Transmittal - 12/4/2023ERIN MENDENHALL DEPARTMENT of COMMUNITY
Mayor and NEIGHBORHOODS
Blake Thomas
Director
SALT LAKE CITY CORPORATION
451 SOUTH STATE STREET, ROOM 404 WWW.SLC.GOV
P.O. BOX 145486, SALT LAKE CITY, UTAH 84114-5486 TEL 801.535.6230 FAX 801.535.6005
CITY COUNCIL TRANSMITTAL
Date Received: _________________ ________________________
Rachel Otto, Chief of Staff Date sent to Council: _________________
______________________________________________________________________________
TO: Salt Lake City Council DATE:
Darin Mano, Chair
FROM: Blake Thomas, Director, Department of Community & Neighborhoods
__________________________
SUBJECT: Landscaping and Buffers Chapter Text Amendment
STAFF CONTACT: Nan Larsen, Senior Planner
nannette.larsen@slcgov.com or 801-535-7645
DOCUMENT TYPE: Ordinance
RECOMMENDATION: Adopt the Landscaping and Buffers Ordinance as recommended by
the Planning Commission.
BUDGET IMPACT: None
BACKGROUND/DISCUSSION: This is a text amendment for a complete rewrite and
reorganization of the Landscaping and Buffers Chapter of the zoning ordinance to better support
the City’s adopted policies related to reducing water use, enhancement of the urban forest,
reduction in the urban heat island, improve air quality, and improvements to air quality and green
infrastructure city-wide. Reorganization and clarity of the ordinance was of upmost importance
for both the public’s understanding and for city administration.
On September 6, 2022, the Planning Division and Public Utilities held a work session with the
City Council to get initial feedback on priorities related to changes to landscaping regulations to
help achieve city policies and goals. The report that was prepared for the City Council briefing is
included in the staff report to the Planning Commission as found in Planning Commission records
b). The proposed Landscaping and Buffers Chapter changes are based on the feedback received
11/27/2023
- # '*//*җ уѶ20231фѷ3уҘ 12/0у/2023
12/0у/2023
2
from the Council during the briefing, feedback from several departments including Public Utilities,
Urban Forestry, and Enforcement, begins to implement strategies in the Urban Forest Action Plan.
ZONING REGULATIONS AND LANDSCAPING:
Title 21A, SLC zoning code, regulates landscaping in several ways for several purposes.
Generally, landscaping is regulated in the zoning code to reduce the heat island effect, reduce
stormwater runoff, reduce auditory and visual impacts of certain uses, improve aesthetics, and
make use of the health benefits of being in a more natural environment. These goals are
accomplished by regulating landscaping in certain locations of a property depending on the use or
district.
The zoning code regulates landscaping in the following locations:
Park strips: The strip of vegetation that is usually between the street and the sidewalk. Park
strips vary in size and form, different standards for different park strip sizes are
proposed.
Yard areas: Front or corner side yards are identified as required landscaped yards. Yard
areas are where the building is required to be setback from the property line, where
buildings are prohibited, and other structures like fences and sheds are limited. Outside
of a required landscaped yard, there are no specific vegetation requirements in a
required yard, except for buffer yards (if required) or parking lot landscaping (if
applicable).
Buffers: The purpose of buffer areas is to mitigate potential impacts between dissimilar
zoning districts. Landscaping in buffer areas is utilized to reduce auditory or visual
impacts on an adjoining property.
Parking lots: Landscaping standards in parking lots are utilized to reduce the auditory,
visual, or temperature impacts of a large surface area that is paved. This type of
landscaping takes the form of interior and perimeter parking lot landscaping and
generally applies to parking lots with 10 or more stalls.
PROPOSED AMENDMENTS:
What’s Staying?
Several standards that are currently required in the landscaping chapter will remain:,
- Regulated landscaping locations.
- 33% vegetation standard.
- 20% hard surfacing limitations.
- Landscaping and irrigation designed depending on watering needs.
- Drip and spray irrigation on separate valves.
- Park Strip less than 36” in width are exempt from some landscaping standards.
- Landscaping buffer tree and shrub quantities.
- Mulching depth and permeability standards.
3
- And encroachment standards in the park strip or public right of way.
- Maintaining the City’s resident’s eligibility for “rip your strip” rebate programs through
the CUWCD (Central Utah Water Conservancy District) and Utah Department of Natural
Resources.
What’s New?
The significant new additions to the landscaping chapter aim to:
- Improve water conservation by:
o Requiring a landscaping or irrigation professional letter of compliance with
irrigation and landscaping standards.
o Requiring a WaterSense automatic irrigation controller.
o Prohibiting water waste.
o Creating standards for irrigation systems to be designed and maintained to
maximize water efficiency.
- Simplify and clarify through:
o Requiring separate plans for planting, grading, and irrigation.
o Addressing artificial turf.
o Consolidating buffer sizes.
o Updating the Freeway Landscape buffer better comply with goals and intent of
chapter.
o Creating tables and graphics where possible.
o Removing duplicate or wordy standards that were difficult to implement.
o Quantifying, where possible, minimum landscaping standards.
- Prioritizing trees by:
o Allowing tree canopy to count toward vegetation coverage standards and
requiring the largest tree appropriate to the landscape location in most zoning
districts.
o Ensuring tree health by requiring Urban Forestry review of alterations to street
trees and root zone protection.
o Improving tree survival rates by requiring a permanent irrigation system for street
trees when a landscape plan is required (new construction, or a commercial
property where the landscaping is being updated by 50% or more, or a
commercial addition that increases the floor area by 50% or more).
o Requiring trees in the Northwest Quadrant.
- Reduce the urban heat island by:
o Creating parking lot landscaping standards directed at reducing the urban heat
island effect.
o Establishing rock mulch limitations.
o Allowing tree canopy to count toward landscape coverage and requiring street
trees where new construction is proposed.
- Reduce stormwater runoff by:
4
o Allow stormwater curb cuts.
o Require bioretention for parking lots with 50 or more stalls in the Parking Chapter
(21A.44).
SUMMARY OF PROPOSED LANDSCAPING AND BUFFERS CHAPTER:
The proposed Landscaping and Buffers Chapter is outlined and briefly described below:
21A.48: Landscaping and Buffers
Purpose and Intent: Explains the purpose of establishing a landscape chapter and
the intent of the standards.
- Increase tree canopy, protect and preserve
public trees, reduce heat island, reduce
stormwater runoff, improve air quality,
enhance community appearance from the
public realm, mitigate impacts through
buffer between uses, and promote water
conservation.
Applicability: Applies to all properties in SLC, any updates must
comply. Existing landscaping that does not comply with
the regulations of the chapter do not need to come into
compliance unless there is a change made to the
landscaping for single- and two- family districts, or if the
floor area or the number of parking stalls required
increases by 50% or more for all other uses.
Authority: What modifications can be applied; Zoning Administrator
may make modifications to standards to better comply with
the intent of the chapter, or in coordination with the Urban
Forestry, Police, or Public Utilities.
Responsibility &
Maintenance:
Establishes the responsibilities of the property owner and
ongoing maintenance required in regard to landscaping
maintenance in general, landscape yards, park strips, street
trees, and irrigation.
- Clearance from the public right-of-way.
- Maintained in good condition.
- Lists specific responsibilities for street
trees and irrigation systems.
- Height limitations within the sight distance
triangle to prevent vision obstructions from
approaching traffic.
Landscape Plan: Required for new construction of a primary structure and
when an addition increases the floor area by 50%, or modifies
any required landscaping by 50% .
- Landscape plans require a planning plan, a
grading plan, and an irrigation plan. Lists
specific criteria for each.
5
- Requires Landscape Architect licensed
with the State or a US-EPA WaterSense
certified professional signature and letter of
completion.
Landscape Requirements: Describes required landscape locations, landscape location
sizes, and specific landscape standards per location.
Landscape locations include park strip, landscaped yards,
surface parking lot landscaping, and buffer areas.
- Establishes minimum ground coverage and
tree planting in all landscape areas.
- Describes locations where turf is permitted,
and the coverage allowed.
- Describes impervious surface coverage
maximums.
- Establishes where landscape buffers are
required, the size, location, and coverage,
shrub, and tree planting requirements.
Parking Lot Landscaping: Applies to surface parking lots with 10 or more stalls.
- Interior landscape areas and perimeter
parking lot landscaping required. Describes
size, location, exceptions, and vegetation
requirements in these areas that include
trees, shrubs, and ground cover.
- Curbs are required where no biodetention is
utilized.
Standards: Requires specific landscape installation and landscape
material standards that apply to all regulated landscaping
locations.
- Requires drought tolerant, adaptive, or
native species.
- Establishes limitations and standards on
turf, mulch, and berming. Prohibits
artificial turf.
- Describes specific park strip material
standards that includes ground cover
regulations, pathways, stormwater
detention allowances, and permitted
encroachments.
Private Lands Tree
Preservation:
Establishes process and standards for removing a tree on
private lands. This section has not been changed, it is expected
the Urban Forestry Division will update this section in the
coming years as they continue to work on updates to better
respond to the Urban Forest Action Plan.
Appeal: Right to appeal statement.
6
PLANNING COMMISSION RECOMMENDATION:
On April 26, 2023, the Planning Commission held a public hearing on the proposed text
amendment and voted 10 to 1 to recommend that the City Council adopt the proposed Landscaping
and Buffers Chapter amendments with two recommended modifications to the draft ordinance:
• Define a landscape or irrigation specialist.
The draft ordinance language has been updated to address this and now requires review
and signature by a Landscape Architect, licensed with the State of Utah, or a US-EPA
WaterSense Labeled Certified Professional. The previous draft included a generalized
statement about a landscaping or irrigation professional, during the Planning Commission
hearing comments questions were raised on the need to define what constitutes a
landscaping or irrigation professional.
• Remove all language that permits artificial turf.
The existing Landscaping and Buffers chapter does not allow artificial turf in required
landscaped locations. The chapter draft the Planning Commission reviewed on April 26th,
permitted artificial turf in front and corner yard landscaping locations as an impervious
surface, which is limited to a maximum of 20% of the required landscaping. In all other
required landscaping locations, artificial turf was prohibited. Additionally, artificial turf
would have had to meet certain material standards such as individual grass blade length
and quantity as well as infill material type. With the Planning Commission’s recommended
modification, the artificial material standards and its inclusion in the impervious surface
has been removed. Now included in the draft language is a statement that artificial turf is
prohibited anywhere landscaping is regulated by the chapter. Where landscaping is not
regulated in this chapter, artificial turf would be allowed (such as the rear yard), as it is
today in unregulated landscaping areas. The commission’s recommendation was based on
a discussion centered around artificial turfs impact on stormwater runoff and possible
harmful chemicals contained in the manufacturing process.
MODIFICATIONS MADE AFTER PLANNING COMMISSION REVIEW:
Following the positive recommendation from Planning Commission, planning staff made
corrections to the draft chapter for the City Council to consider. The current draft ordinance
reflects these changes:
Landscaping buffer
table
- Inconsistencies were found and updated between specific district
landscaping buffer references, within the I, RP, EI, and MU districts,
and the proposed chapter’s required landscaping buffers. Also updated
the table to maintain a required landscaping buffer between multi-
family residential and commercial districts, residential and Business
Park, residential and Research Park, and required a landscaping buffer
in Extractive Industries and Mobile Home Districts when abutting any
zoning district. Added a buffer between manufacturing districts and
open space.
7
- Included language that a freeway landscape buffer is required on
properties abutting a freeway.
Parking lot
landscaping
- Added a provision that parking lot interior landscaping must include no
less than 5% of the total parking lot. This provision ensures there is
sufficient amount of landscaping to reduce the urban heat island effect
regardless of the parking lot design.
- Deleted the vehicle sales and lease lot provision that required a 5’
landscaping buffer in the front and corner side yard. The parking lot
perimeter landscaping provision already ensures that a greater setback
with sufficient landscaping would apply.
- Included in the perimeter parking lot landscaping specific section
references of 21A.44.060 and 21A.36.020 that address where a parking
lot may be allowed in a yard area.
- Clarified that the perimeter parking lot landscaping that abuts a building
does not need to be included in the tree calculation. Clarified that the
vehicle overhang area may be included in the perimeter parking lot
landscaping width.
- Specified parking lot interior landscaping allowed locations, minimum
size, and ratio of trees and shrubs required.
- Specified in 21A.44.060 that parking lots with 10 or more stalls or
within 20’ of a lot line are subject to the landscaping chapter.
Landscaping
graphics
- Consolidated the residential and nonresidential landscaping locations
graphics into a single graphic that addresses both residential and
nonresidential zoning districts. Updated the parking lot landscaping
graphics to show the approximate number of trees required based on
approximated scale and size of the interior and perimeter parking lot
landscaping areas.
Revision - Revised the purpose and intent section in the landscaping chapter that
simplified language and listed purposes and intents based on priority.
Multiple Section
Deletions
- Landscaping related terms and definitions as they are no longer
referenced in the ordnance: Evapotranspiration rate, Best Management
Practice, Landscape BMPs manual, Evergreen and Perennial,
Overspray, Maximum extent practicable, Tier 2 water target, Treasured
landscape, Landscaping vegetation, Water budget, and a duplicative
Street tree definition.
- Language in the applicability section that referenced that the entire
chapter 48 may be exempted if permitted in other sections of the zoning
code. There are no other sections that allow for an exception from the
entire chapter 48, specific sections exception language within the
proposed chapter have remained.
- Removal of Bond requirement to comply with State Code.
Multiple Section
Clarifications
- In the landscape requirements section of the landscaping chapter
clarified that where conflict between specific district standards and this
landscaping chapter the specific district standards shall prevail.
- In the Foothills and Foothills Protection District removed titles in the
landscape plan requirements to be consistent with the rest of the section.
8
- Clarified precedence language in the Design Standards section where
conflicting language may occur between the design standards and the
district specific standards. Clarified where percent tree canopy coverage
is required in the design standards table, the tree canopy cannot be
counted toward vegetation coverage in the downtown districts.
Removed vegetation coverage and streetscape landscaping to ensure
vegetation coverage and streetscape landscaping applies to all
properties not just the downtown and CG districts.
- Included language that clarified landscaping installation process during
winter months through a temporary certificate of occupancy.
- In the park strip standards table, specified where the center of a park
strip is.
- In the authority section, stated simply which departments or divisions
may provide input to the zoning administrator when the provisions of
the landscaping chapter may be waived. Removed qualifying
provisions required when departments or divisions may recommend a
landscaping waiver.
- Clarified in the landscape plan section, permitted modification if the
change is from one plant species to another with similar watering needs.
- Specified in the CSHBD district sufficient soil volumes for street trees
must be approved by Urban Forestry.
PUBLIC PROCESS:
Recognized Organizations: All recognized organization chairs city-wide were notified on
February 10th, 2023, of the proposed text amendments. The Planning Division presented the
proposed code amendments to the Sugar House Community Council on March 20th, 2023 and
accepted comments and answered questions.
Open House: A virtual open house was hosted on Planning’s website and published via list serve
on February 10th, 2023. The open house information included the most recent version of the
landscaping and buffers chapter draft. The open house page was continually updated to include the
most recent draft amendments and public hearing dates.
Public Hearing Notification: Notice of the public hearing was posted on City and State websites
and emailed via list serve to subscribers on April 19th, 2023.
Planning Commission Public Hearing: The Planning Commission held a public hearing on the
text amendments on April 26, 2023. The Planning Commission provided a positive
recommendation to City Council on the proposed amendments.
Planning Commission Staff Report
Public Comments Received: We received 14 public comments, as of the date this memo was
transmitted. The public comments ranged from concerns of enforceability of some of the
standards, landscaping rocks and their contribution to the urban heat island, landscaping
materials on the sidewalk and unkempt landscapes, vegetation and vegetation maximum height
9
in the park strip, costs associated with requiring permanent irrigation, water waste, allowing
native grass species, and public noticing procedures. Comments included statements encouraging
waterwise landscaping and improving water conservation in landscaping areas. There were also
statements where there was some misunderstanding on when a street tree is required. Where
possible staff clarified when a street tree is required to the public – in a park strip over 36” in
width and for new construction for single- and two- family developments.
PLANNING COMMISSION (PC) RECORDS:
a)PC Agenda of April 26, 2023 (Click to Access)
b)PC Staff Report of April 26, 2023 (Click to Access Report)
c)PC Minutes for April 26, 2023 (Click to Access)
d)PC Video for April 26, 2023 (Click to Access)
EXHIBITS:
1) Project Chronology
2) Notice of City Council Public Hearing
3)Petition Initiation
4) Public Comments Received after Planning Commission Staff Report Published
5)Public Utilities Director Statement
TABLE OF CONTENTS
1. Project Chronology
2.Notice of City Council Public Hearing
3.Petition Initiation
4.Public Comments Received After Planning Commission Staff Report Published
5.Public Utilities Director Statement
1)PROJECT CHRONOLOGY
Petition: PLNPCM2023-00098
September 6, 2022 City Council briefing to get initial feedback on potential changes
to landscaping regulations.
February 8, 2023 Text amendment to update the Landscaping and Buffers chapter
initiated.
February 10, 2023 Notice emailed to recognized organizations City-wide.
February 10, 2023 The proposed code changes were posted to the Planning Division’s
Online Open House webpage.
March 20, 2023 The Planning Division presented proposed code changes to Sugar
House Community Council. Public comments and questions were
accepted.
April 19, 2023 Public hearing notices were posted on City and State websites.
April 21, 2023 Staff Report posted online and sent to the Planning Commission.
April 26, 2023 Planning Commission forwards a positive recommendation to City
Council.
May 8, 2023 Draft ordinance forwarded to the Attorney’s Office for review.
June 7, 2023 Ordinance corrections forwarded to the Attorney’s Office.
June 12, 2023 Ordinance corrections forwarded to the Attorney’s Office.
Ordinance returned from the Attorney’s Office.
June 15, 2023 Ordinance corrections forwarded to the Attorney’s Office.
June 22, 2023 Reviewed ordinance returned from the Attorney’s Office.
June 29, 2023 Ordinance forwarded again to the Attorney’s Office, reviewed
final received from Attorney’s Office.
August 29, 2023 Corrected ordinance returned to Attorney’s Office for final review.
September 26, 2023 Final ordinance version received from Attorney’s Office.
September 27, 2023 Transmitted to CAN administration.
October 26, 2023 Council Office informed of needed modifications to the ordinance.
November 6, 2023 Ordinance with needed corrections forwarded to the Attorney’s
Office.
November 14, 2023 Corrected ordinance returned to Attorney’s Office for final review.
November 15, 2023 Transmitted to CAN administration.
2)NOTICE OF CITY COUNCIL HEARING
NOTICE OF PUBLIC HEARING
The Salt Lake City Council is considering Petition PLNPCM2023-00098 – A petition initiated by Mayor
Erin Mendenhall to amend the Salt Lake City Zoning Code for the Landscaping and Buffers Chapter Text
Amendment. This proposal includes amendments that will be affected City-wide. The proposed code
amendments seek to better address landscaping regulations and seek to reduce water consumption,
enhance the urban forest, and improve air quality and green infrastructure city-wide. The proposed
amendment also seek to clarify, simplify, and reorganize the landscaping and buffer chapter to be more
user friendly. The City Council may consider modifications to other related sections of the code as part of
this proposal.
DATE: Date #1 and Date #2
TIME: 7:00 p.m.
All persons interested and present will be given an opportunity to be heard in this matter.
his meeting will be held via electronic means, while potentially also providing for an in
person opportunity to attend or participate in the hearing at the City and County
Building,located at 451 South State Street, Room 326, Salt Lake City, Utah. If you are
interested in participating during the Public Hearing portion of the meeting, please visit the
website www.slc.gov/council/virtual-meetings/ or call 801-535-7654 to obtain connection
information.
Comments may also be provided by calling the 24-Hour comment line at (801)535-7654 or
sending an email to council.comments@slcgov.com. All comments received through any
source are shared with the Council and added to the public record.
If you have any questions relating to this proposal or would like to review the file, please call
Nannette Larsen at 801-535-7645 between the hours of 8:00 a.m. and 5:00 p.m., Monday
through Friday or via e-mail nannette.larsen@slcgov.com
People with disabilities may make requests for reasonable accommodation no later than 48 hours in
advance in order to participate in this hearing. Please make requests at least two business days in advance.
To make a request, please contact the City Council Office at council.comments@slcgov.com , 801-535-
7600, or relay service 711.
3) PETITION INITIATION
SALT LAKE CITY CORPORATION
451 SOUTH STATE STREET, ROOM 406 WWW.SLC.GOV
PO BOX 145480 SALT LAKE CITY, UT 84114-5480 TEL 801-535-7757 FAX 801-535-6174
PLANNING DIVISION
DEPARTMENT of COMMUNITY and NEIGHBORHOODS
MEMORANDUM
To: Mayor Erin Mendenhall
Cc: Lisa Shaffer, Chief Administrative Officer; Blake Thomas, Department of Community and
Neighborhoods Director; Michaela Oktay, Deputy Planning Director
From: Nick Norris, Planning Director
Date: January 27, 2023
Re: Initiate Petition to Amend Text in the Zoning Ordinance to Update the Landscaping Chapter
This memo is to request that a petition is initiated directing the Planning Division to update the
Landscaping Chapter to better address the needs of the City and the changing climate being
experienced along the Wasatch Front. Amendments to the Landscaping Chapter will also better
conform to Plan Salt Lake.
In Plan Salt Lake direction to reduce water consumption, protect and enhance the urban forest, and
improve green infrastructure in the City’s neighborhoods is emphasized. To achieve these goals
amending the landscaping chapter is necessary to reduce barriers to water conservation while
improving water and air quality.
In addition to providing best management practices to reduce barriers and incentive water
conservation, is promoting accessible conservation strategies and standards in the Zoning Ordinance.
The updates to the Landscaping chapter will accomplish this by quantifying best practices and
creating visual elements to the chapter to better achieve accessibility needs of the residents in the
City.
As part of the process, the Planning Division will follow the City adoption process for zoning text
amendments, which includes citizen input and public hearings with the Planning Commission and
City Council. The adoption process will include collaboration with other City Departments and the
Central Utah Water Conservancy District to ensure best management practices are utilized.
This memo includes a signature block to initiate the petition if that is the decided course of action. If
the decided course of action is to not initiate the application, the signature block can remain blank.
Please notify the Planning Division when the memo is signed or if the decision is made to not initiate
the petition.
Please contact me at ext. 6173 or nick.norris@slcgov.com if you have any questions. Thank you.
Concurrence to initiate the zoning text amendment petition as noted above.
_____________________________________ ______________
Erin Mendenhall, Mayor Date
4)PUBLIC COMMENT RECEIVED AFTER PLANNING
COMMISSIONS STAFF REPORT PUBLISHED
Caution: This is an external email. Please be cautious when clicking links or opening
attachments.
From:Amanda Dillon
To:Larsen, Nannette
Subject:(EXTERNAL) Comment on new Landscaping Ordinance - Planning Commission Meeting
Date:Tuesday, April 25, 2023 10:38:19 PM
Hey Nan!
I was chatting with Amanda Roman and she let me know that tomorrow is when the new
landscaping ordinance goes in front of the planning commission. Congrats on getting these
revised policies to this point! I had the chance to skim through it earlier today and wanted to
submit two official comments. SLC's website said to reach out to you as the staff listed at the
top of the report. Let me know if I should reach out somewhere else to get this comment
officially recorded.
The first comment is in regards to plant height in the park strip. The proposed ordinance
says: Plant height is limited to 22” to preserve clear views from intersection driveways,
alleys, and streets, to preserve line of sights for people, and to prevent areas that some
people may find unsafe when visibility is blocked.
One issue we've found with this limited plant height is that it makes it hard to put planter boxes or
similar into the park strip because we are so limited in height. As a developer of infill multifamily
housing, we find that many of our residents let their pets relieve themselves in the park strips on
any planted vegetation. The high acidity of their urine/feces makes it so that most plants die
immediately and don't really grow back, leaving barren and unattractive park strips. One solution
we've found that helps keep the park strips vegetated and looking nice is putting plants in planter
boxes, which makes it harder for pets to disturb them. However, to create one that is hard for pets
to get into, the planter box needs to be at least 12" tall. With the plant height restriction, that
means we can only put a plant in that will mature to 10" tall. This really narrows down the
selection of plants we can use to beautify the park strips and prevents us from designing attractive
landscaped right of way areas for the City. It would be great to have a slight modification in this
part of the code that would allow for taller plant heights if those are planted in garden boxes or the
like.
The second comment is more of a clarification question. On page 6 of the ordinance, in the second
paragraph, it says "rocks (over a certain size)" but no where else in the code does it give any
specifics about that size. Can more definition/clarity be added on this point?
Thanks so much! Let's get together soon.
Amanda
Amanda Dillon
Giv Development
From:Bruce A. Hamilton
To:Larsen, Nannette
Subject:(EXTERNAL) Case PLNPCM2023-00098: oppose vegetation requirements on park strips
Date:Monday, April 24, 2023 10:54:24 PM
Caution: This is an external email. Please be cautious when clicking links or opening attachments.
Re: Planning Commission, April 26 agenda, case PLNPCM2023-00098:
It is insane to require vegetation on park strips in this age of
droughts. Please oppose all such existing and new zoning requirements.
--Bruce (Bruce A. Hamilton, Salt Lake City, UT)
Caution: This is an external email. Please be cautious when clicking links or opening
attachments.
From:Margaret Holloway
To:Larsen, Nannette
Subject:(EXTERNAL) PLNPCM2023-00098
Date:Tuesday, April 25, 2023 10:40:34 AM
The goal of the city is to increase the canopy throughout the city.
But what I see is a stumbling block is the fact of a permanent irrigation line to a street tree. I
was quoted 3000 dollars just to connect a irrigation connection to my water line.
If this is required of ALL homeowners who would like a tree or are going to be required to
have a tree planted To whom is going to pay this bill?
That quote was just to dig down to the water line and connect a meter. That does not include
the line to the tree. I understand the need to encourage watering the tree. But if this is not done
correctly you can have the water go into reverse and contaminate the water supply. It has
happened when people try to do plumbing themselves. Now how is this even reasonable?
All you need is a hose . The city gave buckets to the homeowners that had their trees taken out
by Rocky Mountain power on 900 west. They were told to haul 5 gallons to the tree each week
or 10 days.
Which sounds reasonable... But how do you fill the bucket with a hose...... And if they had
given them a hose instead maybe they would have watered the trees. But they didn't and they
did not get watered
They all died except a couple that did..... The city plants trees into parks without water and
then they die. The new trees the city planted on 1200 west there were 10 all but 2 died
Because the sprinklers were turned off
and the new trees need help for the first few years. The city turns off the sprinklers or cuts
back and the trees die. But here you are requiring homeowners to spend upward of 3,000 to
put a line in maintain it
when you just need a hose..... I water my street tree with a soaker hose every other week if it
doesn't get enough water like last 2 years.... The canopy changes over the life of the
tree.....You MUST water under
the canopy..... It only benefits the tree if you water under the growing canopy... This is where
a soaker hose is important.. it goes straight to the roots....
But to make the decision that everyone has to pay upto 3,000 dollars to put a permanent line to
where it isn't going to do what you want it to do.... seems missguided.
The city just planted 30 more trees in Rosewood In Rosepark..... if they have to cut off the
water again will they make it? It depends this year they have a chance because of all the water
in the soil.
But last year they lost 5 from the previous year lack of water. The west side needs the trees
but forcing people to put in an expensive hook up when a 30 dollar hose will do ...
But last year you just drive around and see the trees they had planted in the parks that died.
So why is the city going to require something of homeowners that the city does not do itself?
Please reconsider this it won't do the trees any good to water where they can't use it.,..It will
not get the city where it wants to go with the canopy.
If there are actually any new houses built in the city i can see where this might come into play
before everything is installed. But since we don;t have any place to build new houses
you are telling existing homeowners what to do. after the fact of 60 or more years.
Margaret Holloway
1412 west 1100 north
SLC
Caution: This is an external email. Please be cautious when clicking links or
opening attachments.
From:
To:Larsen, Nannette; Planning Public Comments
Cc:Wharton, Chris; City Council Liaisons; slcgreen;
Subject:(EXTERNAL) Public Comment on Petition PLNPCM2023-00098 - 21A.48 Landscaping and Buffers Updates
Date:Tuesday, April 25, 2023 12:51:52 PM
Attachments:21A.48 Nextdoor posting 1.4 K Views 5 Days .pdf
Public Comment on Petition PLNPCM2023-00098 - 21A.48 Landscaping and Buffers Updates
From: Stanley Holmes
4-25-2023
Dear Salt Lake City Planning Commission,
I urge you to reject the proposed ordinance rewrite of 21A Zoning that was submitted as Petition
PLNPCM2023-00098 - "21A.48 Landscaping and Buffers Updates" as flawed and problematic on
several fronts. The set of proposed amendments to Title 21A Zoning should be remanded back to
Salt Lake City's Planning Division ("Division") for revision and a new, more appropriately noticed
45-day public comment period to be opened by the Division before a corrected set of proposed Title
21A Zoning amendments is brought before the Planning Commission ("Commission").
The proposed changes to Title 21A Zoning Chapter 48 under consideration now would have
significant, wide-ranging, and costly impacts for many Salt Lake City ("City") property owners of
various means and for all city taxpayers. That the Division would rely primarily on community
council chairs to, at their individual discretion and in a timely manner, notify the general public of
statutory/regulatory changes of this scope and magnitude can be most graciously characterized as
cavalier.
Division records indicate that only four comments were received during the 45-day comment
period and that Sugarhouse C.C. was the only community council to actively engage. I learned
from city staff that the Division’s notification system had been used, but found that there are no
water conservation, landscaping, energy conservation, environment, or other sustainability
categories listed. Through which category did the Division send the landscaping code updates
notice; and how many city residents actually get notices through that means?
Please be advised, and let the public record show, that on April 20, 2023, I posted on the
community blog --Nextdoor.com-- information about the proposed Title 21A Zoning changes and
ways that interested citizens could submit public comments. Over the next five days, Nextdoor.com
reported 1,400 views and there were 48 public comments. Please see evidence of this included
with the Addendum at the close of my comment and attached.
Those folks on Nextdoor.com were Salt Lake City residents who missed the initial comment period
that ended on March 27th and, quite likely, also did not know about your April 26 Planning
Commission meeting or their opportunities to submit public comments before the zoning/ordinance
changes had become a ‘done deal.’ Outrageous.
I am also quite surprised and disappointed that there was no input from the Sustainability
Department, and wonder how their input was solicited. SLCGreen is copied on this comment, as
are my District 3 Councilman Chris Wharton and the City Council Liaisons.
City officials should have known that not every community council would post or distribute the
notice. Not every potentially interested and impacted citizen is on a community council distribution
list or regularly checks a community council's website. One might wonder to what extent the
Division was truly desirous of robust public input, having solicited comments by such a narrow and
undependable means. The Commission should insist upon a proper re-do of the public comment
period and extend its further consideration of any Title 21A Zoning Chapter 48 amendments until
legitimate opportunities for public input have occurred.
The proposed Petition PLNPCM2023-00098 - "21A.48 Landscaping and Buffers Updates" are
themselves in several ways inadequate and problematic. Their 'as is' endorsement by the
Commission and the City Council would, upon attempted implementation and enforcement by the
City, certainly result in strong opposition that would include costly litigation.
Please recall that the most recent revision of 21A.48 was in the year 2000, prior to over two
decades of climate change-exacerbated heat increases and drought that finally prompted state and
local officials to take action. The updates now under consideration were supposed to deal more
effectively with the climate change-related impacts.
Let me begin with the proposed re-write of 21A.48.010, the Purpose and Intent section. While the
earlier version calls for promoting "the prudent use of water", the update would remove this and
make no mention of water conservation as a priority. The lead "purpose" of a revised chapter
21A.48 would be to "increase Salt Lake City's urban tree canopy"; and the lead "intent" would be to
"promote and enhance the community's appearance."
While trees are nice, useful, and can be aesthetically pleasing, the City is located in the second
driest U.S. state and is experiencing an unprecedented, worsening drought. Water conservation
should not only have been mentioned in the proposed re-write of 21A.48.010, but been listed as a
priority goal, as has been done by other Utah municipalities. Why was this not done?
Under the current zoning ordinance, Section 21A.48.060 refers to Park Strip Landscaping and one
of the "intent" items is to "encourage water conservation". But the proposed re-write (update) would
change the title of 21A.48.060 to "Landscape Requirements" and remove the water conservation
reference.
The re-write of 21A.48.060 has a new "Park Strip Standards" section that adds the requirement of
at least one "street tree" in the park strip. Additional park strip trees would be required, depending
on the park strip length. The current ordinance has no park strip tree requirement. Therefore,
residents who've implemented water-wise park strip measures --in compliance with the existing
ordinance -- that do not include at least one street tree would be required to add a tree and,
according to the 21A.48.040 re-write, see that it is "irrigated with a permanent automatic irrigation
system." A hydrozoned irrigation system would be required, so that tree(s) watering can be
isolated from any water needed for other vegetation.
The park strip abutting property owner would have to pay for the new park strip tree-plus-irrigation
requirement. That could be quite costly, especially if the park strip has to be excavated to install
the required irrigation system. The Commission should assume that some residents will be unable
to afford this and that others who had been compliant would rather fight the compliance rules
change in court. Please consider the burden on low-income families, especially if the $25-per-day
violation fine is retained.
The Commission should also consider that the City's Department of Community and
Neighborhood's Civil Enforcement staff would have to be expanded and that additional budgetary
provisions would have to be made for the City's legal team. Litigation could delay implementation
and enforcement of parts or all of the proposed 21A.48 Landscaping and Buffers Updates for an
extended period of time.
And aside from pushback from angry residents delaying implementation of the proposed
ordinance updates, the sheer magnitude of any effort to achieve widespread compliance should
sober city planners and policy-makers. Have Division staff conducted a city-wide, on-street survey
of the number of park strips that would require tree-planting and new irrigation plumbing? Have
they calculated how many contractors, and how many years, would be required to accomplish full
implementation? Then, there's the additional per-tree water requirement times however many park
strips would be affected.
At this point, I'll add that there are some positive aspects of the proposed ordinance re-write, such
as 21A.48.040.E.1., which says that "All irrigation systems shall be maintained in good operating
condition to eliminate water waste and run-off into the public right-of-way." Drip irrigation is also
mentioned in 21A.48.040.E, though it could have been promoted.
Some of the proposed re-write items are not clear. For example, 21A.48.040.C.2. "Exceptions"
circles back to itself. And under 21A.62 "Definitions", the Park Strip Landscaping section says that
park strip landscaping may include "lawn", which is normally a reference to turf. The re-write, under
21A.48.060 and 21A.48.080, prohibits turf in park strips. There is also a reference to the right-of-
way line's relevance if there is no sidewalk, but the dimensions of the right-of-way line are not
given.
As a final point to this comment, it concerns me that the City Planning Division failed to take a
holistic view of the abutting residential property owner's landscape unless a new home is being
constructed or the floor area of an existing structure(s) is being expanded by 50% or more. The
overall vegetative contribution of individual residential properties that are not undergoing structural
change is ignored by the proposed 21A Zoning rewrite's determination of compliance or non-
compliance with new park strip requirements. I can imagine situations where the owner of a well-
wooded, well-vegetated residential property is forced to install and water a park strip tree while the
owner of a minimally vegetated property who happens to have a tree in the park strip is left alone.
Where is the environmental justice in that?
Salt Lake City needs to do a better job of conserving water. The proposed amendments to Title
21A Zoning are inadequate to the task, as they do not give water conservation the top priority
status our current megadrought crisis demands. I urge the Commission to deny Petition
PLNPCM2023-00098 - "21A.48 Landscaping and Buffers Updates" and send it back to the Division
for revision and a properly noticed, 45-day public review and comment period.
I thank you in advance for your thoughtful consideration of the points I raised and your directive to
have the ordinance revised in a more transparent way that better engages the public and serves
the City's best interests.
Stanley Holmes
846 N. East Capitol Blvd.
Salt Lake City, UT 84103
Addendum:
My attempt to use Nextdoor.com to notify the public of proposed 21A.48 changes, first posted on
April 20, 2023, is copied below. In five days, 1,400 views and 48 resident comments. The
Planning Division got 4 public comments in 45 days.
Stan Holmes
Author
•West Capitol Hills•0 mi
SLC Park Strip, Landscape Policy Changes
Public comments are being taken by the Salt Lake City Planning Division and Planning
Commission as they consider city-wide changes to the Landscaping Chapter of the Zoning Code.
This includes proposed revision of the Park Strip ordinance under which many city residents have
been penalized for their water conservation efforts. The proposed Park Strip policy revision would
require one "street tree" every 30 feet and vegetation covering at least 30% of the area. See all
proposed amendments at...
www.slcdocs.com/Planning/Online%20Open%20Houses/2023/02 2023/PLNPCM2023-
00098/02102023%20DRAFT%20Landscaping%20Updates_Posted.pdf The Planning Commission
will consider landscape/park strip ordinance changes at its April 26 meeting. Public comments can
be submitted in-person or via email to and . Reference case number PLNPCM2023-00098 in the
subject line. The agenda for next Wednesday's (April 26) Planning Commission meeting is at...
www.slcdocs.com/Planning/Planning%20Commission/2023/PC04.26.2023/PC04.26.2023agenda.pdf
Whatever the Planning Commission decides will then be presented to the City Council for final
approval. Now is the time to shift from opinion to action and file a public comment.
Stan Holmes
Author
•West Capitol Hills•0 mi
The email addresses that were stripped are planning.comments and nannette.larsen that are both
at slc.gov. They are also listed in the April 26 agenda at...
www.slcdocs.com/Planning/Planning%20Commission/2023/PC04.26.2023/PC04.26.2023agenda.pdf
also attached:
Caution: This is an external email. Please be cautious when clicking links or opening
attachments.
From:Chelsea Benjamin
To:Larsen, Nannette
Subject:(EXTERNAL) Report to include as part of public record for today"s planning commission meeting
Date:Wednesday, April 26, 2023 11:00:08 AM
Attachments:2022 WRA Artifical Turf Report.pdf
Hello Nannette,
I would like the following report to be included as part of the public record during the Planning
Committee discussion on the new landscaping ordinance today. Here is a link to the report, and I
have attached it as a PDF to this email. https://westernresourceadvocates.org/publications/is-
artificial-turf-a-beneficial-water-conservation-tool-in-the-west/
Please let me know if there is anything else I need to do to include it in the Planning Commission’s
discussion today.
Thank you,
Chelsea Benjamin
photo
Chelsea Benjamin
Water Policy Fellow
| WesternResourceAdvocates.org
2260 Baseline Road, Suite 200 | Boulder, CO 80302
Is Artificial Turf a Beneficial Water
Conservation Tool in the West?
December 2022
Author: Chelsea Benjamin
Contents
Introduction .................................................................................................................................................. 3
Water Management ...................................................................................................................................... 3
Temperature Impacts ................................................................................................................................... 4
Lifecycle Analysis ........................................................................................................................................... 4
Harmful Chemicals ........................................................................................................................................ 5
PFAS Contamination ..................................................................................................................................... 6
Microplastic Contamination.......................................................................................................................... 7
Soil Quality .................................................................................................................................................... 7
Pet Waste Buildup ......................................................................................................................................... 8
Cost ............................................................................................................................................................... 8
Conclusion ..................................................................................................................................................... 9
Introduction
Artificial turf is a landscaping alternative made of plastic that mimics the look, feel, and function of a
natural grass lawn or athletic field. Artificial turf has become more popular in Colorado and the West in
recent years for its ability to reduce landscape water use in the face of unprecedented drought and
water security challenges; the region now accounts for 24% of the artificial turf market share in the
United States, with most being used for athletic fields. In recent years, many communities across the
West have mounted turf replacement programs to encourage residents to save water used on outdoor
landscapes in the face of prolonged drought. Communities are also limiting the amount of high water
use, non-functional turf that can be installed in new development and instead requiring landscaping
alternatives. As momentum continues to grow around reducing high water use turfgrass in our
communities, water conservation practitioners, land use planners, landscape professionals and
community members are asking: is artificial turf a worthwhile landscaping alternative, especially for
residential properties? While artificial turf may reduce landscape water demand compared to traditional
cool season turf, research shows that artificial turf can also have significant environmental and
economic drawbacks. This report explores the current state of the research behind the benefits and
drawbacks of artificial turf as it relates to: water management, temperature impacts, lifecycle analysis,
PFAS contamination, harmful chemicals, microplastic contamination, pet waste buildup, and cost. While
much of the data available are from studies of artificial turf athletic fields, most findings are applicable
to properties with smaller footprints as well.
Water Management
Artificial turf has gained popularity in large part for its ability to reduce outdoor water use. One study
found that full-sized, 1.32 acre, natural grass sports fields can use up to 1.5 million gallons of water for
irrigation per year depending on geographic location. The Synthetic Turf Council estimates that same-
sized artificial turf athletic fields can save 500,000 to 1 million gallons of water per year (8.7 to 17.4
gallons/sq-ft), and that a turf lawn of 1,800 square feet can save 99,000 gallons of water per year, or
about 70% of a homeowner’s water bill. In the arid Western United States, the need for water
conservation has been a driver of artificial turf demand. Artificial turf for residences has proven
especially popular in drought-stricken California, where some areas were limited to one day of outdoor
watering per week in the summer of 2022 due to water shortages.
While artificial turf companies tout water savings as a main benefit of artificial turf, this is not always the
case. Studies have found that on a warm, sunny day artificial turf can measure up to 80 degrees hotter
than the ambient air temperature. In one study, an artificial turf field measured 160 degrees while the
ambient air temperature was 87 degrees. On an athletic playing field, one solution to this heat is to
water the artificial turf. A large amount of water needs to be applied to achieve a cooling effect, and it
has been found that this cooling effect lasts only minutes before temperatures rebound. Some sports
arenas have attempted to solve the problem by installing misters that apply water to the turf field
throughout sports events. Others find that irrigation of artificial turf improves traction and athletic
performance; one university in North Carolina going so far as to apply for a business exemption to water
their artificial turf athletic fields during a drought.
An additional concern is the effect of artificial turf on groundwater recharge. Cities in California that
once encouraged the replacement of natural grass with artificial turf have since changed their policies
upon discovering that artificial turf can increase stormwater runoff and prevent groundwater recharge.
Los Angeles offered a rebate for homeowners who replaced irrigated grass with artificial turf until 2016,
when they revised their program’s requirements to provide a rebate only for replacement with
xeriscape landscaping. Los Angeles realized that artificial turf reduces the amount of rainwater that
soaks into the ground after a storm, and that more stormwater flushed out to sea via the stormwater
system.
Temperature Impacts
Artificial turf can reach temperatures up to 80 degrees higher than the ambient air temperature due to
its material composition and color, as well as the color and heat retention abilities of infill materials
used. This excess heat contributes to urban heat island effect in cities, as heat from the synthetic turf
elevates the ambient air temperature and disperses into the local environment. One researcher found
that some of the hottest areas in New York City are artificial turf fields, rivaling black colored roofs in
their heat retention abilities. Research has shown that excessively hot artificial athletic fields can lead to
heat stress, especially in children who are more susceptible than adults, turf burns, and the cancellation
of athletic events due to unsafe playing conditions. Artificial turf heat can also be an issue when used in
landscaping, as pets and children use the turf for play on warm days. Urban heat island effect can also
increase the demand for energy for air conditioning, and can increase pollution as natural grass areas
are removed. Natural grass absorbs the sun’s heat during the day, and slowly releases it at night,
contributing a cooling effect to the surrounding environment, as well as removing pollutants from the
air.
The artificial turf industry has responded to temperature issues and has developed products that can
repel UV rays, better disperse heat, and even mimic the evaporative cooling effects of natural grass.
Some types of artificial grass have been developed specifically for areas like Arizona that have extreme
high temperatures during the summer. Manufacturers claim that heat-repellent synthetic turf measures
10-20% cooler than grasses with high heat retention. Another heat reduction measure is the infill
material chosen; crumb rubber and sand infill materials can contribute to extreme artificial turf
temperatures due to their color and heat-retention abilities. Special infill materials have been developed
that when wet with water, will slowly release the water over time, mimicking the evaporative cooling
properties of natural grass and reducing the hottest temperatures by 50 degrees. Cooling technologies
seem to be distributed across price points, but largely cannot match the cooling properties of natural
grass or other plants.
Lifecycle Analysis
In the early 1990s, the United States had a mounting problem with the disposal of used automobile
tires; they were costly to dispose of and created pest and fire hazards in landfills. It was then discovered
that discarded tire rubber could easily be recycled into small pellets to be used as “infill” to stabilize
artificial turf athletic fields and lawns. The infill is now mainly used for large athletic field installations
and industry experts estimate that the artificial turf industry now recycles one-twelfth of all automobile
tires disposed of each year. One artificial turf athletic field can use 20,000 to 40,000 used tires as crumb
rubber infill. Infill is added during installation, and as needed to replace infill that migrates out of the
artificial turf area.
Artificial turf has an average lifespan of 8-10 years before an athletic field becomes worn out, or a
residential lawn loses its formerly lush appearance. The Synthetic Turf Council, an artificial turf industry
group, insists that artificial turf is recyclable, and that its members actively recycle the spent turf it sells.
Investigative journalists and concerned citizens have documented otherwise in the Netherlands and in
the United States.
The Netherlands requires artificial turf to be recycled. A few Dutch companies claim to be artificial turf
recyclers; these companies accept payment to recycle spent turf and provide removal services.
However, investigative journalists have found that several of these companies have no active facilities
for turf recycling. The companies do not recycle the artificial turf they accept, but either hold on to it
indefinitely in growing piles in municipalities with lax regulations or sell it to new customers who
repurpose the turf, rather than recycle its components into new materials.
In the United States, there are no regulations that pertain to the disposal or recycling of artificial turf.
Most municipalities will accept artificial turf in local landfills. Fees to dispose of large amounts of turf,
such as from athletic fields, can be extremely expensive. As artificial turf owners are not held
responsible for the turf at the end of its life, it is often illegally dumped, or a small fee is paid to store the
turf on an abandoned lot rather than paying disposal or recycling fees. Piles of discarded turf create fire
and chemical hazards, just as discarded automobile tires did in the 1990s. Although a Danish artificial
athletic field recycler, Re-Match, has plans to open an artificial turf recycling facility in Pennsylvania, and
has recently expanded its European operations to the Netherlands and France, life cycle concerns for
end-of-life artificial turf athletic fields and synthetic residential landscaping remain an active problem
the world over.
Harmful Chemicals
Artificial turf eliminates the need for pesticides, herbicides, and fertilizers that are traditionally used to
maintain a lawn or sports field; the plastic turf and its base layers block the growth of weeds and pests
that otherwise might invade natural grass. However, artificial turf contains many chemicals of concern.
These chemicals can migrate into the surrounding environment as the plastic material degrades when
exposed to heat and light. The majority of research on artificial turf focuses on athletic fields, and many
specifically on the chemicals related to crumb rubber infill. Crumb rubber infill is the cheapest infill
material on the market and is often used in athletic field installations. It is less likely to be used for
artificial lawns, but the following research discussed can at times apply to residential installations.
The cheapest infill material on the market is crumb rubber infill made from recycled discarded tires.
Crumb rubber infill is most often used for athletic fields, as it provides a durable playing surface.
However, crumb rubber infill has been found to release chemicals as it degrades. Crumb rubber infill has
been analyzed and found to contain 197 carcinogenic chemicals. Alternative infill materials include
EPDM rubber, TPE plastic, and recycled athletic shoe material, as well as natural materials like sand,
cork, and zeolite clay. A study comparing infill materials found that almost all contain chemicals of
concern, except natural infill materials, which may conversely be susceptible to mold growth, or cause
negative respiratory effects. Studies have found that organic contaminants and heavy metals in crumb
rubber leach into stormwater runoff, posing hazards to the surrounding environment, aquatic life, and
human health. Studies have also found that Volatile Organic Compounds (VOCs) from crumb rubber infill
can aerosolize during play on artificial turf athletic fields. VOCs can cause respiratory irritation and have
been linked to the development of cancer.
While there are no fully conclusive studies on the human health effects of exposure to artificial turf,
studies have been conducted on the effects of crumb rubber infill chemicals on earthworms, an
invertebrate, and on chicken embryos, a vertebrate. Two experiments have been conducted on the
effects of earthworm exposure to crumb rubber infill. The first experiment tested the effect of exposure
to new crumb rubber infill, and found that after one week of incubation in contaminated soil, the
exposed earthworms had noticeably lower body weight than those in clean soil. A second, similar,
experiment was conducted using recycled tire crumb rubber infill. In this experiment, the exposed
earthworms quickly died in a stress test, demonstrating a marked decrease in resilience to stress when
exposed to chemicals in recycled tire rubber.
Another study that examined the effects of crumb rubber leachate on fertilized chicken embryos during
their development process found that approximately half of the fertilized eggs exposed to the leachate
developed extreme malformations, while the unexposed group developed into healthy chicken
embryos.
Although no conclusive studies have been conducted on the direct effects of artificial turf on human
health, anecdotal collections of statistics have raised concerns about artificial turf’s potential connection
to cancer development in humans. In 2013, one women’s soccer coach compiled a list of 38 US soccer
players who had developed cancer, mainly leukemia and cancers of the blood. Many of the players were
goalies, who regularly dive into artificial turf. Health experts have been unable to reach consensus on
whether artificial turf and the use of crumb rubber infill can be linked to cancer or other human health
effects. Despite this lack of consensus, the presence of known carcinogens in artificial turf blades and
infill and the results of the animal studies have raised alarm.
PFAS Contamination
PFAS chemicals are widely found in artificial turf because they are used in the artificial turf production
process and are typically added as a coating to the grass blades as they are manufactured. The chemicals
can break down and leach into the environment when exposed to heat and light after artificial turf is
installed.
PFAS chemicals are also known as “forever chemicals” because they do not break down under normal
environmental conditions, and can last in the environment for hundreds of years, or longer. PFAS
chemicals are also associated with negative health effects in humans and wildlife. Studies on the human
health effects of PFAS chemicals have found that the chemicals bioaccumulate in human tissues and can
lead to liver effects, immunological effects, developmental effects, endocrine effects, decreased fertility,
cardiovascular effects, and can contribute to the development of cancers. PFAS can cause similar
problems in animals and can also bioaccumulate in plants.
In 2020, one New Hampshire community attempted to purchase PFAS-free artificial turf to minimize
exposure risks. The community tested the turf they had been sold, and found that it did contain PFAS
chemicals. The company claimed that the levels of PFAS in the turf were below EPA accepted maximum
levels of the chemical and could safely be labeled “PFAS-free”. However, the EPA has recently concluded
that no amount of PFAS chemicals are safe in drinking water, which is concerning as many components
of artificial turf installations regularly make their way into surrounding waterways.
Microplastic Contamination
In addition to the chemical concerns surrounding artificial turf, there are also significant concerns
relating to microplastic pollution. Artificial turf plastic grass blades can break off from the turf surface
and migrate into the surrounding environment, creating microplastic pollution as they break down into
smaller pieces over time. Artificial turf athletic fields that use crumb rubber infill can be even greater
sources of microplastic pollution. One study in Norway found crumb rubber infill pieces in 85% of water
samples taken in waterbodies downstream from artificial turf fields, and in 42% of samples taken from
locations upstream. Microplastic pollution from artificial turf fields accounts for over one third of total
microplastic pollution in Norway. Similarly, researchers have found that artificial turf fields are the
second highest source of microplastic pollution in Sweden. Swedish authorities estimate that large
artificial athletic fields lose 2-3 tons of infill to the surrounding environment per year.
Microplastic pollution is a concern for actively used artificial turf fields, and for discarded fields that
await recycling or incineration or are illegally dumped. Discarded fields have the potential to release
microplastic pollution into the surrounding environment indefinitely. Artificial turf lawns also can
release microplastics via the grass blades’ degradation over time, and depending on the choice of infill
will also release infill particles into the environment. Researchers are only beginning to understand what
the effects of this pollution might be.
Study of the effects of microplastics is relatively new. Studies have found the tiny particles worldwide,
including in remote wilderness areas that have no human visitors, and in the umbilical cords of newborn
babies. The effects of microplastic pollution on human health and the environment are still relatively
unknown, but some early studies suggest that microplastic exposure and ingestion can cause harm to
human health and the environment. One study in particular found that microplastics added to soil
disturb natural biological processes and change soil structure. Knowledge of the long-term effects of
microplastics will continue to develop over time.
Soil Quality
Artificial turf installation requires the removal of the existing top level of soil and heavy soil compaction
to create a smooth surface for the turf. Compaction negatively effects the soil structure, disturbs the
soil’s microbial activity, and can damage tree roots. After soil is compacted for athletic field installation,
several layers are added between the soil and the artificial turf surface to level the playing field, improve
storm water drainage, and provide cushioning. In artificial turf lawn installations, plastic and wire layers
may be added beneath the turf for protection from burrowing animals, and weeds. In addition to the
effects of soil compaction, artificial turf changes the quality of the soil beneath it by starving the soil of
water, air, and light. Artificial turf has also been shown to degrade over time, leaching chemicals from
the plastic turf material and the infill materials into stormwater runoff that can soak into surrounding
soils, further disturbing soil health.
Pet Waste Buildup
Pet waste can build up over time on artificial turf, and additional maintenance is required to keep
artificial lawns fresh. Artificial turf companies have designed special types of turf to improve pet waste
drainage and claim that it can better eliminate waste than natural grass. Pet-friendly infill has also been
created with a special coating to prevent odors and the growth of bacteria. Despite these measures,
artificial turf needs to be rinsed off after use by pets. To fully sanitize artificial turf when pet waste builds
up, infill must be vacuumed out and a special cleaner applied to break down urine and other waste.
Natural grass and other plant installations do not need this type of maintenance and special products;
the elements naturally break down remnant pet waste.
Cost
A New York Times investigation compared costs for artificial turf lawns. Bids to install a large artificial
turf grass lawn averaged $10,000. The average lifetime of artificial grass is 10 years or less and there are
maintenance costs associated with artificial turf, and costs associated with removal and replacement at
end of life. Natural grass lawns are likely to have longer lifespans if managed sustainably. Natural lawn
costs increase substantially if located in an area that requires supplemental irrigation. One way to lower
such costs is to install drought-resistant or low-water species of grass in drought-prone regions, though
irrigation systems will likely be needed even if used less frequently.
Regarding athletic fields specifically, many schools and universities choose to install artificial turf rather
than natural grass fields because artificial turf is a durable play surface that allows for continuous use,
while natural grass can require rest between athletic activities. Artificial turf can also save on
maintenance costs associated with irrigation and mowing. However, artificial turf has been shown to
require heat related closures, maintenance such as brushing and sanitization, regular replacement of
infill material, and even irrigation to improve heat conditions and playability.
The Toxics Use Reduction Institute (TURI) has conducted several studies comparing costs between
artificial fields and natural grass fields that show that organically managed natural grass fields can
improve play conditions, reduce wear and tear related closures, and lower maintenance costs. Costs to
install a variety of natural grass field installations range from $0.60-$5.00 per square foot, and estimates
for artificial turf costs range from $4.50-$10.25 per square foot. TURI’s research concludes that artificial
turf athletic fields can cost 2 to 10 times more than organically managed natural grass fields over their
life cycles when accounting for installation fees, maintenance fees, and disposal and replacement fees at
the end of an artificial turf’s lifecycle. Many sports facilities decide that the investment is worth it
because artificial turf can extend playing time, and be used in any season or weather condition,
including in snow.
Conclusion
Artificial turf has gained popularity, particularly in the increasingly arid West, as it conserves water used
on outdoor landscapes and sports fields, among other reasons, like extending playing time for athletic
activities. While artificial turf eliminates the need for pesticides, herbicides, and fertilizers used on
natural grass, it can have considerable drawbacks. Artificial turf can have unexpected negative impacts
to water supplies including requiring watering for cooling on hot days and hindering groundwater
recharge. The heat generated by artificial turf can increase urban heat island effect and cause heat-
related injuries. To date, there are few sustainable options for artificial turf recycling, leading to stacks of
discarded artificial turf building up the world over. In addition to the above issues, the chemicals and
microplastic particles that make up artificial turf can leach into the environment, causing environmental
and health impacts not yet entirely known. And, while many artificial turf companies tout the material
as more cost-effective, cost comparisons with natural grass show that in some cases artificial turf is
significantly more expensive. Better alternatives to artificial turf exist in the form of water wise
landscaping, including drought-resistant and native species of grasses, trees, shrubs, and perennials.
Water-wise landscaping can reduce irrigation water use significantly, with some native plants and
grasses requiring no or very little supplemental irrigation. While water savings vary depending on what
is installed, compared to cool season turf, water-wise plantings provide numerous other benefits such as
pollinator habitat, reduced fertilizer and pesticide use, and groundwater recharge. As the West faces a
hotter and drier future, we must continue to research and assess opportunities for reducing landscape
water demand while maximizing benefits and minimizing negative consequences. For residential
property owners seeking to be more water efficient or wanting lower maintenance landscaping, artificial
turf is likely not the hoped-for solution due to costs and wide-ranging environmental and potential
health impacts.
From:Christopher C. Nixon
To:Planning Public Comments; nannette@slcgov.com
Cc:jan Nixon
Subject:(EXTERNAL) Comment on Landscaping, Park Strip Changes to Code 21A.48
Date:Wednesday, April 26, 2023 12:25:04 PM
Caution: This is an external email. Please be cautious when clicking links or opening attachments.
To Whom It May Concern,
I just learned of this public comment opportunity through our neighborhood social media, not from city officials.
Apparently, the first comment opportunity has come and gone with little publicity.
Salt Lake City must try harder to not only save water, but also to provide the public with more chances to have a
say in what we can do as individuals and neighbors. The water crisis is serious. City officials need to get serious,
too.
What Salt Lake City needs to do first is to stop all the water waste on park strips and adjoining properties. Every
day in the summer, I see broken and badly adjusted sprinklers watering the street and sidewalks. I’ve received two
citations from SLC Civil Enforcement wanting to penalize me for getting rid of park strip turf and putting in a
water-wise, attractive rock garden.
What is Civil Enforcement doing about the gutter rivers from the wastrels that are mismanaging their landscape and
park strip water? Do city planners need water-wise residents to submit photos and addresses of these residential,
commercial, and industrial wastrels across the city?
I know neighbors who would like to have a say in this but also missed the opportunity. The city planning division
should re-open the public comment period and have it properly noticed in the Deseret News and Salt Lake Tribune.
KSL and KUER would air PSAs to let people know.
Please get serious about the drought situation and bring the residents onboard to find solutions.
Thank you.
Jan Nixon
Salt Lake City
Caution: This is an external email. Please be cautious when clicking links or opening
attachments.
From:Margaret Holloway
To:Larsen, Nannette
Subject:(EXTERNAL) design presented on landscaping last night
Date:Thursday, April 27, 2023 11:25:34 AM
I see a design with a tree in the corner with mulch and drought bushes spotted around. The
problem with mulch is that leaves that fall from the tree can not be raked or blown without
removing the mulch with the leaves.
So that is a problem I was going to put bark and mulch like this buyt my trees drop small
leaves and large leaves during the year. WHich i saw before i did this new landscaping. So it
sounds and looks good
until the trees drop leaves.
Margaret Holloway
1412 west 1100 north
Salt Lake City, Utah
Caution: This is an external email. Please be cautious when clicking links or opening
attachments.
From:Kyle Deans
To:Larsen, Nannette
Subject:(EXTERNAL) PC
Date:Tuesday, May 16, 2023 12:41:42 PM
Nannette,
I am sending this in regards to the Landscaping and Buffers Amendments.
I am in full support of anything that can help reduce the consumption of water by SLC
residents, especially when it comes to non essential ornamental landscapes.
Kyle Deans
SLC Resident
Caution: This is an external email. Please be cautious when clicking links or opening
attachments.
From:
To:Larsen Nannette
Cc:Planning Public Comments; City Council Liaisons; Gliot Tony;
Subject:(EXTERNAL) Second Public Comment on 21A.48 Landscaping and Buffers Updates
Date:Thursday, July 20, 2023 4:57:24 PM
Attachments:West Side Street UHI Despite Park Strip Trees jpg
Freshly Black Topped West Side Street UHI.jpg
Public Comment Follow-Up to 21A.48 Landscaping and Buffers Updates
From: Stanley Holmes
7-20-2023
Dear Salt Lake City Planning Division,
As a follow-up to my 4-25-202 public comment [copied further below] urging the S.L.City Planning Commission to
reject the proposed 21A.48 Landscaping and Buffers Updates, I submit the following inquiry along with
suggestions for improvement of your Urban Forest Action Plan adopted Feb. 2023.
First, the inquiry.
Some residents have asked me whether the new park strips street tree requirement applies to park strips abutting
existing homes as well as to new homes and remodeled homes. My responses have included references to the
Salt Lake City Planning Division's ordinance revision proposal report that was submitted to the SLC Planning
Commission on April 26, 2023, the day the Commission considered proposed Landscape and Buffers Chapter
[21A.48] Amendments. That report included the Planning Commission Draft as Attachment B.
My counsel to residents for whom the ordinance revision is unclear is that, as worded, the new park strips street
tree requirement applies everyone, with few exceptions. I point to the following document components which,
taken together, substantiate this:
The 4-26-2023 document states that it is intended to "Specify responsibilities of the property owner."
Applicability [21A.48.020] chapter provisions state that the ordinance "[A]pplies to all properties within the city,
unless otherwise exempted in another chapter."
Responsibility & Maintenance [21A.48.040] chapter provisions state that, with reference to park strips, "The
owner of the property abutting the park strip shall be responsible for the correct installation, maintenance, repair, or
replacement of all landscaping vegetation..." and include "Providing sufficient irrigation to a street tree located in
the abutting park strip." That section proceeds to list multiple requirements for irrigation systems.
The Landscape Plan chapter, 21A.48.050, indicates that a landscape plan is only required for "[New] construction
of a primary structure" and alterations to an [existing] property that increase the floor area by 50% or more.
The next chapter, Landscape Requirements [21A.48.060], however, makes no distinction between properties
requiring a landscape plan and those that do not, when it states that "Where there are conflicting standards in this
chapter, the more restrictive requirements shall apply." Park Strip Standards include "Minimum of 1 street tree..."
and, for overall vegetation, "Minimum 33% coverage."
The General Standards chapter, 21A.48.080, states that "All landscape improvements in the required landscape
locations, as described in 21A.48.060 and 21A.48.70 shall meet the regulations described in this section." Under
the chapter's Specific Park Strip Standards section, the Street Trees:Substitutions rule is that the Urban Forester
"may approve a substitute of the required street tree provision for a cash in lieu payment..."
In the Key Considerations section, under Consideration 2, the SLC Planning Division's 4-26-2023 document
references its Urban Forest Action Plan, then concludes that the proposed landscaping chapter will include the
requirement that "[S]treet trees are required in every park strip depending on the length of the park strip."
[Attachment A, Water Conservation and Landscaping Regulations Council Briefing Report, includes specific
observations and recommendations in its Water Conservation and Landscaping Regulations. It acknowledges that
"property owners are not aware" of landscape zoning rules and criticizes the current landscape chapter's "lack of
clarity" and consequent problems that include resident violations and subsequent [civil] enforcement actions. My
takeaway is that the Division has identified a problem, but not corrected it.]
Looking again at the Planning Commission Draft:
The first textual content specifying applicability to new construction does not occur until chapter 21A.48.050,
Landscape Plan, where it states that such a plan shall be required for new construction and modification of an
existing property's floor plan by 50% or more. Up to that point, the revision suggests that requirements apply to all
residences...with a few exceptions.
Prior to 21A.48.050 we have:
~ 21A.48.020: Applicability... "The provisions of this chapter apply to all properties within the city, unless otherwise
exempted..."
~ 21A.48.040: Responsibility and Maintenance ... "The owner of the property abutting the park strip shall be
responsible for...all landscaping vegetation." "Providing sufficient irrigation to a street tree located in the abutting
park strip." "shall provide water adequately and efficiently to each street tree..."
Then, in 21A.48.060 under Park Strip Standards, the document sets a minimum of one street tree per park strip
and a minimum 33% vegetation. No distinction is made between existing properties and those requiring a
landscape plan. If the Commission intended to exempt existing properties, it should have stated that.
I therefore conclude that the SLC Planning Division document fails to convince me that the revised ordinance
requirements would only apply to new projects or non-residential landscape sites. While there are separate
chapters in the Division and Commission portions of document that apply to new projects and changes to existing
residential property floor plans, and there are later chapters citing variations for certain areas, such as the
Northwest Quadrant, there are no residential park strip requirement waivers or exemptions specified in prior
chapters. Nor is it stated in introductory sections, such as Project Description or later in Purpose & Intent, that the
ordinance update does not apply to most existing residential properties. General applicability of the park strip
street tree requirement should have been clearly stated up front, but was not.
Since the proposed ordinance update is not clear about all who would be subjected to the new park strip street
tree requirement, my counsel is that SLC residents whose park strips have no trees should assume they will be
required to make changes if the Commission-approved ordinance update is adopted by the Salt Lake City Council.
What would you say to SLC residents who feel threatened by the proposed ordinance update?
Finally: Some comments on the Urban Forest Action Plan (UFAP)…
Inasmuch as the City is concerned about the urban heat island (UHI) effects of <33% vegetation covered park
strips, and is focusing on irrigated park strip street trees as a solution, I am surprised that the UFAP lacks details
about the UHI of super-wide residential streets, especially on the West Side. For example, 1100 West and 400
North are 77 feet wide. That's the width of seven or eight car lanes…all imposing intense UHI effects and trying-to-
stay-cool cost burdens on economically vulnerable families.
The only [passing] reference to the option of street trees median strips is a sketch on page 76. There's no
discussion of the functionality of street trees median strips, which could be quite useful in reducing UHI on wide
residential streets. I have attached to this comment the photo of a West Side street block whose park strips are full
of trees. Notice the huge area of exposed street pavement still drawing and radiating heat. Another attached
photo shows a recently black-topped street. Why is the City still coating streets with black when lighter alternatives
are available?
There are other cost-burden, mitigation responsibility, and water conservation topics that should inform
improvements to the Urban Forest Action Plan and the revision of city ordinance 21A.48 prior to the City Council's
scheduling of public hearings and its final vote.
Thank you for your attention to questions and suggestions raised in this, my second, public comment to the City
regarding plans, policies, and programs to address climate change impacts that threaten our quality of life.
And please let me know when any potential revisions are available to the public prior to City Council hearings.
Thanks.
Caution: This is an external email. Please be cautious when clicking links or opening
attachments.
Stanley Holmes
846 N. East Capitol Blvd.
Salt Lake City, Utah 84103
Quoting "Larsen, Nannette" <Nannette.Larsen@slcgov.com>:
Stanley,
Thank you for your comments. I will forward them to the Planning Commission for commission
members to view before the public hearing tomorrow.
Best,
NANNETTE LARSEN | (She/Her)
Senior Planner
PLANNING DIVISION | SALT LAKE CITY CORPORATION
Mobile: (801) 535-7645
Email: Nannette.Larsen@slcgov.com
WWW.SLC.GOV/PLANNING WWW.SLC.GOV
From:
Sent: Tuesday, April 25, 2023 12:52 PM
To: Larsen, Nannette <Nannette.Larsen@slcgov.com>; Planning Public Comments
<planning.comments@slcgov.com>
Cc: Wharton, Chris <Chris.Wharton@slcgov.com>; City Council Liaisons
<City.Council.Liaisons@slcgov.com>; slcgreen <slcgreen@slcgov.com>
Subject: (EXTERNAL) Public Comment on Petition PLNPCM2023-00098 - 21A.48 Landscaping and
Buffers Updates
Public Comment on Petition PLNPCM2023-00098 - 21A.48 Landscaping and Buffers Updates
From: Stanley Holmes
4-25-2023
Dear Salt Lake City Planning Commission,
I urge you to reject the proposed ordinance rewrite of 21A Zoning that was submitted as Petition
PLNPCM2023-00098 - "21A.48 Landscaping and Buffers Updates" as flawed and problematic on
several fronts. The set of proposed amendments to Title 21A Zoning should be remanded back to
Salt Lake City's Planning Division ("Division") for revision and a new, more appropriately noticed 45-
day public comment period to be opened by the Division before a corrected set of proposed Title 21A
Zoning amendments is brought before the Planning Commission ("Commission").
The proposed changes to Title 21A Zoning Chapter 48 under consideration now would have
significant, wide-ranging, and costly impacts for many Salt Lake City ("City") property owners of
various means and for all city taxpayers. That the Division would rely primarily on community council
chairs to, at their individual discretion and in a timely manner, notify the general public of
statutory/regulatory changes of this scope and magnitude can be most graciously characterized as
cavalier.
Division records indicate that only four comments were received during the 45-day comment period
and that Sugarhouse C.C. was the only community council to actively engage. I learned from city
staff that the Division’s notification system had been used, but found that there are no water
conservation, landscaping, energy conservation, environment, or other sustainability categories listed.
Through which category did the Division send the landscaping code updates notice; and how many
city residents actually get notices through that means?
Please be advised, and let the public record show, that on April 20, 2023, I posted on the community
blog --Nextdoor.com-- information about the proposed Title 21A Zoning changes and ways that
interested citizens could submit public comments. Over the next five days, Nextdoor.com reported
1,400 views and there were 48 public comments. Please see evidence of this included with the
Addendum at the close of my comment and attached.
Those folks on Nextdoor.com were Salt Lake City residents who missed the initial comment period
that ended on March 27th and, quite likely, also did not know about your April 26 Planning
Commission meeting or their opportunities to submit public comments before the zoning/ordinance
changes had become a ‘done deal.’ Outrageous.
I am also quite surprised and disappointed that there was no input from the Sustainability
Department, and wonder how their input was solicited. SLCGreen is copied on this comment, as are
my District 3 Councilman Chris Wharton and the City Council Liaisons.
City officials should have known that not every community council would post or distribute the
notice. Not every potentially interested and impacted citizen is on a community council distribution list
or regularly checks a community council's website. One might wonder to what extent the Division was
truly desirous of robust public input, having solicited comments by such a narrow and undependable
means. The Commission should insist upon a proper re-do of the public comment period and extend
its further consideration of any Title 21A Zoning Chapter 48 amendments until legitimate opportunities
for public input have occurred.
The proposed Petition PLNPCM2023-00098 - "21A.48 Landscaping and Buffers Updates" are
themselves in several ways inadequate and problematic. Their 'as is' endorsement by the
Commission and the City Council would, upon attempted implementation and enforcement by the
City, certainly result in strong opposition that would include costly litigation.
Please recall that the most recent revision of 21A.48 was in the year 2000, prior to over two decades
of climate change-exacerbated heat increases and drought that finally prompted state and local
officials to take action. The updates now under consideration were supposed to deal more effectively
with the climate change-related impacts.
Let me begin with the proposed re-write of 21A.48.010, the Purpose and Intent section. While the
earlier version calls for promoting "the prudent use of water", the update would remove this and make
no mention of water conservation as a priority. The lead "purpose" of a revised chapter 21A.48 would
be to "increase Salt Lake City's urban tree canopy"; and the lead "intent" would be to "promote and
enhance the community's appearance."
While trees are nice, useful, and can be aesthetically pleasing, the City is located in the second
driest U.S. state and is experiencing an unprecedented, worsening drought. Water conservation
should not only have been mentioned in the proposed re-write of 21A.48.010, but been listed as a
priority goal, as has been done by other Utah municipalities. Why was this not done?
Under the current zoning ordinance, Section 21A.48.060 refers to Park Strip Landscaping and one of
the "intent" items is to "encourage water conservation". But the proposed re-write (update) would
change the title of 21A.48.060 to "Landscape Requirements" and remove the water conservation
reference.
The re-write of 21A.48.060 has a new "Park Strip Standards" section that adds the requirement of at
least one "street tree" in the park strip. Additional park strip trees would be required, depending on
the park strip length. The current ordinance has no park strip tree requirement. Therefore, residents
who've implemented water-wise park strip measures --in compliance with the existing ordinance --
that do not include at least one street tree would be required to add a tree and, according to the
21A.48.040 re-write, see that it is "irrigated with a permanent automatic irrigation system." A
hydrozoned irrigation system would be required, so that tree(s) watering can be isolated from any
water needed for other vegetation.
The park strip abutting property owner would have to pay for the new park strip tree-plus-irrigation
requirement. That could be quite costly, especially if the park strip has to be excavated to install the
required irrigation system. The Commission should assume that some residents will be unable to
afford this and that others who had been compliant would rather fight the compliance rules change in
court. Please consider the burden on low-income families, especially if the $25-per-day violation fine
is retained.
The Commission should also consider that the City's Department of Community and Neighborhood's
Civil Enforcement staff would have to be expanded and that additional budgetary provisions would
have to be made for the City's legal team. Litigation could delay implementation and enforcement of
parts or all of the proposed 21A.48 Landscaping and Buffers Updates for an extended period of time.
And aside from pushback from angry residents delaying implementation of the proposed ordinance
updates, the sheer magnitude of any effort to achieve widespread compliance should sober city
planners and policy-makers. Have Division staff conducted a city-wide, on-street survey of the
number of park strips that would require tree-planting and new irrigation plumbing? Have they
calculated how many contractors, and how many years, would be required to accomplish full
implementation? Then, there's the additional per-tree water requirement times however many park
strips would be affected.
At this point, I'll add that there are some positive aspects of the proposed ordinance re-write, such as
21A.48.040.E.1., which says that "All irrigation systems shall be maintained in good operating
condition to eliminate water waste and run-off into the public right-of-way." Drip irrigation is also
mentioned in 21A.48.040.E, though it could have been promoted.
Some of the proposed re-write items are not clear. For example, 21A.48.040.C.2. "Exceptions"
circles back to itself. And under 21A.62 "Definitions", the Park Strip Landscaping section says that
park strip landscaping may include "lawn", which is normally a reference to turf. The re-write, under
21A.48.060 and 21A.48.080, prohibits turf in park strips. There is also a reference to the right-of-way
line's relevance if there is no sidewalk, but the dimensions of the right-of-way line are not given.
As a final point to this comment, it concerns me that the City Planning Division failed to take a
holistic view of the abutting residential property owner's landscape unless a new home is being
constructed or the floor area of an existing structure(s) is being expanded by 50% or more. The
overall vegetative contribution of individual residential properties that are not undergoing structural
change is ignored by the proposed 21A Zoning rewrite's determination of compliance or non-
compliance with new park strip requirements. I can imagine situations where the owner of a well-
wooded, well-vegetated residential property is forced to install and water a park strip tree while the
owner of a minimally vegetated property who happens to have a tree in the park strip is left alone.
Where is the environmental justice in that?
Salt Lake City needs to do a better job of conserving water. The proposed amendments to Title 21A
Zoning are inadequate to the task, as they do not give water conservation the top priority status our
current megadrought crisis demands. I urge the Commission to deny Petition PLNPCM2023-00098 -
"21A.48 Landscaping and Buffers Updates" and send it back to the Division for revision and a
properly noticed, 45-day public review and comment period.
I thank you in advance for your thoughtful consideration of the points I raised and your directive to
have the ordinance revised in a more transparent way that better engages the public and serves the
City's best interests.
Stanley Holmes
846 N. East Capitol Blvd.
Salt Lake City, UT 84103
Addendum:
My attempt to use Nextdoor.com to notify the public of proposed 21A.48 changes, first posted on April
20, 2023, is copied below. In five days, 1,400 views and 48 resident comments. The Planning
Division got 4 public comments in 45 days.
Stan Holmes
Author
•West Capitol Hills•0 mi
SLC Park Strip, Landscape Policy Changes
Public comments are being taken by the Salt Lake City Planning Division and Planning Commission
as they consider city-wide changes to the Landscaping Chapter of the Zoning Code. This includes
proposed revision of the Park Strip ordinance under which many city residents have been penalized
for their water conservation efforts. The proposed Park Strip policy revision would require one "street
tree" every 30 feet and vegetation covering at least 30% of the area. See all proposed amendments
at... www.slcdocs.com/Planning/Online%20Open%20Houses/2023/02_2023/PLNPCM2023-
00098/02102023%20DRAFT%20Landscaping%20Updates_Posted.pdf The Planning Commission
will consider landscape/park strip ordinance changes at its April 26 meeting. Public comments can be
submitted in-person or via email to and . Reference case number PLNPCM2023-00098 in the subject
line. The agenda for next Wednesday's (April 26) Planning Commission meeting is at...
www.slcdocs.com/Planning/Planning%20Commission/2023/PC04.26.2023/PC04.26.2023agenda.pdf
Whatever the Planning Commission decides will then be presented to the City Council for final
approval. Now is the time to shift from opinion to action and file a public comment.
Stan Holmes
Author
•West Capitol Hills•0 mi
The email addresses that were stripped are planning.comments and nannette.larsen that are both at
slc.gov. They are also listed in the April 26 agenda at...
www.slcdocs.com/Planning/Planning%20Commission/2023/PC04.26.2023/PC04.26.2023agenda.pdf
also attached:
5)PUBLIC UTILITIES DIRECTOR STATEMENT
From:Briefer, Laura
To:Larsen, Nannette
Cc:Thompson, Amy; Bench, Nikole; Rice, Marian; Duer, Stephanie; Draper, Jason
Subject:RE: Landscaping Chapter Planning Commission Public Hearing Tonight
Date:Wednesday, April 26, 2023 1:02:05 PM
Attachments:image002.png
image003.png
Good afternoon, Nannette – please let me know if this will be useful tonight for the questions
concerning artificial turf– see below:
Artificial turf has the potential to impact water quality and stormwater runoff in the following ways:
1.The combination of soil compaction in the installation of artificial turf and the material that is
used does not allow water to be retained onsite. As such, this is considered an impermeable
surface. This contributes to additional stormwater runoff from a site, which can have negative
downstream impacts, such as flashier and increased stormwater flows.
2.As stormwater flows across impermeable surfaces it picks up and carries pollutants that get
deposited in receiving water bodies, such as the Jordan River and streams that flow through
our city. All stormwater that flows through Salt Lake City ultimately heads toward Great Salt
Lake.
3.Pollutants of concern that can emanate directly from artificial turf include micro-plastics and
PFAS compounds (https://www.epa.gov/pfas/pfas-explained). PFAS compounds are “forever
chemicals” that pose health risks to people and animals. It is unclear whether all artificial turf
contains PFAS compounds, but there is evidence that at least some of it does. To our
knowledge, it is not currently tested and certified regarding the presence or absence of PFAS.
Microplastics also pose health risks to people and animals. Both PFAS and microplastics are
ubiquitous in the environment, and there is much concern nationally and globally about this
pollution.
4.Artificial turf also needs to be washed periodically, which could contribute runoff that contains
cleaning chemicals. Pet feces needs to be removed from artificial turf, and pathogens from pet
feces could be introduced into stormwater during cleaning.
Regulatory and health considerations with respect to PFAS compounds: Salt Lake City
Public Utilities is obligated to comply with drinking water and clean water regulations promulgated
by the US Environmental Protection Agency (EPA) and enforced by both the Utah Department of
Environmental Quality and the EPA. The EPA is prioritizing the regulation of PFAS in drinking water
and in cradle to grave hazardous materials regulations (https://www.epa.gov/pfas/key-epa-actions-
address-
pfas#:~:text=On%20August%2026%2C%202022%2C%20EPA,for%20cleaning%20up%20their%20c
ontamination). In March 2023, EPA proposed new very stringent regulations for six PFAS
compounds with a proposed maximum contaminant level of four (4) parts per trillion, showcasing
that EPA is extremely concerned about the health risks associated with PFAS in drinking water. The
EPA is also considering new regulations under the Clean Water Act which would affect stormwater
and wastewater discharges. Finally, EPA is considering new PFAS regulations under the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, also known as
Superfund). This primarily impacts environmental remediation for PFAS-contaminated soil and
water, and there is some concern about the potential long thread of liability associated with PFAS
contamination.
Please let me know if you have any further questions. I have added Jason and Stephanie to this email
thread too.
LAURA BRIEFER, MPA | (She/Her/Hers)
DIRECTOR
Department of Public Utilities | Salt Lake City Corporation
Office: (801) 483-6741
Cell: (385) 252-9379
Email: Laura.Briefer@slcgov.com
www.slc.gov/utilities
www.slc.gov
Signature:
Email:
Alejandro Sanchez (Dec 4, 2023 13:15 MST)
alejandro.sanchez@slcgov.com
11152023 Transmittal FINAL
Final Audit Report 2023-12-04
Created:2023-11-27
By:Aubrey Clark (aubrey.clark@slcgov.com)
Status:Signed
Transaction ID:CBJCHBCAABAA0PzvbpGjNz77WUcjaXmTX2mPGTprNRHF
"11152023 Transmittal FINAL" History
Document created by Aubrey Clark (aubrey.clark@slcgov.com)
2023-11-27 - 6:43:40 PM GMT
Document emailed to Blake Thomas (blake.thomas@slcgov.com) for signature
2023-11-27 - 6:46:21 PM GMT
Email viewed by Blake Thomas (blake.thomas@slcgov.com)
2023-11-27 - 6:54:35 PM GMT
Document e-signed by Blake Thomas (blake.thomas@slcgov.com)
Signature Date: 2023-11-27 - 8:29:54 PM GMT - Time Source: server
Document emailed to Alejandro Sanchez (alejandro.sanchez@slcgov.com) for signature
2023-11-27 - 8:29:57 PM GMT
Email viewed by Alejandro Sanchez (alejandro.sanchez@slcgov.com)
2023-11-27 - 8:31:28 PM GMT
New document URL requested by Blake Thomas (blake.thomas@slcgov.com)
2023-12-04 - 8:11:11 PM GMT
Document e-signed by Alejandro Sanchez (alejandro.sanchez@slcgov.com)
Signature Date: 2023-12-04 - 8:15:44 PM GMT - Time Source: server
Document emailed to rachel otto (rachel.otto@slcgov.com) for signature
2023-12-04 - 8:15:48 PM GMT
Email viewed by rachel otto (rachel.otto@slcgov.com)
2023-12-04 - 10:33:18 PM GMT
Document e-signed by rachel otto (rachel.otto@slcgov.com)
Signature Date: 2023-12-04 - 10:34:11 PM GMT - Time Source: server
Agreement completed.
2023-12-04 - 10:34:11 PM GMT