ") is a tourist destination for millions of in -state and out of state residents, and international visitors; WHEREAS, many visitors are drawn to the City for our fresh air, clean ocean water, and miles of pristine coast line; WHEREAS, many visitors and residents also come to the City to participate in the longstanding tradition of a beach bonfire; WHEREAS, prior to the adoption of South Coast Air Quality Management District Rule 444 ( "Rule 444 "), the City had 60 wood burning fire rings in the vicinity of the Balboa Pier and at Corona del Mar State Beach; WHEREAS, to comply with Rule 444, the City implemented a temporary plan whereby the number of fire rings was reduced from 60 wood burning fire rings to a combination of 56 wood burning and charcoal -only burning fire rings; WHEREAS, on June 9, 2015, the California Coastal Commission approved the City's application for a Coastal Development Permit to replace the City's temporary plan with a permanent plan that balanced air quality concerns with the ability to enjoy a traditional beach bonfire; WHEREAS, the permanent plan provided for 64 fire rings (including four rings that previously existed at the Newport Dunes) and included adding fire rings to a new location, relocating fire rings, including a mix of wood - burning and charcoal -only fire rings, and making access to some fire rings consistent with the Americans with Disabilities Act ( "ADA "); WHEREAS, to implement the Coastal Development Permit, the City must modify the Newport Beach Municipal Code provisions related to the fuels that can be burned in fire rings; and WHEREAS, the City has a compelling interest in the health, safety, and welfare of both residents and visitors and wishes to prevent any use of fire rings that may negatively affect beachgoers, residents, and the environment. 1 Attachment C 12-28 NOW THEREFORE, the City Council of the City of Newport Beach does ordain as follows: Section 1: Section 11.08.060, Chapter 11.08, Title 11, of the Newport Beach Municipal Code is hereby amended to read as follows: 11.08.060 Use of Beach Fire Rings. A. No person shall burn, ignite or otherwise set on fire any material in a fire ring or fire pit, except natural wood, lighter fluid, fire log(s), or charcoal (collectively "fuel'), unless the person is burning the fuel in a fire ring or fire pit that has been specifically designated by the City Manager as a fire ring or fire pit where the designated fuel may be burned. The City Manager shall designate what fuel may be burned in fire rings and fire pits in accordance with the Coastal Development Permit related to the location and use of fire rings. B. For purposes of this Section, the following terms shall be defined as follows: 1. "Natural Wood" means the hard fibrous substance consisting basically of xylem that makes up the greater part of the stems, branches, and roots of trees and shall not include any material that has been processed or treated including, but not limited to, wooden pallets, books, newspapers, furniture, or construction materials. 2. "Fire Log" means any manufactured log constructed of sawdust; sawdust and paraffin; or waste fiber from the oil palm. 3. "Charcoal' means a carbon substance obtained as a residue when wood or other organic matter is heated in the absence of air. Section 2: The recitals provided in this ordinance are true and correct and are incorporated into the substantive portion of this ordinance. Section 3: If any section, subsection, sentence, clause or phrase of this ordinance is for any reason held to be invalid or unconstitutional, such decision shall not affect the validity or constitutionality of the remaining portions of this ordinance. The City Council hereby declares that it would have passed this ordinance and each section, subsection, sentence, clause or phrase hereof, irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared unconstitutional. Section 4: The City Council finds the introduction and approval of this ordinance is not subject to the California Environmental Quality Act ( "CEQK) because compliance with AQMD Rule 444 is not subject to CEQA pursuant to Public Resources 2 Attachment C 12-29 Code Section 21080(b)(1) and CEQA Guidelines Section 15268(a) because the City's proposal to space the fire rings farther apart and convert wood burning rings to charcoal -only rings is mandated by Rule 444. The City's compliance with Rule 444 is therefore ministerial. Further, based upon the substantial evidence, the City Council finds that spacing wood - burning fire rings farther apart and converting wood burning rings to charcoal -only rings will not cause significant impacts to the environment and therefore is exempt from CEQA pursuant to CEQA Guidelines Section 15061(b)(3). In addition, this ordinance and aspects of the project are exempt pursuant to CEQA Guidelines Section 15301, Operation, Repair, Maintenance, or Minor Alteration of Existing Structures or Facilities (Class 1), CEQA Guidelines Section 15302, Replacement or Reconstruction of Existing Structures or Facilities (Class 2), CEQA Guidelines Section 15303, New Construction, Installation or Conversion of Small Structures, Facilities or Equipment (Class 3), CEQA Guidelines Section 15304, Minor Alterations to Land, Water or Vegetation (Class 4), CEQA Guidelines Section 15305, Minor Alterations to Land Use Limitations (Class 5), CEQA Guidelines Section 15311, Construction or Placement of Accessory Structures (Class 11), and CEQA Guidelines Section 15323, Normal Operations of Existing Facilities for Public Gatherings (Class 23), in that this ordinance and aspects of the project involve the replacement or reconstruction of existing structures, specifically the fire rings, within what is generally the same beach footprint, the addition /modification of signage, and minor modifications to the City's Municipal Code via this ordinance. Section 5: The Mayor shall sign and the City Clerk shall attest to the passage of this ordinance. The City Clerk shall cause the same to be published pursuant to Charter Section 414, and it shall be effective thirty (30) days after its adoption. This ordinance was introduced at a regular meeting of the City Council of the City of Newport Beach, held on the 23rd day of June 2015, and adopted on the 14th day of July, 2015, by the following vote, to wit: AYES, COUNCIL MEMBERS NOES, COUNCIL MEMBERS ABSENT COUNCIL MEMBERS MAYOR Edward D. Selich 3 28 -10 Attachment C 12-30 ATTEST: Leilani I. Brown, City Clerk APPROVED AS TO FORM: CITY ATTORNEY'S OFFICE Aaron C. Harp, City Attorney 0 28 -11 Attachment C 12-31 1 Brown, Leilani From:Denys Oberman <dho@obermanassociates.com> Sent:Wednesday, March 02, 2016 5:36 PM To:Dixon, Diane; kcurry@newportbeachca.gov; Petros, Tony; kevinmmuldoon@yahoo.com; Peotter, Scott; Duffield, Duffy; Kiff, Dave Cc:Brown, Leilani; Scott Robinson; lcurran@me.com; paul@lawfriend.com; 'Fred Levine'; karen_tringali@msn.com; jwatt4@aol.com; Jeanne Price; Mike Henn Subject:FIRE RINGS- PLEASE DISTRIBUTE TO THE CITY COUNCIL AND ENTER INTO THE PUBLIC RECORD FOR MARCH 8th COUNCIL SESSION Mayor and Council Members:    I understand that the Council will be considering a proposal at next week’s Council session to reinstate Fire  rings “at their locations which existed prior to 2013”.  As the staff report is not out, and I am out of town and unable to participate next week, I and other neighbors  cannot ascertain the specifics of the recommendation at this time. However, we are gravely concerned that  there may be Reintroduction of additional Wood burning rings, or the expansion of any number of wood  burning rings further into areas close to residential zones, or areas frequented by children or seniors. This  would be a position adverse to Public health and safety.    To quote one of the Coastal Commissioners: “ The Science is in, there is no debate. Wood smoke is an  established Carcinogen”    We respectfully request that the Council recollect the public’s voice to remain a healthy smoke‐free  community, and not move to approve any proposal which increases the number of Wood‐burning rings, or  moves against the guidance of  SC AQMD.    Thank you for your consideration,  Denys Oberman  Community stakeholder and resident   ………………………………………….    Regards, Denys H. Oberman, CEO    OBERMAN Strategy and Financial Advisors 2600 Michelson Drive, Suite 1700 Irvine, CA 92612 Tel (949) 476-0790 Cell (949) 230-5868 Fax (949) 752-8935 Email: dho@obermanassociates.com CONFIDENTIALITY NOTICE: The documents accompanying this transmission contain confidential information belonging to the sender which is legally privileged. The information is intended only for the use of the individual or entity named above. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or the taking of any action in reliance on the contents of this telecopied information is strictly ATTACHMENT D 12-32