AGENDA. Environmental Committee Meeting. Monday, February 26, :30 p.m. City Council Chambers 3800 Laverne Avenue North. A.

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1 Our Mission is to Provide Quality Public Services in a Fiscally Responsible Manner While Preserving the City s Open Space Character Environmental Committee Meeting Monday, February 26, :30 p.m. City Council Chambers 3800 Laverne Avenue North AGENDA A. Call to Order B. Minutes-November 27, 2017 C. Arbor Day 2018 D. Water conservation E. Hagberg s recognition F. Recycling center visit(s) G. Next Meeting-TBD H. Adjourn

2 City of Lake Elmo Environmental Committee Meeting Minutes of November 27, 2017 COMMITTEE MEMBERS PRESENT: Brenda Jo Carlson, Tedi Carlson, and Dominic Travis COMMITTEE MEMBERS ABSENT: Scott Drommerhausen and Beverly Schwalbach STAFF PRESENT: Assistant City Administrator Jake Foster Call to Order By Chair Carlson at 5:30pm Minutes-September 25, 2017 Motion by Brenda Jo Carlson, seconded by Travis to approve the minutes from the September 25, 2017 meeting. Motion carried 3-0. Environmentally Responsible Recognition Policy Assistant City Administrator Jake Foster summarized the proposed policy and provided a brief overview of the related processes. General discussion to place in regards to who could be nominated and how the nomination/recommendation process would take place. Foster addressed questions from committee members relating to how nominees should be brought forth, who would be eligible for nomination, and how they would be recognized. It was also discussed that this policy could be changed and improved in the future if need be. Motion by Brenda Jo Carlson, seconded by Travis to recommend the environmentally responsible practices recognition policy to Council for approval. Motion carried 3-0. Invitation to Comment on Historic Properties Affected by Proposal Foster summarized the invitation to comment on historic properties affected by the proposed cell tower sent from Environmental Resources Management. Committee members had questions regarding the height of the tower, current use of the land, and if there would be any impact. Foster also showed the committee members a map of the location at hand. As this invitation was to comment on whether or not there were any historical properties affected by the proposal, and the committee members were not aware of any impact, it was decided no comment would need to be made so long as appropriate due-diligence was done on behalf of Verizon Wireless. Ideas for Recycling/Environmental Guide Foster provided details for a potential recycling guide for the City, and referenced the City of Forest Lake providing a similar resource for residents.

3 Next Meeting Monday, February 26, 2018 at 5:30pm Without any specific agenda items, committee members discussed visiting the Washington County Recycling Center in January for ideas on what they should be looking for in recognizing environmentally-friendly practices and for the proposed recycling guide. Meeting adjourned at 6:46pm Respectfully Submitted, Jake Foster

4 STAFF REPORT DATE: February 26, 2018 TO: Environmental Committee AGENDA ITEM: Arbor Day 2018 SUBMITTED BY: Jake Foster, Assistant City Administrator BACKGROUND: As in past years and discussed at previous meetings, the committee will be hosting an Arbor Day Tree Giveaway event. The date and time of the event will be Saturday, April 29, 2017 from 9:00 AM to noon. People will need to bring their own bags to transport the trees. There will be 475 trees to giveaway. The Mayor will also be issuing an Arbor Day Proclamation at the April 17 th meeting to maintain tour Tree City USA status. ISSUE BEFORE COMMITTEE: Volunteers? Tree transportation? PROPOSAL DETAILS/ANALYSIS: We will need volunteers from the committee to commit to helping with the event. Set up will occur between 8am and 9am. Myself and Kristina will be at the event and can open the city hall doors for access to a table for checking IDs. Rather than sign-in residents, volunteers can check IDs to verify that individuals are Lake Elmo residents. Help may also be needed in assisting folks with their tree selection. As in years past, flyers with planting instructions will be provided for each tree. Additionally, we will also need a volunteer (or volunteers) with access to a truck to transport the trees to city hall. To save with shipping costs, the trees will once again be combined with the County s shipment. The trees have been delivered to the fairgrounds in prior years, but the delivery location will be verified closer to the date of the event. FISCAL IMPACT: $500 for trees and delivery ATTACHMENTS: Arbor Day Flyer Schumacher Nursery & Berry Farm Sales Order

5 Saturday, April 28, 2018 In celebration of Arbor Day, the City of Lake Elmo s Environmental Committee is sponsoring a tree giveaway on April 28th, 9:00am-12:00pm at City Hall

6 Schumacher Nursery & Berry Farm th St Heron Lake, MN USA Voice: Fax: SALES ORDER Sales Order Number: SO7319 Sales Order Date: Jan 2, 2018 Ship By: Jan 2, 2018 Page: 1 To: CITY OF LAKE ELMO 3800 LAVERNE AVE N LAKE ELMO, MN Ship To: CITY OF LAKE ELMO 3800 LAVERNE AVE N LAKE ELMO, MN Customer ID CITY OF LAKE ELMO Customer Contact JAKE FOSTER PO Number Shipping Method Truck Sales Rep Name Payment Terms Net 30 Days Quantity Item Description Unit Price Amount SPRNOT07 SPRUCE, NORWAY BIRPAS12 BIRCH, PAPER HACS12 HACKBERRY MAPSUS12 MAPLE, SUGAR PINWHT07 PINE, WHITE LILCOS12 LILAC, COMMON PURPLE CHENAS12 CHERRY, NANKING Subtotal Sales Tax Freight 0.00 TOTAL ORDER AMOUNT

7 STAFF REPORT DATE: February 26, 2018 TO: Environmental Committee AGENDA ITEM: Water conservation SUBMITTED BY: Jake Foster, Assistant City Administrator BACKGROUND: The City has been a part of a nine city consortium, the Washington County Municipal Water Coalition, aimed at water efficiency and the long-term sustainability of water supplies within the area. The Coalition retained Short Elliott Hendrickson Inc. (SEH) to complete a study of water efficiency practices. Additionally, as a result of the White Bear Lake vs. the Minnesota Department of Natural Resources lawsuit, all existing Lake Elmo water permits will need to include an enforceable plan to phase down per capital residential water us to 75 gallons/day and total per capita water us to 90 gallons/day. ISSUE BEFORE COMMITTEE: Would the committee like to address the issue of water conservation? Next steps? PROPOSAL DETAILS/ANALYSIS: There are several potential routes the committee could pursue relating to water conservation and the longterm sustainability of water supplies in the area. SEH has outlined several opportunities for the City of Lake Elmo to improve their water efficiency in that portion of the study. If the committee chooses to address water efficiency and long-term sustainability, a member from SEH has agreed to come to a future committee meeting to address their findings and how the committee and City can best move forward. Conversely, the committee could also choose to explore any water efficiency/conservation methods outlined in the study, other methods that are not included in the study, or choose not to address water conservation and long-term sustainability of Lake Elmo s water altogether. FISCAL IMPACT: None ATTACHMENTS: Water Efficiency Study Executive Summary

8 Water Efficiency Study Executive Summary Washington County Municipal Water Coalition Washington County, Minnesota SEH No January 31, 2018

9 About this Report Executive Summary The Washington County Municipal Water Coalition recognizes that water supply planning is an integral component of long-term regional and local comprehensive planning. The Coalition has undertaken projects to provide a base of technical information needed to make sound water supply decisions. This report executive summary summarizes the result of work for the Washington County Municipal Water Coalition Water Efficiency Study. The Washington County Municipal Water Coalition includes the cities of Bayport, Cottage Grove, Lake Elmo, Newport, Oakdale, Oak Park Heights, Stillwater, Saint Paul Park, and Woodbury. The Washington County Municipal Water Coalition retained Short Elliott Hendrickson Inc. (SEH) to complete this study of water efficiency practices. This assessment has been carried out with input from, and engagement with stakeholders, including community public water utilities, through a technical advisory committee (TAC). This group continues to meet regularly to discuss the study along with other water supply topics of importance to group members. Partial funding for this project was provided through the Clean Water Fund. Recommended Citation Executive Summary, Washington County Municipal Water Coalition Water Efficiency Study, Prepared by Short Elliott Hendrickson Inc., St. Paul, MN.

10 Executive Summary The primary source of drinking water in southern Washington County is groundwater from the Prairie du Chien-Jordan aquifer. Concerns with groundwater use in the region include areas of contamination, interference with surface waters, and potential aquifer drawdown due to increased future demands. It is possible that groundwater may not be able to meet all of the future drinking water demands. The Washington County Municipal Water Coalition (Coalition) consists of interested community stakeholders engaged to address the long-term sustainability of water supplies within the area. The Coalition includes the communities of Bayport, Cottage Grove, Lake Elmo, Newport, Oakdale, Oak Park Heights, Stillwater, Saint Paul Park, and Woodbury. The Coalition, with the assistance of Metropolitan Council Environmental Services (MCES) and Washington County, led this study to evaluate opportunities for water efficiency within the Coalition communities. In 2016, MCES, working with the communities of the Coalition, led the Water Supply Feasibility Assessment to examine feasibility of approaches to meet future water demands of the Coalition. The approaches focused on adding new sources of water including reusing water from pollution containment wells, new surface water treatment plants, connecting to Saint Paul Regional Water Services, and drilling new wells. The 2016 Feasibility Assessment provided the Coalition with concept level costs and considerations for various water supply approaches. The 2016 Feasibility Assessment primarily looked at alternatives to meet increased demand (supply side alternatives) and only provided a cursory review of water efficiency opportunities. WASHINGTON COUNTY MUNICIPAL WATER COALITION ES-1

11 Objective The Coalition communities have expressed a desire to explore the potential to implement water efficiency practices in order to reduce groundwater use before it becomes necessary to find new water supply sources at significant expense. The primary objective of this study was to investigate the water demand reduction potential of communities in the Coalition by using water more efficiently. The study evaluates opportunities for improved water efficiency in the following areas: Landscape irrigation Indoor water use (toilets, faucets, showerheads, clothes washing machines) Industrial and Commercial water use Distribution system metering and non-revenue water Landscape Irrigation Efficiency Opportunities An analysis of water use patterns in the Coalition communities indicated that an additional 2.2 billion gallons (equivalent to 6 million gallons per day for an entire year) of water is used in the summer above winter water use. This is referred to as non-essential water use. The primary component of the non-essential water use is landscape irrigation. A major opportunity for water efficiency is to install smart controllers on the irrigation systems. Most existing irrigation systems use clock-based controllers. A smart controller is an electronic device that monitors environmental factors in order to operate an irrigation system to optimize water consumption. A recent study conducted by the Minnesota Technical Assistance Program (MnTAP) determined that smart controllers can reduce water demand by up to 50% over clock-based controllers. This water efficiency study determined the following: If half of the existing residential irrigation systems in the coalition installed smart controllers and achieved 30% water savings: Water demand is reduced by 250 million gallons a year Residents save $500,000 annually on utility bills Indoor Water Efficiency Opportunities Water efficiency opportunities also exist to reduce indoor water usage. These include water efficient toilets, shower heads, faucets, and washing machines. WaterSense Toilets According to US EPA, 24 percent of the average American household s indoor water use is from toilet flushing. In 1994, the U.S. Environmental Policy Act of 1992 went into effect mandating maximum water consumption for toilets at 1.6 gallons per flush (gpf). By replacing standard toilets in homes constructed prior to 1994 with WaterSense labeled toilets, a 63 percent savings in water can be realized per flush. Installing WaterSense toilets can reduce water use by 10,500 gallons and save a household $60 per year in utility bills WaterSense Shower Head EPA estimates 20 percent of the average American household s water use is from showers. Standard shower heads use 2.5 gallons per minute (gpm) of water. WaterSense labeled shower heads use no more than 2.0 gpm of water. Installing WaterSense shower heads can reduce water use by 2,700 gallons and save a household $65 per year in utility bills. WaterSense Faucets EPA estimates that 19 percent of the average American household s water use is from faucets. Standard faucets use 2.2 gpm of water. WaterSense labeled faucets use no more than 1.5 gpm of water. Installing WaterSense faucets can reduce water use by 700 gallons and save a household $17 per year in utility bills. Municipalities save over $100,000 in operation and maintenance (O&M) costs a year WASHINGTON COUNTY MUNICIPAL WATER COALITION ES-2

12 Commercial, Industrial, and Institutional Efficiency Opportunities EnergyStar Clothes Washing Machines EPA estimates that approximately 17 percent of indoor water use in the average American household is from clothes washing machines. The average American family washes about 300 loads of laundry each year. EnergyStar rated machines can help residents reduce water and energy costs by using up to 45 percent less water and 25 percent less energy compared to standard machines. Installing EnergyStar washing machines can reduce annual water use by 3,000 gallons and save a household $67 per year in utility bills. Overall Indoor Water Efficiency Opportunity This study determined the following: If half of the existing homes in the Coalition communities constructed prior to 1990 installed water efficient toilets, shower heads, faucets and washing machines: Water demand is reduced by approximately 250 million gallons a year Residents save $3,000,000 annually on utility bills The same irrigation and indoor efficiency opportunities that exist for residential properties also exist for commercial, industrial, and institutional facilities. In addition to those opportunities, commercial and industrial customers have water efficiency opportunities that are specific to their type of facility. Non-Revenue Water Non-revenue water is the amount of water not delivered to paying customers. There are a number of sources of nonrevenue water including: leaks in the distribution system, metering inaccuracies, water used in parks, ice skating rinks, hydrant flushing, etc. The Minnesota Department of Natural Resources considers an acceptable amount of non-revenue water to be less than 10%. The total annual non-revenue water for the Coalition is approximately 230 million gallons. At $2.00 per 1,000 gallons, the value of this water is approximately $460,000. Community Profiles Profiles identifying each Coalition community s overall water use patterns, potential savings for residents and utilities, and water efficiency opportunities specific to the individual community are presented below. Municipalities save over $100,000 in operation and maintenance (O&M) costs WASHINGTON COUNTY MUNICIPAL WATER COALITION ES-3

13 Bayport Water Use, Per Person, gallons/day All Uses 119 Residential Use 73 Total Annual Use, million gallons 103 Non-Revenue Water 6% Non-Residential Use 39% Water Use Profile: Bayport is a smaller community with older homes and relatively low growth expected. Bayport has higher industrial water use and lower irrigation water use. Indoor Use Indices Median Home Age: 1960s Essential Water Use: 76% Outdoor Use Indices Non-Essential Use 24% Peak to Winter Use Ratio 2.8 All Uses in Summer 258 gal/person/day All Uses in Winter 89 gal/person/day WATER EFFICIENCY OPPORTUNITIES FOR THE CITY OF BAYPORT 27% 12% 61% Residential Use Commercial Use Industrial Use Significant opportunities for residential indoor water efficiency. Water efficient indoor fixtures could save 9 million gallons of water per year. Total savings for residents: $110,000 per year Utility O&M Savings: $3,700 Partner with industrial customers to encourage water efficiency. Relatively low irrigation efficiency opportunity; however, smart controllers are still very effective. Based on 2013 water use records and population Cottage Grove Water Use Profile: Cottage Grove is the second largest community in the Coalition and is expected to grow by an additional 35% by the year Although Cottage Grove is a growing suburb, they have a relatively high percentage of homes constructed prior to % Water Use, Per Person, gallons/day Indoor Use Indices Outdoor Use Indices 9% All Uses 90 Median Home Age: 1980s Non-Essential Use 34% Residential Use 80 Essential Water Use: 66% Peak to Winter Use Ratio 4.3 All Uses in Summer Total Annual Use, million gallons 1, gal/person/day 89% Non-Revenue Water 11% All Uses in Winter Non-Residential Use 11% 53 gal/person/day Residential Use Institutional Use Commercial Use WATER EFFICIENCY OPPORTUNITIES FOR THE CITY OF COTTAGE GROVE Significant opportunities for residential indoor water efficiency. Smart irrigation controllers could save 57 million gallons of water per year. Perform water audit to identify causes of non-revenue water. Water efficient indoor fixtures could save 55 million gallons of water per year. Total savings for residents: $780,000 per year Utility O&M Savings: $47,000 Based on 2013 water use records and population WASHINGTON COUNTY MUNICIPAL WATER COALITION ES-4

14 Lake Elmo Water Use Profile: Lake Elmo is a medium sized community where many of its residents are not on the municipal water systems. Some areas on the municipal water system are newer and are experiencing very rapid growth. The high non-essential water use and peak to winter ratio is due to establishing sod in new developments. Water Use, Per Person, gallons/day Indoor Use Indices Outdoor Use Indices 24% All Uses 110 Median Home Age: 1990s Non-Essential Use 52% Residential Use 81 Total Annual Use, million gallons 165 Non-Revenue Water 2% Non-Residential Use 24% Essential Water Use: 48% Peak to Winter Use Ratio 5.0 All Uses in Summer 283 gal/person/day All Uses in Winter 57 gal/person/day 76% Residential Use Commercial Use WATER EFFICIENCY OPPORTUNITIES FOR THE CITY OF LAKE ELMO Significant opportunities for residential irrigation and indoor water efficiency. Smart irrigation controllers could save 5 million gallons of water per year. Partner with commercial and institutional properties to encourage water efficiency. Water efficient indoor fixtures could save 4 million gallons of water per year. Total savings for residents: $60,000 per year Utility O&M Savings: $47,000 Based on 2013 water use records and population Newport Water Use Profile: Newport is a smaller community with older homes and relatively low growth is expected. Newport s overall water use is very low. Water Use, Per Person, gallons/day Indoor Use Indices Outdoor Use Indices All Uses 76 Residential Use 45 Median Home Age: 1960s Essential Water Use: 87% Non-Essential Use 13% Peak to Winter Use Ratio % Total Annual Use, million gallons 106 All Uses in Summer 116 gal/person/day 61% Non-Revenue Water 10% Non-Residential Use 39% All Uses in Winter 65 gal/person/day Residential Use Commercial Use WATER EFFICIENCY OPPORTUNITIES FOR THE CITY OF NEWPORT Significant opportunities for indoor water efficiency. Water efficient indoor fixtures could save 12 million gallons of water per year. Total savings for residents: $143,000 per year Utility O&M Savings: $5,000 Perform water audit to identify causes of non-revenue water. Partner with commercial and institutional properties to encourage water efficiency. Based on 2013 water use records and population WASHINGTON COUNTY MUNICIPAL WATER COALITION ES-5

15 Oak Park Heights Water Use Profile: Oak Park Heights is a smaller community with relatively little growth expected. Oak Park Heights has very low non-essential water usage. A significant portion of Oak Park Heights water usage is commercial/institutional. Water Use, Per Person, gallons/day Indoor Use Indices Outdoor Use Indices All Uses 125 Residential Use 71 Median Home Age: 1990s Essential Water Use: 88% Non-Essential Use 12% Peak to Winter Use Ratio % Total Annual Use, million gallons 228 All Uses in Summer 250 gal/person/day 57% Non-Revenue Water 13% Non-Residential Use 43% All Uses in Winter 107 gal/person/day Residential Use Commercial Use WATER EFFICIENCY OPPORTUNITIES FOR THE CITY OF OAK PARK HEIGHTS Oak Park Heights highest potential for water efficiency is likely commercial/institutional. Perform water audit to identify causes of nonrevenue water. Opportunities exist for indoor water efficiency. Water efficient indoor fixtures could save 6 million gallons of water per year. Total savings for residents: $75,000 per year Utility O&M Savings: $2,500 Based on 2013 water use records and population Oakdale Water Use Profile: Oakdale is one of the larger Coalition communities, is relatively mature, and is not expected to grow significantly. Oakdale s overall water use is moderate. 1% Water Use, Per Person, gallons/day Indoor Use Indices Outdoor Use Indices 20% All Uses 90 Median Home Age: 1980s Non-Essential Use 25% Residential Use 75 Total Annual Use, million gallons 937 Non-Revenue Water 3% Non-Residential Use 21% Essential Water Use: 75% Peak to Winter Use Ratio 2.6 All Uses in Summer 176 gal/person/day All Uses in Winter 67 gal/person/day 79% Residential Use Commercial Use Industrial Use WATER EFFICIENCY OPPORTUNITIES FOR THE CITY OF OAKDALE Significant opportunities for indoor water efficiency and smart irrigation controllers. Partner with commercial and institutional properties to encourage water efficiency. Water efficient indoor fixtures could save 47 million gallons of water per year. Smart irrigation controllers could save 29 million gallons of water per year. Total savings for residents: $630,000 per year Utility O&M Savings: $32,000 Based on 2013 water use records and population WASHINGTON COUNTY MUNICIPAL WATER COALITION ES-6

16 Saint Paul Park Water Use Profile: Saint Paul Park is a smaller community with older homes and relatively low growth is expected. Saint Paul Park has higher industrial use and their non-essential water use is very low. 5% Water Use, Per Person, gallons/day All Uses 85 Residential Use 60 Total Annual Use, million gallons 179 Non-Revenue Water 8% Non-Residential Use 24% Indoor Use Indices Median Home Age: 1960s Essential Water Use: 92% Outdoor Use Indices Non-Essential Use 8% Peak to Winter Use Ratio 1.8 All Uses in Summer 140 gal/person/day All Uses in Winter 78 gal/person/day 19% 76% Residential Use Commercial Use Industrial Use WATER EFFICIENCY OPPORTUNITIES FOR THE CITY OF SAINT PAUL PARK Significant opportunities for indoor water efficiency. Water efficient indoor fixtures could save 15 million gallons of water per year. Total savings for residents: $182,000 per year Utility O&M Savings: $6,000 Partner with industrial properties to encourage water efficiency. Perform water audit to identify causes of nonrevenue water. Based on 2013 water use records and population Stillwater Water Use Profile: Stillwater is one of the larger Coalition communities, is relatively mature, and is not expected to grow significantly. Stillwater s overall water use is moderate. Water Use, Per Person, gallons/day All Uses 111 Residential Use 81 Total Annual Use, million gallons 738 Non-Revenue Water 1% Non-Residential Use 27% Indoor Use Indices Median Home Age: 1960s Essential Water Use: 75% Outdoor Use Indices Non-Essential Use 32% Peak to Winter Use Ratio 3.0 All Uses in Summer 228 gal/person/day All Uses in Winter 76 gal/person/day 19% 8% 73% Commercial Use Residential Use Institutional Use WATER EFFICIENCY OPPORTUNITIES FOR THE CITY OF STILLWATER Significant opportunities for indoor water efficiency and smart irrigation controllers. Water efficient indoor fixtures could save 50 million gallons of water per year. Smart irrigation controllers could save 26 million gallons of water per year. Total savings for residents: $660,000 per year Utility O&M Savings: $32,000 Based on 2013 water use records and population WASHINGTON COUNTY MUNICIPAL WATER COALITION ES-7

17 Woodbury Water Use Profile: Woodbury is the largest community in the Coalition and is expected to grow by an additional 34% by the year Woodbury is a newer community 6% and has high residential and commercial irrigation water use. Water Use, Per Person, gallons/day Indoor Use Indices Outdoor Use Indices 17% All Uses 114 Median Home Age: 1990s Non-Essential Use 42% Residential Use 96 Total Annual Use, million gallons 2,755 Essential Water Use: 58% Peak to Winter Use Ratio 4.0 All Uses in Summer 262 gal/person/day 77% Non-Revenue Water 1% Non-Residential Use 23% All Uses in Winter 65 gal/person/day Residential Use Commercial Non-Irrigation Commercial Irrigation WATER EFFICIENCY OPPORTUNITIES FOR THE CITY OF WOODBURY Significant opportunities for residential irrigation water efficiency and moderate opportunities for indoor water efficiency Smart irrigation controllers could save 128 million gallons of water per year. Continue to partner with commercial businesses and homeowners associations to install smart irrigation controllers. Commercial and HOA irrigation accounts for over 200 million gallons of water use per year in Woodbury. Water efficient indoor fixtures could save 50 million gallons of water per year. Total savings for residents: $870,000 per year Utility O&M Savings: $74,000 per year Based on 2013 water use records and population WASHINGTON COUNTY MUNICIPAL WATER COALITION ES-8

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19 STAFF REPORT DATE: February 26, 2018 TO: Environmental Committee AGENDA ITEM: Hagberg s recognition SUBMITTED BY: Jake Foster, Assistant City Administrator BACKGROUND: At the December 5 th, 2017 meeting, Council approved the committee s recommended policy to implement a program to recognize businesses, organizations, and individuals in Lake Elmo that are engaging in environmentally-friendly practices. Committee Chair, Tedi Carlson, nominated Hagberg s to be added to the agenda and discussed for recommendation to Council to be recognized for their environmentally-friendly practices. ISSUE BEFORE COMMITTEE: Should the committee recommend to Council the recognition of Hagberg s for environmentally-friendly practices? PROPOSAL DETAILS/ANALYSIS: Chair Carlson will provide some details as to why they should be recognized, and committee members can further discuss whether or not they would like to recommend them for recognition. FISCAL IMPACT: None RECOMMENDATION: Move to recommend to Council that Hagberg s be recognized for engaging in environmentallyfriendly practices. ATTACHMENTS: None