HomeMy WebLinkAboutminutes.council.19910624Aspen City Council Regular Meeting June 24, 1991
PROCLAMATION - Native American Indians 1
CITIZEN COMMENTS 1
COUNCILMEMBER COMMENTS 2
CONSENT CALENDAR 5
LIQUOR LICENSE RENEWALS - 5
LIQUOR LICENSE TRANSFER - Silve r City Grille 5
SPECIAL EVENT PERMITS - Eagle's Club; Aspen Theater Co. 6
REQUEST TO MODIFY PREMISES - Le gends of Aspen 6
ORDINANCE #25, SERIES OF 1991 - RFTA GMQS Exemption 6
ORDINANCE #26, SERIES OF 1991 - Aspen Mountain Lodge PUD
Section M Amendment 7
ORDINANCE #24, SERIES OF 1991 - Newspaper Racks 7
ORDINANCE #18, SERIES OF 1991 - Institutional Controls
Smuggler Superfund Site 8
CONCEPTUAL SPA RIO GRANDE 2 0
ORDINANCE #21, SERIES OF 1991 - Electrical Code Revision 20
ORDINANCE #27, SERIES OF 1991 - West Hopkins AH Rezoning 20
ORDINANCE #28, SERIES OF 1991 - PUD Amendment Clarendon 21
ELECTION OF MAYOR PRO TEM 22
COUNCIL APPOINTMENTS 22
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Aspen Citv Council _____ Regular Meeting June 24, 1991
Mayor Bennett called the meeting to order at 5:15 p.m. with
Councilmembers Richards, Reno, Peters and Pendleton present.
PROCLAMATION - Native American Indians
Mary Martin told Council she is chairman of a benefit sponsored by
the Smithsonian Institute. The activities will be held in Ashcroft
and will be celebrating native Americans. Mayor Bennett read a
proclamation declaring August 18 to 25 the Aspen celebration week
of Native Americans. Council presented the proclamation to Ms.
Martin
CITIZEN COMMENTS
1. Jeff Yusem, representing the Rotary Club, said in the past
they have given money to local organizations. The Rotary Club has
decided they would like to do a capital improvement project on a
Rotary Park. Yusem said there is not a larger park in Aspen for
people to have large events. Yusem said he has been working with
Carol O'Dowd, city manager, and George Robinson, parks department,
on the property next to Iselin park. Yusem said they would like to
have this designated as an area to develop a Rotary park. Ms.
O'Dowd said staff would like the ability to work on this proposal
and bring it back to Council. Yusem told Council the Rotary club
will be doing the work and donating the labor.
Councilwoman Pendleton said she would like to see something closer
to town. This area gets a lot of use from the schools. Yusem said
some ideas are to have a tot lot behind the pool, picnic areas
toward the river, volleyball courts. Yusem pointed out that
nothing in town is really large enough for this kind of park.
Councilwoman Richards said she would like to see how this meshes
with the long range comprehensive plan. Councilman Peters said
this review should start in the planning office so that the Rotary
club does not spend a lot of money on something that is not going
to get approved. Amy Margerum, planning director, told Council she
can review this quickly. The land is owned by the city but is
located in the county. Staff will put together the long term parks
plan and work up preliminary comments for Council.
2 . Hal Clifford asked i f the Ordinance # 2 4 , newspaper racks , wi 11
be tabled. USA Today has not been able to get someone from their
staff to be present for the hearing. Jed Caswall, city attorney,
said Council will take testimony at the public hearing and can
agree not to take final action until another date.
3. Mickey Herron, representing the applicant for Ordinance #17,
Tagert lot split, requested Council table this applications.
Neighbors have voiced concerns and they would like to work this out
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Aspen City Council Regular Meeting June 24, 1991
before the public hearing. John Foley, neighbor, concurred they
would like this tabled.
Councilman Peters moved to table Ordinance #17, Series of 1991, to
July 8; seconded by Councilwoman Richards. All in favor, motion
carried.
COUNCILMEMBER COMMENTS
1. Councilman Reno said he spent time at the Colorado Municipal
League conference and found the seminars very helpful. Councilman
Reno encouraged Council to participate next year if possible.
Mayor Bennett agreed.
2. Councilman Reno brought up the electric underground project;
last Tuesday there was a neighborhood meeting and people are
generally concerned that the project is too expensive. People want
to have their lines buried but are not willing to pay the price.
Councilman Reno said he does not want staff to continue spending
time and money if the city is going to end up with no result.
Carol O'Dowd, city manager, said she will report back to Council
exactly where the project is and if it should be ended.
3. Councilman Reno pointed out that the city day camp ends two
weeks before school starts. Councilman Reno said he has heard
different reasons for this. It puts a burden on a lot of parents.
Councilman Reno requested staff look into this. Councilman Reno
said the junior golf program is being offered free and perhaps the
day camp could get involved in this program. Carol O'Dowd, city
manager, said she will investigate these two issues and report
back.
4. Councilwoman Pendleton said she has no interest in the
electric underground program and would like to have staff drop
this. Carol O'Dowd, city manager, said there have been a series of
meetings to collect information. Staff is going to meet June 27 to
see if there is a recommendation to go forward. Councilwoman
Pendleton agreed with Councilman Reno there is not a realistic
price and suggested the process be stopped unless the citizens come
back stating they are willing to pay for it. Councilwoman Richards
said she feels uncomfortable making that decisions not having heard
from the homeowners. Councilwoman Pendleton said a duplex would be
charged $11, 0 0 0 per s fide to have the 1 fines buried to the structure .
Councilwoman Pendleton said if the neighbors are interested in the
undergrounding, they should bring this forward rather than wasting
staff time. Councilman Peters asked about putting the secondary
connections into the improvement district so the costs are easier
to bear. Councilman Peters agreed if the citizens do not want
this, Council should drop it. Mayor Bennett suggested Council get
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Aspen City Council Regular Meeting June 24. 1991
a summary of data to date without additional time being put into
this and discuss it at a future meeting.
5. Councilwoman Pendleton said as an advocate of employee
housing, she would like to see the city get moving on affordable
housing. Councilwoman Pendleton said there is a proposal from the
owners of 939 East Cooper to trade that property for the east
Hopkins site. Carol O'Dowd, city manager, told Council staff met
with the owners of 939 East Cooper and will report back to Council.
6. Councilwoman Richards requested staff draft a proclamation to
Esprit and Global Re-leaf for all the trees that were donated to
the art park.
7. Councilwoman Richards said for the transportation work session
scheduled July 1st, it is important to bring forward the existing
work towards making a pedestrian orientation to the town, the
elements that came out of the community comprehensive plan, the
town meetings, the pedestrian trails and bikeways committee, bring
up the discussion of delivery trucks and possible implementation
for this summer.
8. Councilwoman Richards said she would like to see a proposal
from the recreation department on how to survey their users.
Councilwoman Richards said she would like to find out if the needs
of the users are being met by the day camp and whether there are
enough afternoon programs to meet the needs of the families in the
area. Carol O'Dowd, city manager, said she had started some work
on the survey for the day camp users and will expand that work.
9. Councilwoman Richards moved to direct the planning staff to
evaluate the impacts of Burnt Mountain Ski Area on the city in
terms of transportation impacts, employee impacts to the affordable
housing program and to offer assistance to the county planners who
are working under a tight timeline to evaluate that development;
seconded by Councilman Peters.
Councilwoman Richards said Burnt Mountain is very close to Aspen
and she is concerned about the impacts to the affordable housing
program and how it relates to the transportation system. Council-
man Peters agreed Burnt Mountain development will create a major
impact on Aspen. Councilwoman Richards said the forest service is
compiling a new EIS including off-site impacts. The planning
office should be prepared to offer input on off-site impacts. Amy
Margerum, planning director, told Council the planning office is
working on Burnt Mountain and has been working with the County on
how to fit the process into the IGA. Ms. Margerum said she will
give Council an information memorandum for the next meeting.
All in favor, motion carried.
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Aspen Citv_Council Reaular Meeting June 24, 1991
10. Councilman Peters complemented the streets department and city
staff for putting down road base by the art park. It keeps the
dust down and is an enhancement for the area.
11. Councilman Peters asked that the police department begin
preliminary work on bicycle and pedestrian safety issues.
Councilman Peters said there are a number of decisions that need to
be made on where to concentrate police activities for monitoring
speed, crossing, etc. There are some street safety issues the
public works department would like to address, like Main street and
pedestrians. Carol O'Dowd, city manager, told Council some of
these issues will be covered in the transportation work session,
Monday, July 1st at 5 p.m.
12. Councilman Peters brought up the open house at the Marolt
project Sunday. Councilman Peters said Harry Teague and Richard
Shaw deserve applause; it is a public project that works well is
aesthetically pleasing.
13. Councilman Peters said he and Carr Kunze went to Frisco to a
meeting sponsored by region 12 on housing issues. Councilman
Peters told Council HUD will have money available to provide
affordable housing development. To get that money the state will
have to develop a comprehensive affordability strategy. The state
is looking for input on how to spend this money. Kunze was very
articulate in explaining local issues. Mayor Bennett said there
will also be housing authority discussions on July 1st after the
transportation work session.
14. Carol O'Dowd, city manager, requested Council reaffirm the
efforts to improve Independence Pass with ERG. Councilwoman
Richards moved to support Good Road Day on Independence Pass;
seconded by Councilman Peters. All in favor, motion carried.
15 . Carol O' Dowd, city manager, told Council there will be traffic
routing changes by the highway department at highway 82 and Cooper
Avenue next week. There will be no stop outbound on Original;
inbound will have a stop sign.
16. Jed Caswall, city attorney, told Council Tom Smith has
requested the appeal of code interpretation be tabled to July 8.
Councilwoman Richards moved to table appeal of code interpretation
to July 8; seconded by Councilwoman Pendleton. All in favor,
motion carried.
17. Amy Margerum, planning director, announced there is a
community planning meeting Thursday June 27th at 5:30 p.m. at city
hall. The two topics are growth management balance and carrying
capacity.
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Ashen City Council Regular Meeting June 24, 1991
18. Carol O'Dowd, city manager, said the Roaring Fork Valley Forum
will also meeting June 27th. There will be a bus to that meeting.
The trails task force is making a presentation on a trail from
Rifle to Aspen. The highway department is sponsoring a presenta-
tion by an English firm who has been working on their EIS and to
review the latest intelligent vehicle system technologies and how
this might be included in the EIS.
CONSENT CALENDAR
Councilwoman Richards moved to approve the consent calendar;
seconded by Councilwoman Pendleton. The consent calendar is
A. Minutes - May 29, 1991
B. Extension of Deadline for application Ice Rink/Park
C. Request from Aspen/Snowmass Repertory Theater
D. Forum Trails Task Force Appointments
E. Reconsideration of HPC appointments
Councilwoman Richards asked if the trails task force would be
working at cross purposes with the train group. Carol O'Dowd, city
manager, said there are no conflicts. Councilman Peters said
Council has not had the opportunity to interview the trails task
force appointments and talk about the potential conflict with the
railroad.
All in favor, motion carried.
Councilman Peters moved at the earliest convenience before or at
the next regular meeting both the Roaring Fork trails representa-
tives met with Council to discuss the trails and train goals;
seconded by Councilwoman Richards. Councilwoman Pendleton
suggested Lee Ambrose, the railroad representative, be invited
also. All in favor, motion carried.
LIQUOR LICENSE RENEWALS -
Councilwoman Richards moved to approve the liquor license renewals
for Takah Sushi and Home Plate; seconded by Councilman Reno. All
in favor, motion carried.
LIQUOR LICENSE TRANSFER - Silver City Grille
Councilwoman Richards moved to approve the liquor license transfer
to DSG Inc.; seconded by Councilman Peters.
Councilwoman Richards said over the past winter several outside
ownerships of liquor license establishments have left employees
without pay. Councilwoman Richards asked if there is an ability
for the city to require out-of-state owners to post bond toward
payment of employees. Council requested the city attorney's office
research this and report back.
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Aspen City Council Regular Meeting June 24, 1991
All in favor, motion carried.
SPECIAL EVENT PERMITS - Eagle's Club; Aspen Theater Co.
Councilman Reno moved to approve the special event permits for the
Eagle's Club and Aspen Theater Co; seconded by Councilwoman
Pendleton.
Jed Caswall, city attorney, told Council the state statutes require
a special event permit be posted for 10 days before the hearing in
order to allow the public a chance to comment. Caswall told
Council this event was only posted for 5 days. City Clerk Kathryn
Koch told Council this event for July 10th is with the French
National Rugby Club. There was not enough time to post for 10
days, get Council approval and get this to the state for the to
issue a license. Mayor Bennett said he is willing to take a risk
in not having this posted for 10 days.
All in favor, motion carried.
REQUEST TO MODIFY PREMISES - Legends of Aspen
Councilwoman Richards moved to approve the request to expand the
liquor licensed premises and have outdoor seating; seconded by
Councilman Peters. All in favor, motion carried.
ORDINANCE #25, SERIES OF 1991 - RFTA GMQS Exemption
(Councilman Reno stepped down due to conflict of interest). Dianne
Moore, planning office, recommended approval of this ordinance
approving a GMQS exemption for essential public facilities and
vested rights for the 440 square foot expansion of the Rubey Park
Transit center. Ms. Moore reminded Council at first reading they
requested staff to investigate whether other types of trees could
be planted on Durant avenue. George Robinson, parks department,
said the installation of 3 more trees would impede the movement of
pedestrians about the transit center. The parks department will
enhance the other landscaped areas. Councilwoman Richards said on
the plat of Rubey park and the hearing before the citizens, urban
treescape was very important to the program. Councilwoman
Richards pointed out this is the view of Aspen for many guests
getting off at Rubey park.
Patrick Stuckey said the concern is getting a tree that could live
in this area. Councilwoman Richards asked if there is adequate
irrigation to the tree wells. Councilwoman Richards said the plan
approved by the public has a line of tall willows and is a major
feature. Councilwoman Richards said she is not willing to let
these trees go. Stuckey told Council the circulation problem is
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Aspen City Council Regular Meeting June 24, 1991
one reason the trees were not planted in the first place.
Councilman Peters agreed with planting some trees and see if they
grow.
Mayor Bennett opened the public hearing.
Bil Dunaway agreed the trees are valuable and should be planted.
Mayor Bennett closed the public hearing.
Councilwoman Richards moved to adopt Ordinance #25, Series of 1991,
amending it to include planting of trees as shown on the original
landscape design of the building; seconded by Councilman Peters.
Roll call vote; Councilmembers Pendleton, yes; Richards, yes;
Peters, yes; Mayor Bennett, yes. Motion carried.
ORDINANCE #26, SERIES OF 1991 - Aspen Mountain Lodge PUD Section M
Amendment
Jed Caswall, city attorney, told Council this formally ratifies the
extensions on the construction schedule for the Ritz Carlton hotel
and other aspects of the Aspen Mountain Lodge.
Mayor Bennett opened the public hearing. There were no comments.
Mayor Bennett closed the public hearing.
Councilwoman Pendleton moved to adopt Ordinance #26, Series of
1991, on second reading; seconded by Councilman Reno.
Councilman Peters said the second whereas addresses the reasons for
the extensions and asked if this should say "some of the reasons".
Caswall pointed out the findings are attached to the ordinance and
show that some but not all of the reasons were found. Caswall said
he does not feel this is necessary in the ordinance. Councilwoman
Richards asked if there is a more clear cut answer as to what will
happen to the Ritz. Joe Imbriani told Council there is nothing
more known than what has been reported in the newspapers. Caswall
told Council one of the first conditions is that Savanah is to come
to an agreement with staff the form of the security to insure
demolition of the hotel if that is necessary. Caswall told Council
he and the applicant have agreed in principal to the form of the
security.
Roll call vote; Councilmembers Richards, yes; Reno, yes; Pendleton,
yes; Peters, yes; Mayor Bennett, yes. Motion carried.
ORDINANCE #24, SERIES OF 1991 - Newspaper Racks
John Worcester, city attorney's office, told Council there have
been minor changes since first reading.
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Aspen City Council Regular Meeting June 24, 1991
Mayor Bennett opened the public hearing.
Bil Dunaway, Aspen Times, said Council has a letter from USA Today
requesting this be tabled so they can be in attendance. The letter
also praises the city staff for preparing an ordinance that meets
many questions and satisfies much of the First Amendment. The
preamble of the ordinance explains the complications. Dunaway said
if there are going to be permits, the ordinance should state that
permits cannot be withheld. Dunaway said there is no good reason
not to allow newspaper racks in the mall area. Dunaway said by
limiting the number of racks in a certain area and having a raffle
for other areas, the city is bound to discriminate against other
papers. Dunaway suggested this be tabled so the problems can be
worked out before final adoption.
Councilwoman Richards moved to continue the public hearing to July
22, 1991; seconded by Councilman Peters.
Councilman Peters said the mall exclusions for newsracks are not
appropriate especially if the malls be expanded in the future.
Councilman Peters said he would like the city to get out of the
newsrack business. Councilman Peters said he does not want the
ordinance to define what is news. Councilman Peters said there
ought to be an automatic feature of the ordinance that allows
permits to issue without a lot of hassle. There should be some
guidance for the public works director that permits shall not be
unreasonably denied. This should be incorporated into the
ordinance. Councilman Peters said not requiring insurance may not
be a valid criticism. Councilman Peters requested the legal staff
investigate requiring insurance further.
Mayor Bennett agreed with Councilman Peters. Mayor Bennett
apologized to CCLC for any lack of knowledge that this had been
going on so long and the CCLC had met as often with the media as
they had. Councilwoman Richards said she much prefers the condo
rack configuration. Councilwoman Richards said she does not see
any sense in passing an ordinance which does not address the
premise of aesthetics.
Councilwoman Richards amended her motion to include a work session
July 15; seconded by Councilman Peters. All in favor, motion
carried.
All in favor, motion carried.
ORDINANCE #18, SERIES OF 1991 - Institutional Controls Smuggler
Superfund Site
Jed Caswall, city attorney, told Council this ordinance arises out
os EPA's efforts to remediate the Smuggler area. The ordinance
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Aspen City Council Regular Meeting June 24, 1991
resulted from negotiations between the county and EPA representa-
tives to try and minimize the remedy previously proposed for the
site. Caswall told Council because certain contaminated materials
are to remains on site after the remediation is completed, the
remedy calls for the local governmental entities with jurisdiction
over the site to adopt institutional controls; the purpose is to
try to preserve the integrity of the remedy once it is installed.
The ordinance is designed to operate for enforcement purposes out
of both the building department, which regulates excavations and
the environmental health department. The environmental health
department has been involved in this clean up plan and has a lot of
expertise which the building department does not have. The
environmental health department can contribute to the enforcement
and monitoring functions of the ordinance. Caswall said the
institutional controls are part of the remedy when it was chosen.
In March the city executed the superfund contract, between the
Colorado Department of Health, EPA, county and city. One of the
provisions in the agreement calls for the city to adopt institu-
tional controls. Caswall said there have been changes on whether
or not apartments and condominium complexes other than Hunter Creek
and Centennial would be required to submit maintenance plans. This
requirement may not be appropriate for all complexes in the area.
Staff agreed with the Justice department to put more flexibility in
the ordinance to allow the director of environmental health
department to make a determination whether a particular condominium
or apartment needs to prepare a maintenance plan.
Councilwoman Pendleton said she withdrew for conflict of interest
at first reading of this ordinance as she offered concrete bids on
this clean up. Councilwoman Pendleton said she has conferred with
the city attorney who has opined she does not have a conflict.
Councilwoman Pendleton asked Council if she could be part of this
discussion. Caswall said he does not believe her participation is
conflicted out. Council agreed Councilwoman Pendleton should stay
in the discussion.
Mayor Bennett opened the public hearing.
Richard Cohen asked the liability that faces the city if this
ordinance is not passed. Cohen asked the liability for the city if
the process goes through, the containment site is built and the
city does not enforce the regulations as the EPA set them out.
Nancy Mangone, assistant regional counsel assigned to Smuggler,
listed options of EPA if Council decides not to pass the institu-
tional controls; EPA could consider this a breech of the state
superfund contract; EPA has the option of ordering implementation
of institutional controls; the option of beginning the remedy on
certain areas; the option of designing a new remedy which does not
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Aspen Citv Council Regular Meetna___ June 24, 1991
incorporate institutional controls because they are not assured
this remedy without the institutional controls would be protective
of health and the environment. The EPA believes in this remedy
and believes it is protective of health and the environment with
the institutional controls. If the remedy goes forward, it will
address both the health risks and the financial uncertainties. Ms.
Mangone said if the institutional controls are not passed, the
health risks and financial uncertainties will be prolonged. This
would also jeopardize any settlements that have been entered into
or are being negotiated with private parties.
Mark Alston, chief Colorado section of superfund branch, said the
June 21st letter responded to questions of Council, went over
factors involved in identifying hazardous waste sites in arriving
at decisions proceeding into the remedial action at Smuggler.
Alston said there is data showing extremely high levels of lead and
cadmium at this site, averaging 3300 ppm. Lead is a very high
priority contaminate for EPA. The target level in soils is 500 to
1000 ppm. This site is 3 times that. Alston told Council any lead
levels in blood are not thought to be of natural occurrence. Blood
level studies are one way of assessing exposure. There is a state
blood level study of which preliminary results have been released.
This study showed low blood levels at this site. Alston said the
superfund program is intended to and mandated to be very conserva-
tive in addressing risk from hazardous waste and in trying to cut
pathways of exposure. Alston said the EPA has determined there is
a potential risk to health at this site. The EPA feels the remedy
selected of excavation and replacing with clean soils is a
protective remedy. Alston said the EPA feels strongly that the air
monitoring and dust control measures will be protective and there
will not be elevated levels of blood due to the remediation.
Alston said the EPA's experience across the county let them say
that. Alston said the EPA feels it is important to go forward and
requested Council pass the institutional controls ordinance
John Moscato, Department of Justice legal representative for EPA,
said the first alternative would be an action on the contract which
would either be for specific performance of the contract or more
probably damages. The damages would be of 2 types; damages
incurred by the EPA because of loss of time, contract costs, etc.,
and damages for obtaining alternative performance, some alternative
means to remedy the site. Moscato said under 104, the EPA has
ability to compel responsible parties to do work. Under 106, there
is authority to direct through unilateral orders that parties take
abatement actions. These do not have to be responsible parties.
The city has not been approached to date as a responsible party.
Moscato said there are actions under 107 that would allow the EPA
to go forward and do the work and collect the costs from responsi-
ble parties. Moscato said there are sanctions in superfund that
permit the imposition of treble damages should EPA prevail on 104,
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Aspen City Council Reqular Meeting June 24, 1991
106 and 107 orders. This is in addition of penalties of up to
$25,000 per day. The damages would be triple the additional costs.
These are the legal options. There is the option of re-evaluating
the remedy. In this instance, this would prolong the difficulties
of this community.
Moscato said people have a chance to comment during the Record of
Decision, a chance 90 days after a site is listed on the National
Priorities List to take an appeal to the Court of Appeals. After
90 days, one has lost the opportunity to challenge the listing.
Moscato said there has been one site that has been removed; it was
not a listed site, it was a proposed site. Moscato said the only
way to remove a site from the NPL, short of remediating it, is an
act of Congress.
Nick DeWolfe said the reason this community has not risen earlier
is that no one could believe this audacious project was for real.
DeWolfe urged Council to review the very basis, the premises on
which the entire project rests. DeWolfe urged Council not sign the
remediation and surrender their rights to go to Congress. DeWolfe
said it would be irresponsible to lie down and let this irresponsi-
ble project go on. DeWolfe said the first move is to demonstrate
there is no danger in the site in the first place. DeWolfe said
proper technical advice, which does not come from the EPA, should
be sought. DeWolfe invited Council to a hearing June 29th on lead
poisoning.
Tom Clapper asked if the cure for a certain disease is greater than
the disease, CERCLA law states the clean up will not be done.
Clapper said the people have shown that the cure is a lot worse
than the disease. Clapper said there is a greater danger due to
the trucks rolling and dust in the air than to leave it where it
is. Clapper requested Council vote against this ordinance. Alston
said if anyone in the community has scientific evidence to submit
that has been overlooked, it can be forwarded to EPA. Alston said
the EPA has been conducting their business in the open. This
testimony seems a bit late. Under the statute, if the remedy poses
a threat of endangerment, it will be re-examined. The EPA would be
happy to consider evidence on that point. Alston stated the
program people have assured that the remedy can be conducted so
that no additional lead will be introduced into the air. The EPA
has worked with the environmental health department on air
monitoring to insure there is a means to detect any problems and to
stop work immediately and to correct the situation. Alston said
also in CERCLA there is great deference to the agency's decision to
remediate a site and to its expertise. In any challenge, whether
or not a remedy is needed, the plaintiff would have an unusually
high burden.
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Aspen Citv Council Regular Meeting June 24, 1991
Jim West said the key word is potential; the potential in the
future for children to become lead contaminated, to develop lead
poisoning. West said he sees no point in disturbing the soil when
it has been compacted over a period of time and has been covered by
lawns or other things to the point where there is no demonstrable
high level of lead poisoning at this time. Ten years from now if
there is a case of lead poisoning it would make sense to tear up
the land. West said there is no guarantee that if the soil is
disturbed there will not be consequential problems in the future.
The EPA is speculating.
Roxanne McClure asked about the air monitoring and how the EPA will
water down the soil, and not erode into the river. Ms. McClure
asked what will control the exposure of lead to the residents.
Alston said the EPA is comfortable with the experience they have at
other sites that their dust mitigation measures can keep exposures
to zero or to where they cannot be detected with air monitoring
equipment. Ray Pliness, Bureau of Reclamation, told Council tests
have been done in the 0 to 12 inch range. Of those tests, the
first tier was 0 to 2 inches. Pliness said runoff can effect very
quickly 0 to 2 inches worth of soil. Pliness said within that 2
inches there was very high levels of lead in many areas. There
already is a drainage problem. Pliness said to mitigate this and
where they are digging, they keep in contact with the weather
service. This is bordered. If there is a potential chance for
rain storms, this is bordered with either sand bags or an air bag.
The first defence is that the contractors are only allowed 8 hours.
Anything that is excavated out has to be replaced within 8 hours or
a geotextile has to be laid over the top. Geotextile will not
prevent water from going down but it will prevent surface water
from bringing soils back up.
Someone asked about Molly Gibson, which is going to be open for the
next 5 or 10 years, will this have sand bags. Pliness said the
Molly Gibson has 2 solutions; one is slope backed during the
remediation. There is a starter dike in front and the water stays
behind. It is also sloped to the back of the berm and it filters
down. Any water on the surface is caught at the bottom with the
toe drain and re-directed down to the ground.
Stan Lauriski said the dirt is being moved about 400 feet from
people's houses to a higher elevation. Lauriski asked how many
cubic yards of dirt will be moved. Pliness said this is estimated
at 26, 000 cubic yards of dirt to be moved. Lauriski said this will
also have to hauled back in. Mayor Bennett said it was stated in
the earlier meeting that one repository would be 30 feet high and
the other 40 feet high.
Lucy Dunn said her primary concern is for her 2 children. Ms. Dunn
said she asked a toxicologist how he would feel about the safety of
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Aspen Citv Council Regular Meeting June 24, 1991
children. This toxicologist suggested Ms. Dunn stay inside with
the doors and windows closed and have dust blinders on the house.
Ms . Dunn asked how the EPA can say the remedy is not dangerous when
it is recommended to stay inside. Alston stated the EPA believes
they can monitor the levels that go off site and can do this
mitigation and that the remedy is protective and the measures used
will not result in increased exposures. Alston said for families
with children there are temporary relocation plans. Alston said if
there are concerns about health and the EPA has concerns about site
safety, they can offer temporary relocation.
Bob Elkington said the EPA cannot tell people they have to keep
children in the house for up to 6 days while their property is
being remediated. Elkington said a fence has to be erected and the
EPA has to maximize the ability to get construction equipment in to
move dirt around. Elkington said people with children and dogs can
be relocated. Ms. Dunn said she was told by the EPA that she will
be told where she can relocate. Someone said a written relocation
program is needed. Elkington told Council the final relocation
plan has not been approved but it is very close. Pliness said the
relocation program is to give an option for people with children if
they so wish. Ms. Dunn said the EPA is telling her they can
protect her children. Ms. Dunn said that is her job and she does
not need the EPA to do this.
Moscato said relocation is to protect people from the hazards of
construction activity. Moscato said to protect people from the
hazards associated with remediation, they are instituting dust
control measures and air monitoring. Relocation is not because of
the threat of dust, principally, but from construction activity.
Moscato said in terms of where people will be relocated, the EPA is
looking for places locally. If people chose to go elsewhere, it
presents a problem to the EPA as they are accountable for that
expense. Pliness told Council they have contractors in the
competitive range. The average remediation will be 6 days. They
require all lots to be done within 12 days. A person said their
concerns are lead in the air; airborne lead is supposed to be more
hazardous. This person told Council she and her son were tested
and were below the range. They asked what happens if there are
elevated blood levels after this is over; do they get to sue the
EPA. Alston said the EPA is somewhat liable for negligence.
Moscato said there is an sovereign immunity which says one cannot
sue the government unless it lets you. Moscato said there are
federal torts and claims which allows people to bring action
against the U. S. government for negligence, gross negligence,
intentional misconduct, etc. should people believe injuries to
themselves are caused by negligent acts of agents of the govern-
ment.
13
Aspen Citv Council Reqular__Meeting June 24, 1991
Mike Garrish told Council he has lived in this area for 79 years.
Garrish said his relatives lived here and lived to 80s and 90s and
none of them had lead poisoning. Garrish asked if the residents
just sit and pay taxes with no recourse to a not favored project.
Garrish said there are tons and tons of mine tailings that have
been scattered all over this town. Garrish asked how come other
sites have not been inspected. Garrish said the Smuggler area is
victim of selective sampling that has been going on. Garrish said
he wants to know what kind of soil will be brought in to put on his
garden. Garrish says he does not want dirt from the airport.
Pliness said they will use soil that is representative of both
growth potential as well as free of contaminants. Material at the
airport has been provided cost free from the county as a potential
source as backfill, not top soil. The remedy is 8 inches of
backfill and 4 inches of top soil, except for gardens which is 18
full inches of top soil.
Amy Brownstein said there is a lot of support for Council not to
adopt the institutional controls. Council is the last hope of the
residents. Ms. Brownstein said there have been allegations of
misuse of funds in Washington. Ms. Brownstein said just because no
one has not been delisted does not mean this site cannot get
delisted. Ms. Brownstein said when the EPA is finished with
operable unit 1, they will go up Smuggler. Ms. Brownstein said
this will make a terrible mess for the entire town. Ms. Brownstein
said the EPA is wrong here; the agenda of the EPA is not wrong and
there are places that need remediation but not here.
Ray Devega said the issue confronting the community is not lead but
land. Devega said the EPA seems to be into the land grabbing
business. The EPA has closed down thousands of small gas stations
around the country. People cannot borrow money from banks because
the EPA has condemned their land. People cannot sell their land
for the same reasons. Devega said the land in the Smuggler area is
owned by people of modest means. They cannot borrow money against
their land. Wink Jaffee said lawyers are explaining the danger
rather than doctors and scientists. Jaffee said it has not been
proven medically or academically that this area is in danger.
Jaffee said if this area is really in danger, it should be cleaned
up.
Ward Hauenstein said each component of the institutional controls
look logical; however, .the root of the problem is the residents
feel they are getting raped. The whole process is wrong.
Hauenstein said the people on site want to get delisted. There is
nothing that has demonstrated there is a problem with the health of
the people on site. Hauenstein said it is the chance for Council
to say the law is not right. Pat Simpson told Council last summer
a resident went and got the health department to do blood level
testing; the EPA fought that. The EPA then said people should not
14
Aspen City Council Regular Meeting June 24, 1991
take credence in the results of these tests because the blood lead
levels are only good for one month. Ms. Simpson said the lead in
one's blood after a time is absorbed in one's marrow and does not
show up in blood tests. Ms. Simpson said the residents should be
tested all during this and any time one's blood level goes up they
should be able to litigate against the EPA. Ms. Simpson begged
Council not to sign the agreement with the EPA.
Alston said the EPA realizes there is disagreement over the risk at
the Smuggler superfund site; in the judgement of the EPA there is
potential risk at the site. Alston said the blood lead screening
request was honored. The position of the EPA is that they are
pleased the levels turned out low. The EPA feels blood level
screening is a snapshot and that there is a risk in the Smuggler
area that should be remediated. Terry Hale said the issue is
should this work be done. Hale said for the last 8 years the
county government has relied on the experts of the EPA and never
went outside the community. Hale said when the residents called
the Colorado School of Mines and public health pediatricians, and
lead toxicologists who all said this is bullshit. Hale said the
community is united in giving this issue the light of day and will
find out the answers. Hale urged Council to delay signing the
institutional controls until the community can amass some opinions
that do not come from the EPA. Phoebe Ryerson asked for hands of
people who would like the EPA to gracefully remove themselves.
Richard Compton said Council should ask themselves if there is a
demonstrated need for the institutional controls. Compton said
that need has not been demonstrated through the whole process.
Compton urged Council to join with the residents and community who
want to take this to Congress and get the law changed; get the site
delisted, and work to get the EPA working in a way that serves the
residents. June Kirkwood said it is totally unacceptable to have
this remediation done. Ms. Kirkwood said the residents are not
asking "Big Brother" for help. Ms. Kirkwood said she does not feel
like she has freedom of choice and that her rights and dignity are
being offended.
Dave Harris said he tested out of the clean up. Harris asked the
EPA if he would be involved in the institutional controls. Harris
said the EPA told him it is what is under the 18 inches of soil
tested that he has to be part of the institutional controls.
Harris said this is not logical, which would determine that his
property is clean. Harris questioned having the institutional
controls on this property. Moscato said the institutional controls
apply over the site. Kirk Baker said people working for the EPA in
the superfund site have agreed this is totally ridiculous. Baker
urged Council not go to along with the institutional controls.
15
Aspen City Council Regular Meeting June 24, 1991
Patti Wade asked if the geotextile liner has any drainage through
it. Pliness said this is a felt material with more drainage that
the adjacent soil. It is highly permeable and will not stop any
water. The intent of the geotextile is for a noticeable barrier.
Ms. Wade asked if a resident breaks this, do they get sued for
destructing the remediation. Moscato said one point of the
institutional controls was to return to the locality a discretion
on how to enforce the regulations. The institutional controls
address when replacing trees and how to do it. There is no intent
on the part of the United States to sue someone for digging up a
bush. Ms. Wade asked if it is recommended that residents put
things that need to go in the ground more than 18 inches prior to
the remediation. Dunlop said there are interim guidelines
established by the guidelines.
Kirk Baker said what is recommended for dust control has been to
water it down. Baker said the earlier remediation totally flooded
the Molly Gibson and the dirt went right into the river. Baker
said this dust control is just moving the lead from one place to
another, into the river. Pliness said the material put on the
Molly Gibson park was to eliminate any wind erosion . The work done
on the Molly Gibson was a soil stabilizer. The operator of the
vehicle did dump some soil stabilizer in the streets. There was a
problem and it was dealt with. Pliness said the soil stabilizer
reduces wind blown contaminants. Baker suggested that the area
would stay more stable if left alone rather than tearing it up.
Baker asked if it causes more erosion by digging the area up.
Pliness said digging this area up, moving it to a repository and
covering it with permanent facilities will reduce the opportunities
for erosion of that lead contaminated materials.
Stephanie Costello said the problem is the potential risk of lead
contamination. Ms. Costello said the residents do not appear to
have lead toxicity in their bloods, the EPA is basing this clean up
on a potential health risk. Ms. Costello said 25,000 cubic yards
of dirt will be moved; thousands of particles of lead will be
flying around into the .air. Ms. Costello pointed out this is a
valley and the particles will be caught in the valley. Ms.
Costello said the clean up will create a potential health risk.
Tim Anderson said the EPA does not appear to know what they are
doing or this would have been much more concise and done in a more
timely fashion. Anderson agreed with getting some help from
outside the community to help the process. The EPA has taken over
the residents lives.
Grafton Smith supported Council not passing this ordinance. Smith
said there will be about 10,000 dump truck loads. The danger from
that outweighs the potential risk. Smith asked what the EPA will
have to destroy to bring in thousands of yards of dirt. Smith
asked how much money has been spent to date on this process and how
16
Aspen City Council Regular Meeting June 24, 1991
much money is yet to be spent. Mayor Bennett asked how many truck
loads there will be. Pliness said 5,000 round trip. DeWolfe
suggested the community prepare to make the EPA liable. Jeff
Winagle told Council he has grown up on the superfund site.
Winagle asked what the EPA is willing to do for the city in
replacing roads, bridges; 2500 dump truck loads coming from out of
town is a lot.
Mangone told Council the EPA started out with a remedy calling for
4 feet of excavation and progressively have tried to work with the
community to get a remedy that was more palatable. This remedy
includes institutional controls and takes into account getting a
remedy that was less intrusive than the original remedy. Peter
Wirth said the EPA went from 4 feet to 1 foot of soil because there
was no place to put the soil. Barry Siegel said the issue here is
not health. There are mine tailings all over town. Siegel said he
wants to know what the Molly Gibson repository will look like.
Siegel said this neighborhood will have a true dump site; the
residents were promised Molly Gibson would be a park. Siegel asked
when Council ever approved a project without knowing what it looks
like.
Moscato said there will be more trees on site when this is finished
than there are now. The EPA has made steps to preserve trees over
6 inches in diameter. Pliness said he believes the people he is
working with have the ability to make the decisions regarding the
clean up. Pliness said the repository will be a rock based 40 foot
hill on 2.5 to 1 slope at the bottom with a 6 foot high fence. The
EPA has this shown as a rock topped. The dimensions are 100 by 150
feet. Siegel asked what happens when one of the boulders runs down
the hill. Pliness said there are 3 to 8 inch size cobbles which
will be held in place by the slope. Caswall pointed out the
repository is not within the city's jurisdiction. Councilwoman
Richards said she did go to the BOCC and asked for a mock up of the
repository site.
Richie Cohen asked why it takes 6 days to clean up on trailer site
down 1 foot of dirt. Cohen asked if there is a way to delay the
start of this project in order to get more mitigation measures or
to come to another conclusion. Alston said this project has been
going on for a long time and prior to this time the EPA has been
proceeding because they felt people wanted this finished and it
would be best for the community to get it over. Ms. Mangone said
the EPA has tried to work through a number of issues with the
community. The city indicated they wanted to go forward by signing
the superfund contract and starting the institutional controls.
Moscato said this site has been annexed into the city recently.
Cohen said there will be an enormous structure built on the other
side of town from the Ritz. Cohen said he would support Council
turning this down.
17
Aspen Citv Council Regular Meeting June 24, 1991
Jan Wirth read a letter to Council stating Council has been charged
with the public health and safety of the entire community. Council
cannot be pressured into this action without satisfactory answers
to all questions. Ms. Wirth said the sequence of events over the
last 8 years has been totally inappropriate and mistakes have been
made. Ms. Wirth said the city has not been involved for most of
the last 8 years. Ms. Wirth said if another entity came into town
and wanted to build a hotel, a ski area or a mine, the first thing
that would be required would be an EIS . The community needs to the
city have the EIS done right now in order to analyze the secondary
impacts of the clean up on the community before one truck load of
dirt in moved. Questions that needs to be answered are what is the
impact of thousands of truck loads of dirt going through town; how
will this affect the roads and bridges; what will the noise levels
be; what will be the effect on the overall air quality and the
quality of life; what are the long term costs and effects of the
institutional controls; what does the permit process really mean
and how does that affect everyone; what will happen when the sewer
lines need to be replaced; what are the hidden costs everyone will
pay after the EPA is gone.
Angie Griffiths told Council she has lived in this area all her
life, owns a home and has had a business in town. Ms. Griffiths
recently tried to get a loan and was turned down due to her house
being in the superfund site. Bob Cox, Smuggler Caucus, told
Council he has been involved since 1981. The medical community has
started coming in to answer the question of whether there is a
problem or not. The EPA has always said they do not have to prove
this. The medical community has offered assistance to bring in
other experts and they should be given a chance to see whether
there is a problem. Cox asked about page 6 of the institutional
controls where it says if one digs up their dirt below the
geotextile liner and leave it open for more than 5 days, a 6 foot
fence has to be put around and it has to be covered with an
impermeable top. Cox said surface contamination has been sitting
around for years and asked why there is now concern to cover it.
Moscato said the reason there is a requirement in the institutional
controls that applies after a property is remediated is because the
United States will have gone through the expense of remediating
that property and asks that property owners take safeguards to
contain that soil when it is dug up. Cox said from the day the EPA
walked in to do their testing it was skewed. Cox said the EPA
started with digging up 4 feet of soil, which the residents
negotiated down to 1 foot with the EPA. Walt said if Council says
no, the community will not have to keep talking.
Council decided to continue the hearing for two weeks. Ms. Mangone
requested Council come up with a list of questions to help clarify
the issues. Councilwoman Pendleton said if the lead is so low in
18
Aspen City Council Regular Meeting June 24, 1991
this neighborhood, why isn't the EPA willing to find out why it is
so low. Councilwoman Pendleton asked if it is so unreasonable for
the EPA to consider why this area is so low and to look into this
a little deeper and not go by the rules and regulations. Council-
woman Pendleton said she would like some willingness of the part of
the EPA to look at this again.
Alston said because of the correlation across the county between
soils and blood leads that the preliminary results of the state
have not shown and the EPA has not explained that discrepancy.
Alston said there are different tools to look at risks. The
state's blood level study did not show an actual risk that
correlates to the potential risk that the EPA thinks is there.
Alston said the EPA has been asked to prove there is a risk. To
the EPA this means damage has already occurred. The mandate of the
EPA is to prevent the risk and to remove the potential risks if
they exist. Alston said blood level studies do not meet the EPA's
statutory, their highest statutory mandate is to have a permanent
and protective remedy.
Councilwoman Pendleton requested the EPA look at "their" law.
Councilwoman Pendleton said there is a point where people have to
look at what is going on. Just because the word is in EPA's by-
laws does not make it right. Councilwoman Pendleton requested the
whole process be looked at by both sides. Moscato said the EPA did
not happen into the question of lead yesterday and have not ignored
blood lead studies. EPA has determined that blood lead studies are
one means of predicting the health of the community and the
potential risks. The EPA has determined over time there are
general correlations between lead in soil and lead in blood. The
agency has tried hard over the last year to move forward to solve
what is wrong in the Smuggler area. Blood lead studies are not a
definitive predictor of health threats.
Mayor Bennett said what Council would like to hear is hard evidence
that there really is a health risk. Alston said the EPA is not
saying there is an actual risk; they have not proven that. Mayor
Bennett said in theory if there has been a risk in this area and it
has been there for 100 years, it should have shown up somewhere.
Moscato said lead is insidious because its effects are subtle.
Councilwoman Pendleton said the EPA's policy is not to accept blood
levels. Councilwoman Pendleton said she is challenging the word
"potential" and requesting the EPA look at it and see if it a
realistic way to deal with this situation.
Councilman Peters moved to suspend the rules and extend the meeting
to 10:15 p.m.; seconded by Councilwoman Pendleton. All in favor,
motion carried.
19
Aspen City Council Regular Meeting June 24, 1991
Moscato said a presentation to Council on risks and safeguards
during the remedy will be helpful. Council agreed.
Councilwoman Pendleton moved to continue the public hearing to July
8, 1991; seconded by Councilwoman Richards. All in favor, motion
carried.
CONCEPTUAL SPA RIO GRANDE
Leslie Lamont, planning office, told Council there are 3 applica-
tions for this property; the trolley, art park/theater, recycling.
The application will need at least one hour.
Councilwoman Pendleton moved to continue the conceptual SPA on the
Rio Grande to July 22; seconded by Councilman Peters. All in
favor, motion carried.
ORDINANCE #21, SERIES OF 1991 - Electrical Code Revision
Tom Parry, building department, told Council the last reference to
an electric code is 1978. This is the 1990 code and should be
adopted by Council.
Councilwoman Pendleton moved to read Ordinance #21, Series of 1991;
seconded by Councilman Peters. All in favor, motion carried.
ORDINANCE #21
(Series of 1991)
AN ORDINANCE AMENDING SECTION 7-156 THROUGH 7-162 AND
SECTION 7-166 OF ARTICLE VI OF CHAPTER 7 OF THE MUNICIPAL
CODE OF THE CITY OF ASPEN, COLORADO, SUCH SECTIONS
ADOPTING AND AMENDING CERTAIN PROVISIONS OF THE NATIONAL
ELECTRICAL CODE, 1990 EDITION was read by the city
clerk
Councilman Reno moved to adopt Ordinance #21, Series of 1991, on
first reading; seconded by Councilwoman Pendleton. Roll call vote;
Councilmembers Peters, yes; Richards, yes; Reno, yes; Pendleton,
yes; Bennett, yes. Motion carried.
ORDINANCE #27, SERIES OF 1991 - West Hopkins AH Rezoning
Councilwoman Richards moved to read Ordinance #27, Series of 1991;
seconded by Councilwoman Pendleton. All in favor, motion carried.
ORDINANCE #27
(Series of 1991)
20
Aspen City Council Regular Meeting June 24, 1991
AN ORDINANCE OF THE ASPEN CITY COUNCIL GRANTING A
REZONING FROM MEDIUM-DENSITY RESIDENTIAL (R-6) TO
AFFORDABLE HOUSING (AH) LOTS K, L, M & N, BLOCK 19, THE
SOUTHWEST CORNER OF WEST HOPKINS AVENUE AND SOUTH SEVENTH
STREET, ASPEN, COLORADO, was read by the city clerk
Bob Nevins, housing authority planner, told Council the rezoning is
the first step in this affordable housing project and will allow
them to move forward with the production plan.
Councilwoman Richards moved to adopt Ordinance #27, Series of 1991,
on first reading; seconded by Councilwoman Pendleton. Roll call
vote; Councilmembers Reno, yes; Peters, yes; Pendleton, yes;
Richards, yes; Mayor Bennett, yes. Motion carried.
ORDINANCE #28, SERIES OF 1991 - PUD Amendment Clarendon
Councilman Reno moved to read Ordinance #28, Series of 1991;
seconded by Councilwoman Richards. All in favor, motion carried.
ORDINANCE #28
(Series of 1991)
AN ORDINANCE OF THE ASPEN CITY COUNCIL GRANTING A PUD
AMENDMENT FOR THE ADDITION OF BEDROOMS AND BAY WINDOWS,
AND THE EXPANSION OF LIVING ROOMS AND GENERAL LIVING
SPACE TO THE CLARENDON CONDOMINIUMS, LOT 1 CLARENDON
SUBDIVISION, WEST END STREET, ASPEN, COLORADO was read
by the city clerk
Leslie Lamont, planning office, told Council this is not considered
an insubstantial PUD amendment. This is a two step process; the
P & Z reviewed the proposal and recommends approval. Ms. Lamont
told Council at second reading staff will have a presentation
including graphics. Councilwoman Richards asked if the increased
square footage means the applicants have to address employee
mitigation. Ms. Lamont said only a residential growth management
application has to mitigation employee housing. Ms. Lamont said
there are no new units. Councilman Peters asked if this were not
expanding a non-conforming use. Ms. Lamont said this is an R-6 PUD
overlay and they are using the PUD amendment process. Councilwoman
Richards asked if there are any objections from the neighbors . Ms .
Lamont said no. Spencer Schiffer, representing the applicant, told
Council this project has the lowest density in the entire area.
Councilman Reno moved to adopt Ordinance #28, Series of 1991, on
first reading; seconded by Councilman Peters. Roll call vote;
Councilmembers Peters, yes; Pendleton, yes; Reno, yes; Richards,
yes; Mayor Bennett, yes. Motion carried.
21
Aspen City Council Regular Meeting June 24, 1991
ELECTION OF MAYOR PRO TEM
Councilwoman Richards moved to nominate Councilman Peters as Mayor
Pro Tem; seconded by Mayor Bennett. All in favor, with the
exception of Councilmember Pendleton and Reno. Motion carried.
COUNCIL APPOINTMENTS
CAST - Mayor Bennett
CML - Carol O'Dowd, city manager,
NWCCOG - Councilman Peters
Housing - Councilman Peters
Ruedi Water and Power Authority - Councilwoman Pendleton
Roaring Fork Forum - Mayor Bennett
Sister Cities - Councilman Reno; Mayor Bennett
Nordic Council - Council will talk to the Nordic Council
Energy Committee - Councilmembers Pendleton, Richards and Bill
Stirling
In-town School Sites - Councilmembers Peters and Reno and Bill
Stirling
ASAP Community partnership for a healthy community - Council-
woman Pendleton
Councilwoman Richards nominated Councilwoman Pendleton to serve as
the Council representative to RFTA; seconded by Councilman Peters.
All in favor, motion carried.
Councilwoman Pendleton nominate Councilwoman Richards to the
Snowmass Aspen Arts Council; seconded by Councilman Reno. All in
favor, motion carried.
Jed Caswall, city attorney, told Council he had received a letter
from the regional administrator for the EPA in response to a
request made by Senator Wirth. Sheer will be available in Denver
to meet with Council the afternoon of July 3 or July 5th. The
earliest Sheer can come to Aspen is July 10. Mayor Bennett
suggested Sheer be invited to Aspen to meet with Council July 10.
Council scheduled a work session on the Kraut property on Monday,
July 15th at 5 p.m.
Councilwoman Richards moved to adjourn at 10:25 p.m.; seconded by
Councilwoman Pendleton. All in favor, motion carried.
Kathryn S- Koch, City Clerk
22