Get On With It Already!

For over a year now our City leadership and staff have been debating and deliberating over whether or not to adopt a resolution to set a goal of sourcing 100% of our electricity from renewable resources by 2030. The debates over resolutions, and goals, and long term plans drive me crazy! Ask anyone, “Do you think we should minimize pollution from energy sources?” Almost everyone will say “YES!” Ask, “when should we do it?”. The answer is “As Soon As Possible!”

How does it take a year to say that setting a goal, which everyone wants to strive towards, is a good idea? Adopting a resolution is like making a proclamation. It has no legal standing. It simply says, “We think this is a good idea.” This is the most luke warm thing that could possibly be done and our City has dedicated valuable staff time and resources for over a year debating this. Longmont took about a month in January to get it done. 80 other cities and two states have done it. The upside of taking so long to deliberate on this is that the community has been engaged. The outcomes of that outreach are completely predictable (the enviros support bold action, the Chamber of Commerce is afraid of change), but at least awareness has been raised.

In the mean time, the climate keeps changing and tangible solutions are out there waiting to be deployed. To be fair, the City is pursuing wind and solar options, but they are soooo slow and the actions they are taking are yesterday's news. Innovative they are not. We need to be taking bold steps to promote solar on rooftops and parking lots. We need to aggressively pursue electric vehicles. Maybe most importantly, we need to discover and develop our local energy storage solutions. 

CforSE is pushing for real, tangible, concrete actions. A resolution is nice but we have more important things to do. Dear City Council, Get on with it!

The case for Amendment 1

Full-time pay for Full-time work

In 2017 City Council pay was $9,480 per year. That pays for less than 10 hours per week. To do the best job, council is a 40-hour per week job. Half of the current council members have other jobs and can’t give 40 hours to council. The council members who do give 40 hrs per week are paid less than $5 an hour.

Council is responsible for:

·   Approving and supervising a $500 million per year budget.

·   Overseeing a 2,000 employee staff.

·   Answering to 161,000 constituents.

·   Making the decisions that shape Fort Collins

The Full-Time Council workweek looks something like:

·   15 hours - Researching topics from Advertising to Zoning.

·   15 hours - Official and community meetings.

·   5 hours - Meeting with individual constituents.

·   5 hours - Meeting with City staff leaders.

Area Median Income is a fair wage

The Fort Collins Area Median Income is about $60,000/yr, roughly the salary of a city bus driver, parks maintenance tech, police dispatcher, and librarian.

The money (~$550k) will come from savings generated not a tax increase. Council routinely over-funds projects without a thorough review of performance or need. One example is the $500k annually for solar rebates that are no longer needed. A professional City Council will identify these opportunities and save money.

Amendment 1 is not related to the tax question on the ballot.

For more information visit:  www.FTCFTCblog.wordpress.com

Community for Sustainable Energy supports Amendment 1 because:

Vital sustainability concerns are not being adequately addressed.

·      Cost of living is outpacing wages.

·      We are missing targets in the Climate Action Plan.

·      Creative solutions like solar for schools are not being pursued.

City Council is not responsive to CforSE members

·      It took over a year for council to adopt the 100% Renewable Electricity by 2030 goal despite widespread support.

·      Council has not adequately responded about solar policy.

·      Council dismissed calls to explore Amtrak to Denver.

A decent salary will allow council to spend more time on sustainability.

·      Council needs hours of education/research on sustainability.

·      Council needs hours to hear more from citizens and experts.

·      Council needs to know how to better direct City staff action.

A decent salary will attract better-qualified candidates on sustainability.

·      Trained professionals need (and deserve) a professional salary.

·      People who have to work for a living will be able to serve.

·      More diverse representation improves outcomes.

Electric Rates. Is this gonna be a problem?

The new Fort Collins electric rate structure is a big financial risk and doesn’t take in account our growing use of wind and solar.

The new structure increases rates during busy hours, or “peak hours”, of the day and lowers rates for the rest of the day (off peak). This is new to Fort Collins but other utilities have been doing it for years. The goal is usually to get people to reduce electric consumption (load) during peak times and shift their load to off peak times. This saves customers and the utility money.

Will you change the time of day that you use electricity to save money? You could blast the AC until 2pm and then turn it off to “coast” through the evening. You could run your appliances after 7pm. By doing just those things you could probably shift half of your load and save a decent amount of money.

That doesn’t sound too hard right? Well City Council doesn’t think you can do it. In fact, they are betting that people will not shift more than about 9% of their load. If they made a bad bet then our utility will not have enough revenue to meet the budget. This is a big risk. Our electric utility has been operating at a deficit for years. We already have 15% rate increases planned over the next 4 years. Customers of other utilities with time of day rates have significantly shifted load. If Fort Collins customers do the same then we will be facing even higher rate increases.

The Time Of Day (TOD) rate is soooo 2015! Back then coal and gas were the cheapest fuel for electricity and TOD made a lot of sense. Wind and solar are changing the electric landscape. In California electricity is now often cheapest when the sun is shining and the wind is blowing. That is usually during peak hours. This will be the reality in Fort Collins before we know it. We will be getting over 50% of our electricity from renewable resources by 2021, and possibly 100% by 2030. Excel plans to get over 50% renewable electricity by 2026. There is a very real risk that wholesale electricity will be cheapest when our utility is charging us the most. It took Fort Collins Utilities four years to develop this rate structure. We need to get working on the next one now if we are going to ready for the renewable electricity reality.

What we want to do is set a rate that encourages a matching of demand to supply. This is often called “dynamic rates”. A simple dynamic rate can be timed to predictable wind and solar production times. If our wind and solar produces the most from 2-4pm (typically) then we set the rate low from 2-4pm every day. That wouldn’t change on a cloudy day, the revenue difference would be absorbed in the utility’s annual average. A “smart” dynamic rate would change every hour of every day depending on real-time wind/solar production. Electric cars could use this rate to micromanage charging times. A “smart thermostat” could turn the AC on and off to match solar production. Household batteries could charge during cheap times and discharge during expensive hours. You could micromanage your load and bill each day but it probably wouldn’t be worth the effort for the small stuff. And if you don’t have the cool new “smart”toys you will still save money compared to the TOD rate.

The point is that the Time Of Day rates are out of date because they will soon not reflect when electricity is cheapest. In addition, they could potentially cause huge rate increases. A few of us utility nerds have pointed this out and were basically told to shut up and don’t worry about it. If TOD goes as planned then I will be the first person to say that I am wrong. If it does turn into a disaster then I will be publicly calling for the resignations of those responsible.

What do you think?

100% Renewable Energy Update

If you became a member of CforSE within the past year then you are probably one of the 2,300 people who signed our petition calling on Fort Collins City Council to set the goal of generating 100% of our electricity from renewable sources by 2030. It is a goal that over 60 cities around the country have adopted including Longmont. A handful of cities claim to have already achieved this goal. I say claim to because what they are doing is "net 100%". They are still using electricity generated by fossil fuels but are buying enough renewable energy to offset the fossil fuel usage. This is a great thing to do, but it is a little disingenuous to claim 100% renewable. 

The Northern Colorado Partners for Clean Energy (of which we are a part) are pushing for 100% generated renewable energy by 2030. The difference is that we need to store excess energy generated by wind and solar for use when the sun don't shine and the wind don't blow. Storage technology isn't quite there yet to make this happen in an affordable way but is expected to be by 2030. Nay sayers say that we shouldn't set this goal because we don't have a clear path to achieving it. To which I quote President Kennedy. In 1961 he wanted the U.S. to go to the moon by 1969. We didn't know how to do it, but we set the goal and we got it done. Our goal is much more attainable.

In May we (Fort Collins Partners for Clean Energy) presented a draft resolution for city council to adopt this goal. Mayor Troxell balked at the idea of a "grand statement" claiming that the goal was only a political statement. Council directed staff to research the idea (see above). The funny thing is that to achieve our climate action goals we almost certainly have to achieve 100% REx2030. The Mayor loves the "grand statement" of our Climate Action Goals and touts it all across the country. 

You can help by writing Mayor Troxell and City leaders (cityleaders@fcgov.com) and asking him to adopt the 100% renewable energy by 2030 goal.

Fort Collins City Council fails through obfuscation and delay

Overall our City government performs very well, as evidenced by our many awards. However, there are... areas of opportunity. One such area is communication and accountability between council and staff. Council is supposed to give staff clear direction on a topic. Staff is supposed to follow that direction. Unfortunately the process frequently breaks down. This has happened recently with our campaign for the City to set a goal of 100% renewable electricity by 2030 and with our "rent your roof" campaign for the utility to rent roofs/parking lots for solar panels. 

Obfuscate - (verb) render unclear, obscure, or unintelligible

Regarding "Rent your Roof", council gave very confusing and weak direction to staff. One council-member timidly asked for a feasibility study, one asked for a scoping study, and the Mayor confused everything by asked for a study of all distributed energy models.  There was no consensus of what council was asking. The City Manager said that the direction was clear but gave no confirmation of what that direction was. To no surprise, the staff action plan was vague and mostly off topic. Council didn't correct staff, probably because they didn't know what it was they had asked staff to do. 

Delay - (verb) make something late or slow

This topic was assigned to a January work-session, then delayed to February, then delayed until May. Finally, after 7 months, staff presented the results of their work to council. This presentation would not have passed my undergrad classes at CSU back in the '90s. It was incomplete, inaccurate, and off topic. I know it was inaccurate because I pointed it out and staff made a correction. But council didn't understand what they were looking at because after all that delay we were back to our old friend, obfuscation. The result? More delay! Council gave staff another two years to do more of whatever it is they did and there is no expectation of concrete results. Staff could come back to council in two years with the same thing.

In the case of 100% renewable electricity by 2030 the direction was a little more clear, "Study the feasibility of achieving the goal". Staff delayed by waiting for a "Net Zero Carbon Study" from PRPA (our power provider). In this case they obfuscated by hiding their work behind the PRPA study and mixing it in with a Climate Action Plan update. No to worry, council wasn't upset. They simply asked staff to come up with something in a month's time. So staff got to work. They presented a set of obfuscated questions and topics to two citizen boards and spent the majority of time talking about the definition of "renewable electricity". Their report to council was due last week and it appears that they will ask for council for a... delay!

So what the hell are we gonna do about this? Well after 12 years of being on the citizen side of the podium, I've had enough! I've decided to run for City Council District 6. I'm running because I believe that I can help fix the process problems that are limiting the City's progress on a range of important issues facing our community. 

To deal with the obfuscate and delay problem I will require the City Manager to recite council direction when given. This will allow council to clarify any miscommunications right from the start. Next, the follow-up memo from staff should be signed off on by all council-members. Delays happen, but need stronger justification. When the topic does come up for discussion the original direction from council will be on the first page. Council can ask, "How does your work address our original concern?" These steps should provide clarity and accountability for staff and for council.

This problem is one symptom of a root problem of council not having the time and resources to do the best job that can be done. Right now council members are paid for about 7 hours of work per week (less than $10k/yr). Many people familiar with the council role say that to do the best job possible requires 40 hours per week. To address this root problem CforSE is advocating to make city council a full-time position paid at Area Median Income with reporting requirements so that citizens can see that their elected (and paid) officials are doing their job.

You can help in a few ways. From August to November we will be circulating a petition to get "Full-Time City Council" on the April ballot. We will need about 8,000 signatures. We would love to have your help gathering signatures, fundraising, or just signing the petition and spreading the word!

Thank you again!

Getting Fastrack back on track

In 2004, Boulder County citizens contracted the Regional Transportation District (RTD) to build a commuter rail between Denver/Boulder/Longmont by 2017. To date, taxpayers have paid over $180 million. Due to a lack of funding and increased costs RTD says the rail will not be completed until after 2040. The question now is, “What is the best path forward?”

RTD is studying Bus Rapid Transit (BRT) for Hwy 119. The idea is that the bus travels independently from traffic, and so, much faster. They expect to have the study completed by the end of the year.

RTD is also exploring a rush hour train. Three trains would run in the morning and evening. This would also be much faster than traffic and a direct step towards completing the promised FasTracks. RTD does not have an official study underway as they do for BRT.

The costs, funding sources, and feasibility of either option are still largely unknown. For this reason we believe RTD should complete a study of BRT and Rush Hour Rail, including all potential funding sources, before pursuing either or both.

Please share your opinion by writing a short note to the Boulder County Commissioners. Should RTD study both options thoroughly or move ahead with one or the other, or both? Without public input RTD may choose the path of least resistance. They need to hear from you!

Thank you!!

PRPA studies "Net Zero Carbon" by 2030

From our friends at Rocky Mountain Institute

 

Net-Zero Future at Cost Parity with Coal—In the Heart of Coal Country

March 8, 2018

Platte River Power Authority (PRPA), the generating authority that serves Fort Collins—a community Rocky Mountain Institute has been working with for a long time—and three other Colorado cities recently got the results of a study it commissioned on the relative costs of transitioning to net-zero carbon generation by 2030. The results of the study, by a subsidiary of power-industry giant Siemens, are… electrifying. The study found that, using relatively conservative assumptions for solar and wind costs, and without considering demand-side efforts, PRPA can deliver a net-zero carbon generation portfolio for a cost premium of only 8 percent over the lifetime of the planning horizon (2018–2050).

This is significant not only because the estimated (net present value) difference in cost is so small, but also because it indicates the actual cost premium may be even lower than 8 percent. The Siemens study was conservative in its estimates of price declines for renewables over the coming years, and was released before the shockingly low bids for wind and solar that another Colorado utility, Xcel, received in an RFP were made public. The median prices of the 350 renewables-only bids that Xcel received were lower than any seen in the U.S. before. In fact, the median bids Xcel got in 2017 were 26 percent lower for wind power and 10 percent lower for solar power than the costs the Siemens study assumes will prevail in 2030, after 13 more years of price declines. The study was also conservative in that it didn’t consider any energy efficiency or demand-response strategies in its net-zero carbon portfolio, even though Fort Collins Utilities is already winning awards for its efforts in those areas, and plans to scale them up.

But it is most significant because PRPA is a power generator in the heart of coal country, just to the south of Wyoming’s vast Powder River Basin coal reserves. Wyoming produced 41 percent of U.S coal in 2016, and the majority of U.S. coal productioncomes from the Mountain states, including Colorado. PRPA owns three coal-burning power plants that produce most of its power, and even (together with three other electric utilities) owns and operates its own coal mine next to two of its power plants. The power that PRPA produces by burning coal is about as cheap as coal power can get, and its coal-fired facilities are among the highest-performing in the U.S.

PRPA is the lowest-cost wholesale power producer in the state of Colorado. If switching to a net-zero carbon generation portfolio is essentially cost neutral for PRPA, then coal’s time has truly run out.

Tweet

Fort Collins’s Path to Decarbonization

At the initial urging of Fort Collins Utilities—one of the four Northern Colorado municipal electric cooperatives that own PRPA—and ultimately at the request of all of its members, PRPA embarked on the study. When Fort Collins began asking for the study, it took the latest step in meeting its remarkably ambitious climate action plan. Starting in 1999, Fort Collins has been leading climate and carbon efforts, first by setting greenhouse gas (GHG) reduction goals and offering clean energy to its customers. Then, in 2008, it set bolder GHG goals and founded FortZED, a zero-energy district and proving ground for energy innovations jump-started by a $6.3 million grant from the Department of Energy and matched by similar funding from the community. RMI and others supported FortZED, and RMI has been proud to work with Fort Collins ever since. Fort Collins has won severalawards for energy innovation.

In 2008, the City of Fort Collins initially aimed for an 80 percent reduction in its greenhouse gas emissions by 2050 but, with RMI’s help, revised that goal to reach an 80 percent GHG reduction 20 years faster. This wasn’t rash optimism; Fort Collins worked with RMI to do a full analysis of its energy use in the buildings, transportation, and electricity sectors that was modeled on the Reinventing Fire analysis. The goal of reaching an 80 percent GHG reduction is also 20 years faster than the Reinventing Fire vision for the U.S. economy, but is achievable for Fort Collins and its city-owned electric distribution utility, Fort Collins Utilities. One of the biggest hurdles to achieving that vision, however, had long been the city’s electric power supply, which comes from coal-heavy PRPA. With this study, that hurdle is down.

Renewables Can Compete—and Win—Anywhere

The Siemens study that PRPA commissioned is a game changer because it is not the result of a cost decline for a single resource like wind or solar. News of dramatically lower prices for single renewable resources have become commonplace. Instead, the new net-zero carbon study results show a dramatically low cost for the total cost of delivered electricity, incorporating transmission costs and balancing charges to meet the same level of service provided by PRPA’s current portfolio. It is proof that there are no hidden pitfalls that might somehow make cheap renewable resources inoperable in practice. And the fact that a net-zero path can achieve cost parity against coal in coal country shows that renewables can compete anywhere.

Indeed, the median prices Xcel received from developers show that building new wind and solar generation sources is much cheaper than operating existing coal generation facilities—even wind-plus-storage came in below the cost of operating existing coal generation. The median price bid for wind power was $18.10/MWh, $6.51/MWh less than the study’s assumed cost of wind power in 2030. The median price bid for solar power was $29.50/MWh, $3.45/MWh less than the study’s assumed 2030 cost. On the other hand, purists might note that PRPA’s net-zero carbon portfolio does use natural gas, rather than batteries, for balancing variable renewables, and then relies on exports of renewables to achieve net-zero carbon. For those critics, we’d note that Xcel’s recent wind-plus-storage bids, at a median price of $21/MWh, are lower than the assumed current price for wind alone in PRPA’s study, suggesting that batteries are likely to edge out natural gas in the near term. By 2030, the costs of wind, solar, storage, and their combinations will no doubt drop further, but even if they were to stay level, the true cost of switching to net-zero carbon will be well below the 8 percent cost premium the study predicts.

Another major cost-reduction driver the study left out is demand-side management and energy efficiency. Fort Collins, one of the four consumers of PRPA’s power, happens to be a national leader in those areas. Fort Collins Utilities recently won a national award for its programs, which are part of an integrated utility services business model developed with RMI’s help. Fort Collins helps its residents achieve energy efficiency and participate in demand management by not only making proven programs available to them, but also by allowing them to finance up-front costs on their utility bills. Energy efficiency and demand management can have a dramatic effect on peak loads, reducing the need for high-capacity transmission systems or power generation, and thus reducing cost. The study also did not consider the potential for distributed energy resources like storage and demand response to reduce capacity charges still further. These, too, should keep the true cost of achieving net-zero carbon in PRPA’s system well below the 8 percent increase the study predicted.

An Unlikely Climate Hero

Fort Collins has earned a prominent place as a global climate leader over nearly 20 years. And another of PRPA’s municipal owners, Longmont, just adopted a goal to use 100 percent carbon-free electricity by 2030. Now, its generation and transmission utility is bidding to take its place beside Fort Collins Utilities and Longmont. PRPA’s CEO announced in January 2018 that the utility will immediately triple its portfolio of wind power with 150 megawatts of new wind capacity. PRPA, a coal-powered and coal-mining utility in the heart of western coal country, is an unlikely climate hero. But its clear-eyed, hardheaded calculations have put it on a path to decarbonize quickly and profoundly—to become net-zero carbon in 12 years. No matter how commonplace that becomes years from now, their market leadership is something to be celebrated, and emulated.

FTC Climate Action Plan

As a member of the Climate Action Plan (CAP) Citizen Advisory Committee I get to meet with 20 other citizens from various backgrounds and with City staff every quarter to discuss CAP related issues. There are some things that are going well. There are some areas that present a lot of opportunity for improvement.

One thing that staff is doing well is soliciting input from a cross section of our community. There are energy experts, business people, school district representatives, and civic groups represented on the board. We sometimes have lively discussion! A common criticism is that our feedback does not translate into policy actions. For example, we are presented with budget requests after they are turned in for review. Our feedback doesn't inform the request. Staff is working on this problem.

The greatest opportunity for improvement may lay in prioritization of action. Instead of prioritizing stronger energy efficiency programs, more democratic solar policy, or electric vehicle incentives staff spent a ridiculous amount of time and money trying to change the name of the CAP. In the end (after about 6 months) they decided that our group was right and they should stick with "Climate Action Plan".

One area where staff wants to improve is in public outreach and education. I have explained to them that CforSE knocks on doors 5 days per week and that in a year we will knock on almost every door in town (~50,000 mostly single family homes). We would happily distribute City literature and talk to folks about the Climate Action Plan. So far they are not interested in our services and are instead struggling with on-line outreach and bill inserts. Apparently not many people read the bill inserts. Staff is not satisfied with their outreach results so maybe they will come around to using the citizen networks that are in place, like CforSE.

PVREA elections

March is PVREA election time. This year we have four amazing, forward looking candidates to put on the Board of Directors! If you are a PVREA member you can vote for all four. Ballots go in the mail March 7th and are postage paid, so no excuses for not voting!

The four candidates are: Karen Stockley, Karen Conduff, Adrian Sweeney, and David Pierson.

A little more about the candidates:

David Pierson - I have been a member of PVREA since 2002. As a retired Air Traffic Controller, I have spent my life in the background: processing data, formulating plans, making decisions, and acting from a dark room to protect the public. I feel that now is the time to step forward.

The energy needs of Northern Colorado and PVREA will do nothing but rise in the coming years, and meeting that need will be essential for our members. PVREA currently enjoys one of the lowest rates for energy in all of Colorado, and to continue that, we need to be proactive in planning for the future. I won’t make promises for specific proposals—doing so when you don’t have access to all data is disingenuous.

I do propose meeting our future energy needs through renewable energy, and replacing older energy sources whenever and wherever practical. The benefits of this approach are numerous: first, by building renewable energy projects locally, JOBS will be created locally; second, because these emerging technologies are currently cost-competitive, and getting cheaper every day, this will help KEEP OUR COSTS LOWER; third, it will help keep our environment CLEANER; and also, the costs to maintain these types of facilities will be LESS THAN current maintenance costs.

Karen Conduff - I want to be your representative on the PVREA board to help speed up this transition to renewable energy. I have worked in the solar industry for a decade, been a PVREA member since 1988 and  I would appreciate your vote if you think embracing the future is a sound business model. 

Adrian Sweeney - Rural Larimer resident, Adrian “Buzz” Sweeney, would bring a wealth of business experience to PVREA’s Board of Directors.

While most corporations are governed by their stockholders and aim to make a profit, the PVREA board exists to ensure our electricity is stable, affordable, and benefits our community. As a member of the democratically-elected PVREA board, I would work to ensure the customer always comes first, and that as much money as possible is staying in our local economy. 

I have hands-on experience in managing corporations, major purchasing agreements, and taking care of the customer. I will do my best as a board member to keep electricity rates low, ensure PVREA is making the best choice for our economy and environment by making smart transitions towards renewable energy, and represent our community values.

Karen Stockley - My name is Karen Stockley, and I’m running to represent you as a PVREA Director. As a local business owner and community leader, I will advocate for affordable, sustainable, reliable energy in our cooperative. I have lived in Colorado for over 50 years, and my husband and I reside west of Berthoud. We have raised 5 children (and many 4H-featured farm animals!) here. We love our rural home and are proud members of the Poudre Valley Rural Electric Association. I have the public service and business experience necessary to lead the PVREA in the best interest of its member/owners. I’ve served the community for almost 30 years, volunteering in schools, Berthoud’s Planning and Zoning Commission, and as Treasurer on the Thompson Board of Education. I am also a local business owner, running Front Range Antiques for over 12 years. I know the importance of reliable, low cost energy for businesses and homeowners. My business experience and my budget expertise would serve our cooperative well on the board. Energy production and storage are rapidly changing, and PVREA must face these changes. Solar and wind energy are comparable in cost to coal; implementing cleaner energy into our portfolio is an exciting opportunity to save money and protect our community. New grid technology and storage possibilities can keep our grids safe, reliable, and affordable for generations to come. These exciting opportunities require leadership that explores new possibilities that benefit all members/owners. As your Director, I will steer PVREA towards an affordable, responsible future.

Solar on Open Space?

October memo to council about energy development on Fort Collins Open Spaces and Natural Areas.

**correction in comments below

Solar panels belong on parking lots and rooftops not Natural Areas and Open Spaces! In October city council received a memo concerning proposals to develop wind and solar resources on Fort Collins Natural Areas and Open Spaces. Fort Collins Natural Areas director, John Stokes expects this to be a "challenging conversation" with the community. I agree. We did not spent hundreds of millions of dollars to preserve land so that it could be developed as energy parks!

The memo refers to one specific proposal to put transmission lines across SoapStone Prairie Natural Area. This is a proposal that merits careful consideration. Soapstone was purchased by the City (for $11 million) to preserve the natural and cultural resources of the property. Potential wind resources lay on the other side of Soapstone and it would cost a lot of money to route the transmission lines around the property. So we will have a decision to make, as a community, about those transmission lines. CforSE will stay up to date as this project progresses and keep you informed and ask for your input at the right time.

The memo also mentions unspecified proposals to develop solar and wind resources on City owned Natural Areas. This we must not allow!