Sustainable Practice Action Plan


To: Mayor & Board of Aldermen
and to Joe Adkins, Deputy Director for Planning
From: C. Paul Smith
Date: March 10, 2009
Re: Sustainable Practice Action Plan


I am submitting these comments and proposed changes to the 18-page Sustainable Practice Action Plan (SPAP) that was presented to the Board of Aldermen on March 5, 2009. Each of my numbered comments/proposals corresponds to a circled number on the attached SPAP so that you can easily see the section and the language to which they refer.

(1) There should first be a section that identifies the specific problem that the SPAP is designed to address. Precise identification of the problem is necessary to precisely and effectively address the problem. Failure to do so can lead to wasteful and inefficient actions and expenses, which will ultimately be costly to taxpayers.

(2) “Environmental sustainability” should be defined. This is a relatively new phrase with a technical meaning. The City should define the term for itself, and this definition should be at the beginning of the document whose purpose is to achieve it.

(3) The language requiring “policy change” and “behavioral change,” is not proper before there is a statement of the “policy” and “behavior” that is a problem.

(4) Two or three steps precede the adoption of a plan: First, we must identify the problem; second we must identify the solution or the desired condition; and third we must identify the obstacles and potential adverse consequences that might be involved. Then we can begin to formulate a plan to achieve the desired goal. I expect these considerations to be addressed in the SPAP.

(5) Coordination between departments and obtaining the input from different departments is something that is routinely done in the City. The extent to which such coordination needs to be increased, depends upon the particular problem being addressed. Having a stated city policy can help achieve coordination and cooperation among departments.

(6) The phrase “climate protection” requires some explanation and definition.

(7) I generally support the reduction of most emissions where feasible. However, any policy to reduce emissions must (a) identify the emission to be addressed, (b) describe and where appropriate establish the adverse effects from the emission, (c) propose a way to ameliorate the situation, and (d) address the cost and economic issues connected with the emissions and with the proposed plan to reduce them.

(8) I do not agree that the City should hire a Sustainability Coordinator, as a new position in the City administration. In fact, there is already such significant and widespread awareness of environmental concerns among city employees that I am not yet convinced that we need to even appoint one of our employees to be the “point of contact to research and coordinate” the addressing of environmental issues. I do not support this paragraph at this time. The argument has not been made that warrants or justifies the need for this new position.

(9) It is premature to conclude that “City Departments and the Public will need to be coordinated to implement the Action Plan” when we don’t even know what the plan is. It is quite possible that the mere existence of a policy statement will be adequate.

(10) Before I subscribe to “a Citywide sustainability culture,” it is necessary to define and describe the “culture” which we are admonished to become. This has yet to occur.

(11) Coordination between departments is routinely done in many of the operations and functions of the City. What is it about the current coordination that is insufficient to address a particular problem? Once this question is answered, the City can then determine what actions would be appropriate to improve a situation. I am currently of the opinion that there is no environmental need that warrants the City’s funding of a new employee position.

(12) The designation of the Sustainability Coordinator’s office as “neutral ground” is most curious. Such a position is inherently non-neutral because it will tend to require the expenditure of time and funds of other departments in order to accomplish its environmental objectives.

(13) To this captioned item add the word “and Cost Efficient” after the words “Energy Efficient.”

(14) Change the wording of this bullet item to: “Conduct an energy audit of its facilities and recommend appropriate changes.”

(15) This suggested action item should also consider the costs. Failure to include the cost factors in evaluating proposals is not a good idea.

(16) Cost factors must also be included in this analysis.

(17) This item adds another action area, but it does not warrant a new city position to consider it.

(18) While this may be an important consideration for some big employers, there is no major need to spend time thinking about AWS proposals for the City, which must be available to serve residents at specified times.

(19) There will be no significant saving of commuting time by addressing AWS in the City government.

(20) This is only the beginning of the discussion on the environmental effects of burning fuel oil/gas. Plants need carbon dioxide to live. The question is whether excessive carbon dioxide is produced and what are the effects from burning it. Further, since there is only a limited amount of fossil fuel, another question is whether fossil fuel will be exhausted before its purported adverse effects will cause global climate damage. Conservation of fossil fuel is warranted to extend its use. But the degree to which it contributes to global warming has not been determined. Neither has it been determined at what point global warming would become over-all damaging to the world. The inclusion of this fact (about the production of carbon dioxide) is being used to promote one opinion without giving an appropriate discussion of the entire issue. I object to this approach.

(21) Why is this purported “Fact” included? This is a projection of something that “could” happen. That is not a fact; it is an opinion or a projection. I suggest it be removed from the document.

(22) No, the City does not need to be researching threatened and endangered species. The City is neither a university nor a scientific research facility. There are plenty of them around, but it should not become a city function to do this. I suggest eliminating this bullet.

(23) These land use programs and techniques have virtually no application to the City; they may be appropriate for jurisdictions that have substantial amounts of rural area. But that is not our situation.

(24) I’m not ready to promote the use of permanent conservation easements on private property. I will be very interested to see what federal incentive monies are ever offered for something like this.

(25) Issues like this are currently dealt with by our engineers. They need to continue to be aware of the latest techniques and strategies to deal with water. But this can and should happen without the involvement of either a Sustainability Coordinator or an SPAP.

(26) This is something that should be addressed and is being addressed by our Planners. There is no need for either a Sustainability Coordinator or an SPAP to address this.

(27) This introduces a fascinating issue. At some point we will have to come to grips with the conflict between the high cost of lighting and the reduction of crime and the increase of safety that are enhanced by lighting.

(28) This is already being adequately addressed.

(29) This is already being addressed through our city arborist. There is no need for either a Sustainability Coordinator or an SPAP to help.

(30) This is a ridiculous comparison: Comparing jobs generated from education spending to jobs generated from oil spending is like comparing apples with oranges. This should be deleted from the document.

(31) This entire action area should be eliminated. In an era of limited funds, there is no need for the City to attempt to establish “Sustainable Policies” in the county-controlled public schools that are located in the City. I will oppose spending city funds to get involved in this type of expenditure. It is more than sufficient to merely establish a City policy.

(32) This entire section area should also be eliminated. It is not the role of the City to educate the public about “Global Warming.” The City can have its policy about what its officials believe and what policy it endorses. But it is not the proper function of the City to undertake to educate the schools, businesses, industry and the public in general about global warming. This indoctrination has already been done by schools, colleges, politicians, media people and by state and federal governments. And much of the indoctrination that has taken place is bad science. Why should the City of Frederick take it upon ourselves to contribute to this pseudo-scientific debate? The answer is: We shouldn’t. What is it that the City has to say on this? Is the City going to teach that the temperature of the earth has increased 1.3 degrees Fahrenheit in the last 100 years? Are we going to point out that during the last ten years the almost undetectable increases in global warming have slowed or stopped? Are we going to teach that man is totally responsible for global warming? Are we going to explain the role the sun has played in this? Are we going to require all of the schools to show their students Al Gore’s anecdotal masterpiece, An Inconvenient Truth? Are we going to allow the students and public to consider any studies that refute or dispute claims of man-made global warming? (The recently released, U. S. Senate Environment and Public Works Committee Minority Staff Report dated December 11, 2008 [which is the product of over 650 prominent international scientists] disputes principal tenets of those who contend that global warming is man-made.)

The City should not be spending its time and money participating in the global warming debate.

I personally subscribe to many conservation practices, some of which are offered as helping to reduce global warming. While I don’t necessarily agree with that global climate preservation is accomplished through certain conservation practices, if there are other reasonable bases for the practices, then I can support them. I expect this to be the case with the SPAP. I believe we can find common ground for many specific policies and practices. To the extent we can do so, I would like to try to do this.

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