Make Developers Pay for Tree Canopy Loss!

Action Alert –  TreePAC.org and Friends of Seattle’s Urban Forest

With the tremendous growth going on in Seattle, trees are more threatened than ever. Developers are clamoring for fewer restrictions and are winning as the Seattle City Council continues to assist developers in their push for more housing and especially affordable housing.  Current legislation before the City Council Planning, Land Use and Zoning Committee, CB 119057 modifying the design review process, is set to be moved on in committee, this Tuesday, Sept 19th at 9:30 AM. It will speed up the design review process and make more administrative decisions rather than citizen review.

The current tree protection ordinance is out of date and has been in interim status for 8 years. Its way past time to update it as development interests put increased pressure on tree loss.   Besides repeatedly recommending the City update its interim tree ordinance, The Seattle Urban Forestry Commission has made 2 recent specific recommendations to the City Council to act on now.

  • The first recommendation is to track tree and canopy removal per project. Specifically, the Commission recommends tracking significant tree removals, exceptional tree removals, and removed canopy coverage, in square feet, as part of a complete application.Without this data, the City cannot accurately quantify tree and canopy removal and implement appropriate tree planting efforts. See the Commission’s previous letter of recommendation dated June 25, 2014 (enclosed).
  • The second recommendation is to provide a fee-in-lieu option for projects unable to replace trees equal to the number of trees and amount of canopy removed by a project. There is a lost public benefit associated with the removal of public and private trees which impacts human psychology, ecosystem services, public health, and neighborhood character. A tree removal fee-in-lieu option should be similar to the alternative compliance option for stormwater mitigation yet deposited in an Urban Forestry Account to fund planting and maintaining for long-term, healthy trees in Seattle.

Please contact the Committee members before Tuesday if possible, either by e-mail or phone,   and urge them to act on these recommendations. They can also be contacted after Tuesday urging support for passing a strong tree ordinance. If you are able to come to the committee meeting on Tuesday in Council Chambers in City Hall, there is a public comment period at the beginning of the meeting.

Rob.Johnson@seattle.gov –  Chair    206-684-8808

mike.obrien@seattle.gov    206-684-8802

lisa.herbold@seattle.gov   206-684-8803

lorena.gonzalez@seattle.gov     206-684-8802

Thanks,

Steve Zemke – Chair – TreePAC.org and Friends of Seattle’s Urban Forest

www.TreePAC.org

www.friends.urbanforests.org

P.S. for additional information see:

Seattle Urban Forestry Commission letter – Design Review Program Improvements – CB119057

Friends of Seattle Urnban Foest and TreePAC letter –

Concerns about CB 119057 modifying design review process

Seattle Urban Forestry Commission – Comments on Design Review Improvements – CB119057

Seattle Urban Forestry Commission
Tom Early, Chair • Steve Zemke, Vice-Chair
Weston Brinkley • Leif Fixen • Megan Herzog • Craig Johnson
Joanna Nelson de Flores • Sarah Rehder • Andrew Zellers
September 13, 2017.
Councilmember Rob Johnson
City Hall
600 4th Ave.
Seattle, WA 98124

RE: Design Review Program Improvements – CB119057

Dear Councilmember Johnson,
The Urban Forestry Commission commends the intent of the Design Review Program
Improvements. A city should continually re-examine its procedures in order to efficiently meet its goals. Based on the Commission’s review, the proposed changes conflict with the goals of the City’s Urban Forest Stewardship Plan (UFSP), specifically to reach 30% canopy cover by 2037. In light of this, the Commission makes two recommendations to the proposed Design Review Program Improvements, which should also be applied to the current permit review procedures such as clearing and grading.

The first recommendation is to track tree and canopy removal per project. Specifically, the Commission recommends tracking significant tree removals, exceptional tree removals, and removed canopy coverage, in square feet, as part of a complete application. Without this data, the City cannot accurately quantify tree and canopy removal and implement appropriate tree planting efforts. See the Commission’s previous letter of recommendation dated June 25, 2014 

The second recommendation is to provide a fee-in-lieu option for projects unable to replace trees equal to the number of trees and amount of canopy removed by a project. There is a lost public benefit associated with the removal of public and private trees which impacts human psychology, ecosystem services, public health, and neighborhood character. A tree removal fee-in-lieu option should be similar to the alternative compliance option for stormwater mitigation yet deposited in an Urban Forestry Account to fund planting and maintaining for long-term, healthy trees in Seattle.

These recommendations are intended to aid the UFSP’s monitoring goals and provide an offsite approach to mitigate tree canopy cover loss due to development. Thank you for the
opportunity to provide comments on the proposed Design Review Program Improvements
described in CB119057.

Sincerely,
Tom Early, Chair

Concerns about CB 119057 modifying Seattle design review process

Concerns about CB 119057 modifying design review process

Testimony before Seattle City Council Planning, Land Use and Zoning Committee

Sept 11. 2017

Steve Zemke – Chair – Friends of Seattle’s Urban Forest and TreePAC

CB 119057 was submitted to the Seattle City Council Planning, Land Use and Zoning Committee on August 15 to significantly modifying the Design Review process. The purpose is to shorten and reduce much of the design review process for large projects and make administrative and hybrid decisions decisions instead to speed up developers building more projects to meet housing needs. Exceptional trees would then in some decisions be an administrative or hybrid decision by DCI instead of public review.

Right now we are getting no significant return on trees lost and what you are proposing will accelerate the loss. Below are two recommendations critical to this bill.  If you add this in this ordinance it will be a big leg up on also revising a private tree ordinance to help protect and enhance our urban tree canopy. You have to act now.  If you do not developers will continue to remove Seattle’s tree canopy and Seattle and its citizens will loss while developers pay nothing for the removal.

– The need to track tree loss by requiring an Urban Forest Canopy Impact Assessment for all development as recommended by the Seattle Urban Forestry Commission. https://www.seattle.gov/Documents/Departments/UrbanForestryCommission/FinalIssuedDocuments/Recommendations/ADOPTEDDPDReportingLetter062514.pdf

– Mandate replacement on or off site of all tree canopy lost or payment into a City Tree Replacement and Maintenance Fund with tree value based on a professional appraisal as approved by the Council of Professional and Landscape Appraisers.

Starting on page 36 of the proposed ordinance the full design review removes all the current design review criteria and says “the Director may establish by rule, the information that the applicant shall present” Then removed on the next page are an initial site analysis, a drawing of existing site conditions that included all tree over 6 inches and species and a number of other conditions. The existing requirements should be retained and expanded to include the canopy impact assessment,

On page 43 the Administrative design review process also eliminates all the existing site evaluation requirements. They should remain.  Then add that “the administrator can add additional requirements.”

The problem remains that DCI’s mandate is to help builders build. Exceptional and other trees will continue to be lost as they are given minimal value in this process. If trees limit the full development potential of the lot they can be removed. The city suffers canopy loss but there is no requirement that the developers compensate the city for the loss of existing canopy.

You need to include a provision that if trees cannot be saved developers need to pay into a Tree Replacement and Maintenance Fund to compensate the city for the ecological and environmental benefits currently provided by a healthy urban forest. If developers are not required to compensate the city, it will be impossible to require compensation from homeowners or anyone else in the future for loss of exceptional trees.

Other cities have established tree funds.  Here are two examples.

Here for example is language from Portland Oregon’s Tree Ordinance for a Tree Planting and Preservation Fund.   https://www.portlandoregon.gov/citycode/?c=66002

11.10.070 Fees. A. Generally. The City Council may establish and amend by ordinance permit, inspection, review, enforcement, in-lieu of planting or preservation, appeal and other fees as necessary to sustain the development permit, tree permit, and other Development Service or Urban Forestry programs. All fees, charges, civil penalties, and fines established by authority of this Title will be listed in the Portland Policy Documents. B. Fees in lieu of planting or preserving trees. Where allowed by other provisions of this Title, a fee may be paid into the Tree Planting and Preservation Fund in lieu of planting or preserving trees. The fee per tree is the entire cost of establishing a new tree in accordance with standards described by the City Forester. The cost includes materials and labor necessary to plant the tree, and to maintain it for 2 years. The fee will be reviewed annually and, if necessary, adjusted to reflect current costs. See Section 11.15.010 for more information on the Tree Planting and Preservation Fund.

“11.15.010 Tree Planting and Preservation Fund. A. Purpose. The purpose of the Tree Planting and Preservation Fund is to facilitate tree planting, to ensure mitigation or tree replacement when tree preservation or tree density standards are not met on a particular site, and to advance the City’s goals for the urban forest and equitable distribution of tree-related benefits across the City. B. Expenditures. Money in the Tree Planting and Preservation Fund may be used only as follows: 1. To plant trees on public or private property, including streets, in the same watershed as the site from which the funds were collected. Planting trees includes the cost of materials and labor necessary to install and establish a tree for a 2 year period; 2. To purchase conservation easements for the perpetual retention of trees and tree canopy. Such conservation easements shall allow the City to replace trees that are removed when they die or become dangerous; and 3. To acquire land to permanently protect existing trees or groves. ”

Woodinville is a local city that has established a Tree Fund. http://www.ci.woodinville.wa.us/Documents/CityHall/Ordinances/Ordinance%20589.pdf

21.50.040 City Tree Fund established.

(1) Fund Established. A City Tree Fund is established for the collection of any funds used for the purpose and intent set forth by this chapter.

(2) Funding Sources. The following funding sources may be allocated to the City Tree Fund: payments received in lieu of supplemental plantings; civil penalties collected pursuant to this chapter; agreed-upon restoration payments or settlements in lieu of penalties; sale of trees or wood from City property; donations and grants for tree purposes; sale of seedlings by the City; and other monies allocated by City Council.

(3) Funding Purposes. The Tree Board shall provide recommendations with each budget to the City Council for approval of how the fund will be allocated. The City shall use money received pursuant to this section for the following purposes:

(a) Acquiring, maintaining, and preserving wooded areas within the City;

(b) Planting and maintaining trees within the City;

(c) Identification and maintenance of heritage trees;

(d) Establishment of a holding public tree nursery;

(e) Urban forestry education;

(f) Urban forest canopy coverage assessment; or

(g) Other purposes relating to tree and woodland protection and enhancement as determined by the City Council. (Ord. 611 § 8 (Att. A), 2016; Ord. 589 § 2, 2016)

There is more in  CB 119057 that is of concern but along with the Seattle 2035 Comprehensive Plan and HALA, DCI’s mission and policies are  intent on helping developers build faster and more intensely. For 8 years DCI and Seattle  Mayors and the Seattle City Council have ignored updating protection for private trees but has been very adept at finding ways to help developers. Trees should have standing in the city, not just developer’s “rights”. Seattle needs an independent city department or agency whose mission it is to save and protect trees and advocate for their role in the city structure and life.  Tree protection should be in a separate Department from DCI as DCI’s prime mission to help builders build things.  DCI has a severe conflict of interest and this legislation is one more example of reducing protection for trees. The most logical location would be in the Office of Sustainability and Environment which should be expanded to a full City Department.

 

Mandatory Housing Affordability Draft EIS Comments

MHA Draft EIS Comments by Friends of Seattle’s Urban Forest

August 7, 2017

From Steve Zemke – Chair Friends of Seattle’s Urban Forest

To:  Office of Planning and Community Development
Attn: MHA EIS
PO Box 34019
Seattle, WA 98124-4019

The Friends of Seattle’s Urban Forest appreciates the recognition and analysis that the MHA Draft EIS did in its study, emphasizing the significance and importance of our urban forest in keeping Seattle a livable city and recognizing the many positive ecological, environmental, aesthetic and health benefits a healthy urban forest provides. Seattle is striving to increase its urban forest canopy to 30% by 2037. The longer range goal in the 2035 Comprehensive Plan remains a 40% canopy goal.

It is important to note that the American Forestry Association, which came up with the original 40% recommendation recently stated “According to a national analysis by U.S. Forest Service researchers David Nowak (also on our Science Advisory Board) and Eric Greenfield, a 40-60 percent urban tree canopy is attainable under ideal conditions in forested states.” (AmericanForests.org)

Calculating Total Tree Canopy loss under Scenarios 1, 2 and 3 is necessary to understand impact of MHA additional canopy loss.

Friends of Seattle’s Urban Forest disagrees that the proposed development of additional housing under MHA is not significant. The impact is cumulative, added on top of the projected growth of housing under the 2035 Comprehensive Plan. The draft EIS by not stating the projected canopy loss under existing projections presents a very misleading and incomplete analysis of the changes occurring in this study area through 2025 when the additional affordable housing units will be added.

The baseline for the EIS should start with the current urban forest canopy in the study area as of 2016 when last studied so that the total projected change over time can be calculated under alternative 1 –No action.  Under alternative 1 some 43,631 new units are projected to be built and significant tree canopy will be lost.  The statement on page 3-284 is thus very misleading stating “The resulting change in canopy cover is assumed to be static.” The projected tree loss through 20125 under scenario 1 is nowhere quantified in the draft EIS.   The premise that “This study does not quantify tree loss resulting from current development patterns” is not acceptable because without understanding the total tree canopy change in the area through 2025 it is impossible to put in perspective the impact of the change that would result from the additional development proposed under HALA.

When you add in the additional housing units proposed under alternative 2 (17,709) and alternative 3 (17,479) they comprise about 28% of the total new growth in the area. To evaluate the addition of this growth to the area under study you have to add it to the projected growth already assumed under Scenario 1 through 2025.  If you have not assessed the impact of the growth quantitatively under Scenario 1, it is impossible to then state that this additional growth will have no significant impact.

Scenario 2      17,709/63,070 =28.1%

Scenario 3     17497/62,856 =27.8%

Rounding up to 28% and assuming the tree loss in alternative 1 is at the same rate (not necessarily true) as alternative 2 and 3 you get the following projected canopy acreage loss as

Loss current development under scenario 1 plus additional loss scenario 2:

Scenario 2 – total tree loss through 2025

28% x total tree loss = 5 acres canopy     total tree loss = 17.86 acres low estimate

28% x total tree loss = 11 acres canopy    total tree loss = 39.29 acres high estimate

Scenario 3 – total tree loss through 2025

28% x total tree loss = 8 acres canopy       total tree loss = 28.57 acres low estimate

28% x total tree loss = 16 acres canopy    total tree loss = 57.14 acres high estimate

By way of size comparisons, please note the following city parks and their acreage:

  • Seattle Japanese Garden – 3.5 acres
  • Myrtle Edwards Park – 4.8 acres
  • Freeway Park – 5.2 acres
  • Olympic Sculpture Park – 9 acres
  • Kubota Gardens- 20 acres
  • Northacres Park – 20.7 acres
  • Volunteer Park – 48.4 acres
  • Schmitz Park – 53.1 acres

It is in error for this EIS to not provide any information on the total tree loss in acreage through 2025 that is projected for Alternative 1, 2 and 3 due to the total development projected under each of the scenarios. Please provide the total projected tree loss in scenarios 1, 2 and 3 so that we can understand the total tree and canopy loss in each of the scenarios through 2025 relative to the additional tree loss projected in scenarios 2 and 3 that would be added.

No analysis made of potential acreage lost due to development that could be used for increasing tree canopy to meet city canopy goals.

The city is striving to increase its tree canopy. This means looking for places where no trees exist or where more trees could reasonably be planted. While the EIS evaluates existing canopy that would be lost, no analysis is made of the loss of potential canopy area for planting trees that if planted would help the city reach both its short term and aspirational goals. SDOT for example has looked at potential planting sites to help increase tree canopy. The reality is that as increased intensive development occurs the number of potential planting sites that could be used for planting trees is permanently lost as building density increases and covers more lot area.

What amount of potential planting area is lost due to this increased development under scenarios 1, 2, and 3?

Need to evaluate changes in growth projections and potential housing units over time based on low and high growth in recent history

The development projected under Alternative 1 should really be a range of projected low and high development in housing units.  It is impossible to project development impacts out 8 -10 years with precise accuracy as Seattle has found in other projections when growth has greatly exceeded expectations in recent years.

As the Urbanist noted recently, “The 2010 Census pegged Seattle at just 608,660, meaning we’ve grown by nearly 100,000 new people in just six years … Housing supply tends to lag behind housing demand; it could be in the coming years supply finally approaches demand. About 10,000 apartments are set to open in 2017, and more than 12,000 more are slotted for 2018. At the very least, with record-setting apartment growth expected, we have ample reason to expect the population growth trend to continue. Since King County averages 1.8 people per apartment, we could see growth in excess of 20,000 per year continue a bit longer if those expected apartments are filled.” (https://www.theurbanist.org/2017/02/27/seattle-700000)

What is the estimated range of housing units under scenarios 1, 2 and 3?

Mitigation Recommendation – To track tree and canopy loss require Urban Forest Canopy Impact Assessment on all development

The Seattle Urban Forestry Commission asked DPD in a letter dated June 25, 2014 and also in a letter dated June 10, 2015 to do an Urban Forest Canopy Impact Assessment on all development so that tree and canopy loss could be tracked. The Seattle Urban Forestry Commission also sent detailed comments on the draft EIS for the Seattle 2015 Comprehensive Plan urging this action. Our recommendation was not included in the final EIS proposed mitigation.   This recommendation should be included as mitigation assessment in this MHA EIS as a condition for proceeding so that canopy and ecological function lost can be more accurately followed and compensated for during development.

From the June 10, 2015 letter of the Seattle Urban Forestry Commission (https://www.seattle.gov/Documents/Departments/UrbanForestryCommission/FinalIssuedDocuments/Recommendations/ADOPTEDCompPlandraftEISLetter.pdf) :

“The Commission has discussed several ideas to improve submittal documentation and final reporting for projects under DPD’s permitting.

  • Currently, the City, through OSE and the Urban Forestry Interdepartmental Team, keeps track of the number of trees planted and removed on public property every year. The Commission recommends tracking trees lost on private property undergoing development to assist in determining where we are gaining or losing trees and canopy. This would add information to the overall city canopy coverage assessment data. By knowing more about canopy trends on different types of land, we can better direct policy and programming to ensure we are on track to meet our 30% goal.
  • What would help the City better understand what is happening with tree canopy protection and enhancement is to require that all development projects submit an Urban Forest Canopy Impact Assessment prior to any construction project being approved.

The Urban Forest Canopy Impact Assessment would include a map of the property with the trees numbered, canopy area of trees drawn, and trees to be removed clearly labeled. Under current guidelines it would minimally require that all trees 6 inches DBH (diameter at breast height) or larger be inventoried on the property. The suggested data points required would be:

  • Species: speaks to size of canopy and amount of storm water benefit.
  • DBH: speaks to age of tree and canopy coverage.
  • Tree Height: speaks to canopy volume and amount of environmental benefit.
  • Canopy Width (area): speaks to canopy volume and amount of environmental benefit.
  • Tree Condition: speaks to overall forest health and environmental impacts.
  • Photographs of the trees on the parcel and adjacent properties.
  • Canopy coverage as a percent of area pre- and post-project development.”

Please consider and discuss benefits of using Urban Forest Canopy Impact Assessments as part of development process.

Mitigation Recommendation – Update City Tree Ordinance to require replacement on or off site of tree canopy lost or payment into City Tree Replacement and Maintenance Fund

In terms of loss of ecological function due to canopy loss, mitigation options to be explored should include total compensation of both canopy loss and ecological function projected such that trees that are nor replaced on site should be mitigated by compensation into a City Tree Replacement and Maintenance Fund for replacing and maintaining trees elsewhere.  Development should pay for losses to the city’s green infrastructure that transfer development impact costs onto the general public while developers pocket the profits.

It is not acceptable that the costs of mitigating for tree and canopy loss should be picked up by all city taxpayers rather than the developers who are removing existing tree canopy the city is trying to maintain and increase. This EIS should recommend that Seattle update its existing tree ordinance to reverse the ongoing tree and canopy loss by the rapid development occurring in Seattle.

Please consider and discuss creation of a City Tree Replacement and Maintenance Fund for mitigation of projected tree canopy loss.

Reference Links needed

Please provide links to references where they are missing on documents that are not readily available to the public including:

  • City of Seattle. 2017a. Tree Regulations Research Project—Phase II Final Findings and Recommendations. March 27, 2017.
  • Seattle Parks and Recreation (SPR). 2011. Seattle’s Parks and Recreation 2011 Development Plan.
  • Adopted November 28, 2011. Resolution: 31336. Seattle Parks and Recreation (SPR). 2016. 2016 Seattle
  • Recreation Demand Study. Seattle Parks and Recreation (SPR). 2017. 2017 Parks and Open Space Plan, May Draft.

 

Submitted by Steve Zemke

Chair – Friends of Seattle’s Urban Forest

steve@Friends.UrbanForests.org

 

Seattle Urban Forestry Commission Raises Questions about Mandatory Housing Affordability Draft EIS

The Seattle Urban Forestry Commission has issued the following comments in response to the Mandatory Housing Affordability Draft EIS. Comments are due by August 7, 2017.

The letter below is the text of the letter dated August 2, 2017.

August 2, 2017.
Samuel Assefa
Director – Office of Planning and Community Development
600 4th Ave
Seattle, WA 98124

RE: MHA Draft EIS

Dear Sam:
As the City of Seattle drafts policy that seeks to increase urban density and affordable housing to accommodate more people and jobs, protecting and enhancing Seattle’s urban forest is needed more than ever to abate the biological, visual, and health impacts of this measure.
The Urban Forestry Commission commends the MHA Draft EIS for stressing the importance of tree coverage for Seattle, specifically citing the goals outlined in the 2013 Urban Forest Stewardship Plan (UFSP), as well as incorporating the most recently published 2016 canopy cover assessment results.
The Commission, however, disagrees with the MHA Draft EIS determination of no significant impacts to the city’s tree canopy and requests clarification regarding methodology and mitigation measures proposed in the MHA Draft EIS, specifically:

1. What is the projected tree loss in the No Action Alternative of the MHA Draft EIS?
2. Please explain in more detail the methodology used to estimate the projected tree loss in
Alternatives 1 (No Action), 2 and 3 of the MHA Draft EIS.
3. How would a mitigation measure be actionable or enforceable when the UFSP is a policy
document and not a required ordinance?
4. Why is a 0.5% loss of tree canopy considered not significant? The MHA Draft EIS does not cite any authority or precedent for that conclusion.

In addition, the Commission requests a response to the following additional comments regarding the MHA Draft EIS:

Underestimation of tree canopy impacts:

The MHA Draft EIS states that there will be less than a 0.5% decrease in the tree canopy for both Alternatives 2 and 3 compared to the No Action Alternative. The Commission questions the methodology used in the MHA Draft EIS for calculating this assessment for the following reasons:

1. The MHA Draft EIS states, “Tree cover for a given zone was assumed to remain constant over time if the zoning designation stayed the same.” [Page 374] The Commission recommends that the MHA Draft EIS should account for some increase in tree canopy loss in zones that stay the same. MHA will likely incentivize developers to maximize gross floor area (GFA) on a 2  redevelopment sites, and one way a developer can maximize GFA is to develop the site to its fullest development potential.

The MHA Draft EIS does not take into account the effect (i.e. enhancement or increase) of the development potential of a lot in MHA areas when calculating tree canopy loss. We request that the final MHA EIS include a calculation of tree canopy reduction using the full development potential of each lot within MHA areas even if the zoning is not changing.

2. The MHA Draft EIS calculates that 0.5% decrease in tree canopy would result in up to a 5 to 16- acre loss in tree canopy associated with Alternatives 2 and 3. While a 0.5% reduction in canopy seems like a low percentage of loss, in real terms it would generally equate to a loss of 173-555 trees (assuming a typical tree canopy has a radius of 20 feet (1,256 square feet)), which is a potentially significant number of trees. Citing tree canopy loss using an estimated number of trees that are lost would more accurately communicate the likely impacts of the MHA policy to the neighborhood tree canopy.

The MHA Draft EIS does not cite any authority for the assertion that a loss of 0.5% tree canopy (i.e., 173-555 trees) is not significant. The Commission believes a loss of this many trees is a significant impact under Alternatives 2 and 3 that should be mitigated, and that the MHA Draft EIS is unsupported as written.

Inadequate Mitigation Measures:
The MHA Draft EIS states no significant, unavoidable adverse impacts to the tree canopy have been identified, but does list some mitigation measures that would help to avoid and minimize tree canopy loss. The Commission thinks the current mitigation measures are inadequate, and need to be expanded and strengthened.

1. The MHA Draft EIS recommends the City evaluate future urban forestry policies as part of the 2018 UFSP update, but does not include mitigation measures within the context of existing policies such as updating Seattle tree protection code, Seattle Green Factor guidelines, or the Seattle Street Tree Manual. Mitigation measures for tree canopy loss should deal with changing or updating existing regulations and not just recommending evaluation of future policy, which is not enforceable.

Specifically, the Commission recommends requiring mitigation for tree loss to include
replacement of equivalent canopy on- or off-site or paying into a City tree replacement and
maintenance fund.

2. A healthy urban forest can have an outsized impact on reducing the negative effects associated with increased development intensity, as trees (especially street trees) help to mitigate the visual impacts of density and create a more human-scaled environment, as well as providing important ecosystem and public health benefits. While the MHA Draft EIS documents multiple negative aesthetic impacts associated with increased development intensity, the plan does not recommend any mitigation measures focused on increasing or improving the urban forest to mitigate aesthetic impacts of density.

The Commission recommends including stronger, more binding requirements to promote and improve tree coverage in urban village areas. These recommendations could include but are not limited to the following:

1. Expand incentives and development standards to promote street trees in Urban Villages;
2. Update the interim tree protection ordinance to account for the impact MHA will have on
development;
3. Reduce conflict between power lines and street trees;
4. Modify the Seattle Green Factor guidelines to give higher score to preserving healthy existing site vegetation;
5. Assess, monitor, and tally tree loss in the permitting process; and
6. Update the tree code to require retention, replacement, or payment into a City tree
replacement and maintenance fund for all removed trees, including hazardous trees, or trees which die as a result of development impacts or that are planted as project mitigation.

Thank you for your attention. The Commission looks forward to your response.

www.seattle.gov/UrbanForestryCommission

Seattle Tree Ordinance Update Priorities – 2017

In 2009, the Seattle City Council issued Resolution 31138 instructing “…the Department of Planning and Development to submit legislation by May 2010 to establish a comprehensive set of regulations and incentives to limit the removal of trees and promote the retention and addition of trees within the City of Seattle on both private and public property…”
It is now 8 years later and there is still no new ordinance. DPD presented 2 drafts that did not follow the suggestions of the Seattle City Council to strengthen tree and urban forest protection but instead sought to remove protections. The Seattle City Council needs to take decisive action to protect our urban forest.

Friends of Seattle’s Urban Forest – Seattle Tree Ordinance Priorities 2017

1. Permit System – Require permits to remove trees on both public and private property so we can keep better track of tree loss and gain. Require 2 week posting of tree removals as SDOT currently does.

2. Tree Replacement – A no net loss of trees requires that tree replacement be required for all significant and exceptional trees removed including during property development. This would be a canopy impact fee to compensate for the removal of existing canopy not replaced on site. The city tree canopy goal is 30% by 2037; the long term goal is 40%.

3. City Urban Forestry Account – Fees collected for tree replacement that cannot be done on site and fines for violating city tree ordinances would go into a city dedicated tree replacement fund that would pay for planting and maintaining trees elsewhere in the city. Donations and grants would be accepted to also plant more trees, acquire land, easements or set up land trusts to protect trees.

4. Urban Forestry Canopy Impact Assessment – Prior to development, a canopy impact assessment would be done on any proposed development to detail existing trees, their species and size so that equivalent replacement can occur. This would be on all trees over 6 inches dbh.

5. One City Department Overseeing Urban Forestry -To facilitate city wide coordination, oversight responsibility for our urban forest and trees should be consolidated in one city department that has a priority of protecting trees and not a conflict of interest.

6. Registration of Arborists with City – Arborists and other cutting trees down would be required for more accountability and compliance with a tree ordinance

7. Emphasis on Native Trees – Planting of more native tree species and less exotics would help preserve native vegetation and associated wildlife as well as provide more ecosystem services.

8. Special Protection – Because of their unique value extra protection should be given to tree groves, exceptional trees, critical areas and natural areas.

9. Incentives and Public Education – Proving incentives and educating the public should be part of the city effort to increase tree canopy coverage.

10. Stronger enforcement and Fines – To ensue enforcement of tree regulations and rules for those violating the law, the city needs to enact stronger penalties and fines.

Friends of Seattle’s Urban Forest, www.friends.urbanforests.org, Chair – Steve Zemke, stevezemke@msn.com

Seattle Needs to Require Developers to do Urban Forestry Canopy Impacts Assessments

The Seattle Urban Forestry Commission in 2014 recommended that its Department of Planning and Development require project developers to complete urban forestry canopy impact assessments. Seattle’s growth and property development and building is continuing at breakneck speed and impacting Seattle’s existing urban forestry infrastructure. Yet the city has done nothing to implement the Seattle Urban Forestry Commission’s recommendation. It should do so. Below is the text of the recommendation made on June 25, 2014.

June 25, 2014.
Mayor Ed Murray and Councilmember Sally Bagshaw
Seattle City Hall
600 4th Avenue
Seattle,WA 98124

Dear Mayor Murray and Councilmember Bagshaw,

As our city increases efforts to improve canopy coverage we have a gap in that even as we plant new trees, the number of trees removed from private land under development in the city is unknown. The Urban Forestry Commission would like to have better information on the number of trees removed from private land to obtain a metric which could be correlated to canopy cover assessments. This correlation would help articulate the need for a future tree code on private property. We would also be able to fulfill the monitoring called for in Seattle’s Urban Forestry Stewardship Plan and provide the City with data to judge how difficult a tree code on private property could be.

There are two specific requests we would like to make to comply with the monitoring efforts of the newly adopted Urban Forestry Stewardship Plan (UFSP).

1. Updated canopy assessment: Regular canopy coverage assessments are integral to the monitoring of the UFSP. The last canopy cover assessment was performed in 2009 with 2007 data. Please allocate funding for an updated canopy coverage assessment to the Office of Sustainability and the Environment per the short term action item (1-5 years) within the UFSP.

2. Quantify Tree Removals: Accurate tree planting and removal quantities are necessary for monitoring of the UFSP within the largest management unit in the city: single family residential areas. The table 8 (attached) is excerpted from page 73 of the UFSP. The last two columns show that we have a goal of raising the canopy cover substantially throughout the city. There currently is no data available to understand the impacts development has on canopy cover. In order to track our progress to reach our 2037 goal, we ask that DPD to:

a. Upgrade building permit applications within the single family zones to quantify tree removals; and
b. Report tree removals within the single family zones annually. Geographically located tally data would also be helpful for correlating development with tree canopy losses and gains.

Enclosed is a more detailed document explaining additional information that would be useful for the City to better manage the urban forest to accomplish the City’s goals.

Sincerely, Peg Staeheli, Chair Tom Early
Urban Forestry Commission Urban forestry Commissioner

cc: Council President Burgess, Councilmember Clark, Councilmember Godden, Councilmember Harrell, Councilmember Licata, Councilmember Rasmussen, Councilmember O’Brien, Councilmember Sawant,Jill Simmons, Diane Sugimura, Brennon Staley, Eric McConaghy

Urban Forest Canopy Impact Assessment

The Seattle Urban Forestry Commission is tasked with advising the Mayor and Seattle City Council on urban forestry issues. This includes implementing the Urban Forestry Stewardship Plan (UFSP) to achieve a 30% canopy goal by 2037. In addition, the current Seattle Comprehensive Plan states that the City needs to maintain no net loss of canopy as a baseline. As noted in our letter, the Commission considers two steps very important:

1. Perform a tree canopy assessment
2. Improve current submittal documentation for projects under development

The Commission has discussed several ideas to improve submittal documentation and final reporting for projects under DPD’s permitting.

• Currently, the City, through OSE and the Urban Forestry Interdepartmental Team, keeps track of the number of trees planted and removed on public property every year. The Commission recommends tracking trees lost on private property undergoing development to assist in determining where we are gaining or losing trees and canopy. This would add information to the overall city canopy coverage assessment data. By knowing more about canopy trends on different types of land, we can better direct policy and programming to ensure we are on track to meet our 30% goal.

• What would help the City better understand what is happening with tree canopy protection and enhancement is to require that all development projects submit an Urban Forest Canopy Impact Assessment prior to any construction project being approved. The Urban Forest Canopy Impact Assessment would include a map of the property with the trees numbered, canopy area of trees drawn, and trees to be removed clearly labeled. Under current guidelines it would minimally require that all trees 6 inches DBH (diameter at breast height) or larger be inventoried on the property. The suggested data points required would be :

  •  Species: speaks to size of canopy and amount of storm water benefit.
  •  DBH: speaks to age of tree and canopy coverage.
  •  Tree Height: speaks to canopy volume and amount of environmental benefit.
  •  Canopy Width (area): speaks to canopy volume and amount of environmental benefit.
  •  Tree Condition: speaks to overall forest health and environmental impacts.
  •  Photographs of the trees on the parcel and adjacent properties.
  •  Canopy coverage as a percent of area pre- and post-project development.

• Landscape Plan Requirements could include calculations for percent canopy coverage at 20 years and soils volume provided for each tree.

• The annual UFSP Progress Report to the Mayor and City Council could include canopy coverage for different development zones.

Implementing some or all of these operational steps would greatly help to evaluate whether or not we are doing enough to reach our 30% canopy goal by 2037. It would also allow some progress on clarifying tree requirements until DPD is able to put forward a new tree ordinance.

Comments on Natural Area and Greenbelt Supplemental Use Guidelines

The following comments were delivered by Steve Zemke, Chair of the Friends of Seattle’s Urban Forest to the Seattle Parks Board on June 25, 2015.

The Seattle Parks Department is proposing to open up long protected natural areas and greenbelts to more intensive recreational use.  It is a wrongheaded policy change. These areas need to be protected for what they are – an exceedingly scarce and valuable urban forest natural experience that is very rare in an urban setting. These areas under the Seattle Greenspaces policy adopted by the Seattle City Council in 1993 were to be mainly for “low intensity recreation, such as walking trails, nature study, informal play areas or pea patches”,  provide “wildlife corridors”, “significant or unique habitat for terrestrial or aquatic wildlife” and includes “streams, watercourses or wetlands”.

The language of the 1993 Greenspaces Policy adopted by the City Council says

“The purpose of greenspaces designation is to establish priority areas for preservation to

1. Help preserve natural landscape and habitat for wildlife,

2. Provide natural buffers between land uses of different intensity or areas of distinct character or identity

3. Help mitigate the effects of noise and air pollution

4. Help reduce the necessity for constructed storm water systems

5. Help preserve the quality of natural drainage systems and enhance the stability of the land.

Greenspaces, with their natural environmental character, will only be used for low impact activities and will complement the city’s Parks and recreation system where open space may be used in a more active manner”

Now the Seattle Parks Department is proposing to change the use of these natural areas to active recreation.

Rather than looking at where is the most appropriate area and need for bicycling and other new uses not presented during the initial creation of this proposal during the mini-summit and focus groups and public comment, we are now presented with a proposal that says the Parks Superintendent can decide a multitude of uses including mountain bike trails, bicycle skills areas, rope courses, orienteering, challenge areas and quote “future activities that may evolve.” Maybe this is zip lines. Maybe it is tree climbing, – the language leaves it wide open and is contrary to most of the comments that have evolved so far and contrary to the spirit of the 1993 Greenspaces policy.

The Seattle Parks Department has the authority now to restore these areas and build walking trails as it has done in areas like Thornton Creek and the South Cheasty area.  I do not believe it has the authority by internal fiat to change the purpose for which Greenspaces were created and believe such a major policy change should be done only by the city council after a public review process that looks at park use in its totality not just the conversion of natural areas and greenspaces to active use.

I don’t believe the Parks Department has been open with the public about its intentions and cannot be trusted to protect these areas as designated by the Seattle City Council and the understanding the public has had for many years about how these areas were to be protected for future generations.  These proposed supplemental uses guidelines need to be shelved and Parks go back to the adopted city policy to preserve these areas for low intensity recreation uses.

end of public statement

Additional Information:

Additional comments made by other groups and individuals can be found on the Seattle Nature Alliance website post entitled  One Voice.

The Seattle Nature Alliance has also posted a petition that people can sign on line opposing the conversion of existing natural areas and greenspaces uses from preservation and passive recreation to one of more intense recreation like mountain bike trails and rope courses.

Click here to sign the petition- Preserve Seattle Parks Natural Areas and Greenspaces

Public comments on the Proposed Seattle Parks Natural Areas and Greenbelts Supplemental Use Guidelines will be accepted until July 16, 2015. The actual proposed guidelines can be seen here:

Natural Area and Greenbelt Supplemental Use Guidelines

Additional information and references can be found here:

Natural Area/Greenbelt Supplemental Use Guidelines Information

Comments to the Park Board should be sent to by July 16 to;

Board of Park Commissioners
100 Dexter Ave. N.
Seattle, Washington 98109

For Park Board Business, please contact Rachel Acosta:

Phone: 206-684-5066
Email: rachel.acosta@seattle.gov

A copy of any comments should also be sent to:

Susanne Rockwell
Strategic Advisor,
Office of the Superintendent
206-733-9702
susanne.rockwell@seattle.gov

Comments Submitted on draft EIS 2035 Seattle Comprehensive Plan

The Friends of Seattle’s Urban Forest wants to express its support for the comments submitted by the Seattle Urban Forestry Commission. They can be seen here: Seattle Urban Forestry Commission Comments of Draft EIS 2035 Seattle Comprehensive Plan

We agree that removing the aspirational long term goal from the Comprehensive Plan of 40% canopy cover is wrong. A 30% goal by 2037 is a step toward that 40%. The Seattle City Council voted twice to support a 40% long term goal in the Comprehensive Plan and no reason is given for removing it and no analysis is given as to the impact on Seattle’s urban forestry canopy or the cost to the city in terms of green infrastructure services in the future if it is removed. What is the long term impact and infrastructure cost of reducing the urban forest canopy goal from 40% to 30%.

It is erroneous to state that SMC 25.11 and the Urban Forestry Stewardship Plan are adequate to ensure that a 30% canopy goal can be reached by  2037. No analysis has been done as to the loss of canopy and trees in the urban forest caused by adding 70,000 housing units and 120,000 new residents and 115,000 new jobs. Canopy is lost during development but the Department of Planning and Development unlike other city departments is not doing a tree inventory and canopy loss assessment during development. The Seattle Urban Forestry Commission has asked DPD to perform and tabulate an Urban Forest Canopy Impact Assessment on all development. Without accurately knowing what is being lost and what is being replaced it is impossible to do an accurate assessment whether we are gaining or losing canopy.  What would be the cost of DPD doing a canopy impact assessment on development projects as recommended by the Seattle Urban Forestry Commission?

Seattle’s current tree ordinance SMC 25.11 does not require permits to remove trees, require replacement for most trees removed, require notice to remove trees and allows 3 trees to be removed every year on private property. It says exceptional trees can not be cut down unless a hazard tree but only operates on a complaint basis  which is not working. Other municipalities have much stronger tree protection ordinances. Exceptional trees are removed without any tracking occurring. The system is not working.

There is no analysis of the impact that increased growth will place on Seattle’s urban forest and to say that the current system will handle increased tree loss from growth impacts has no basis to back it up.

Seattle is not now on track to meet it’s 30% canopy goal and increased development makes it even less likely. As noted in an analysis the Friends of Seattle’s Urban Forest made last year Can Seattle Reach 30% Tree Canopy Goal by 2037?  based on data for tree replacement done by Portland , Oregon we are not on track to reach 30%.
The analysis states that “12,414 new average medium size trees need to be planted in Seattle each year to reach a 30% canopy goal by 2037. This assumes each year there is also no net loss of canopy as the baseline and that 100% of the planted trees survived which is unrealistic.. These trees are in addition to replacing any lost during development or removed from private property or removed in the public sector like street trees or park trees.” Current tree planting are only about 2000 -3000 at most that are documented.

So the question for this EIS is how many trees and what amount of canopy will be lost during development of 70,000 housing units?

How many trees and what size will be replaced for the trees lost?

How much building will occur for the 115,000 jobs and how many trees and what amount of canopy will be lost?

What amount of canopy and trees will be replaced?

What will be the cost for replacing canopy lost to development?

Who will pay for replacing the lost canopy and trees?

The Plan calls for adding 1400 acres of open space to the city.  Where will this open space come from, what will it cost and who will pay for it?

Overall again and again the plan optimistically states that we can address all the increased growth. Yet just on roads everyone know it takes a lot longer to get around the city than just a few years ago based on the recent growth we’ve had.

As long as current residents have to continue pick up the costs for increased growth through higher taxes on property Seattle becomes a much less livable city and forces out lower income people who can’t afford higher housing costs. There is a need to implement developer impact fees to pay for low income housing, road repair, public transit, schools and other impacts on basic city infrastructure.
What are the projected costs of providing increased city services over the next 20 years and how much more can residents expect to pay in increased costs  if developers are not required to pick up the increased costs due to growth?
How much can we expect property taxes and utility bills to increase to pay for these added infrastructure service needs due to the projected growth if developers to not pick up the costs for growth so that growth pays for growth?
What will be the projected median price for a home in 20 years and what impact will the increased growth have on that cost?
How much can we expect rents to increase over the next 20 years with the projected growth over what they would be without the projected growth?

The draft EIS needs to do a better job of projecting the costs associated with growth.  Right now it just seems to say over and over that there is no problem and that we will do just fine. That is not acceptable and doesn’t provide a realistic assessment to Seattle residents of the potential cost of the projected growth.

Steve Zemke
Friends of Seattle’s Urban Forests

Draft EIS for Seattle 2035 Comprehensive Plan Gives Urban Forest Short Shift

 

Seattle is currently undergoing an update of its Comprehensive Plan. The update to deal with growth projections over the next 20 years is required under the State’s Growth Management Act. The projections are that Seattle will see a significant increase of 120,000 new residents, 115,000 additional jobs and 70,000 new housing units. A draft EIS has been prepared for public comment with a closing date of June 18th.

It was the determination of Seattle’s Urban Forestry Commission that the draft EIS did not adequately address the impacts of the projected growth on Seattle’s urban forest and its goal in the near term to reach 30% canopy cover by 2037.

The draft EIS for the 4 alternative growth scenarios by 2035 can be seen by clicking on the following link:

draft EIS Seattle 2035 Comprehensive Plan

You can also go to DPD’s 2035 Seattle webpage for more information

Comments on the draft EIS should be sent by email to: 2035@Seattle.gov by June 18, 2015.

You can also go online and submit comments on DPD’s feedback page

The Seattle Urban Forestry Commission has reviewed the draft EIS and submitted comments. The full text of their letter can be seen here:

SUFC –Comments on the Draft EIS for the Seattle 2035 Comprehensive Plan

The summary is printed below, followed by the full text of the letter:

In summary, the Commission believes that the draft EIS does not address a number of impacts that could be caused by the different growth scenarios as a result of tree canopy loss from increased development. Much more analysis is given to view impacts and noise impacts while ignoring potential significant impacts caused by increased tree canopy loss.

SMC 25.11 is seriously outdated and needs updating like many other cities including Portland, Oregon; Lake Forest Park, WA; Atlanta, GA; and Vancouver, BC have done to protect and increase their green urban forestry infrastructure. So called protection of exceptional trees under SMC 25.11 is based on a complaint system and is unfortunately not protecting exceptional trees.

The Urban Forest Stewardship Plan cannot address reaching a 30% canopy goal without adequate information as to the amount of canopy that is being lost during development. The Commission recommended DPD to implement an Urban Forestry Canopy Impact Assessment for all their projects and so far has not responded to the Commission’s letter of recommendation or indicated any intention to do so.

And eliminating by oblique reference the long-term, aspirational canopy goal of 40% as adopted by the Seattle City Council in the current Comprehensive Plan without any discussion of its impact on Seattle’s future urban forest is unacceptable. The long term 40% canopy goal should remain in the plan and reference that the 30% goal by 2037 is a stepping stone to the larger goal and not the final goal.

Full text of the letter:

June 10, 2015.

Gordon Clowers

Department of Planning and Development

700 5th Avenue, Suite 2000

Seattle, WA 98124

RE: Comments on the Draft EIS for the Seattle 2035 Comprehensive Plan

Dear Mr. Clowers,

The Seattle Urban Forestry Commission wishes to address the following concerns about the draft Environmental Impact Statement (EIS) for the Seattle 2035 Comprehensive Plan.

1. Impacts on the Urban Forest due to Increased Density

The draft EIS does not evaluate the impacts on Seattle’s urban forest by adding 120,000 new residents, 115,000 new jobs, and 70,000 housing units to Seattle by 2035. Only one page’s worth of print out of the approximately 400 pages is devoted to potential impacts on the urban forest and it basically says that there is no problem because we have the Urban Forest Stewardship Plan and provisions in SMC 25.11. It is the Commission’s view that this is not accurate. The draft EIS provides no direct or detailed evaluation of the yearly or cumulative loss of urban forest canopy due to development and growth and the associated impacts on air pollution and human health, noise, storm water runoff, wildlife habitat, open space, or heat island effects.

The draft EIS on p 3.5-11 states: The Urban Forest Stewardship Plan’s goal’s and the implementing regulations in SMC 25.11 would apply to development that occurs under all EIS alternatives and would help to mitigate for the potential removal of all trees and reduction of canopy cover with future development. In this respect, the growth patterns examined under all alternatives would be able to be implemented while remaining consistent with the UFSP’s goals.”

Unfortunately, there is no environmental analysis of the specific impacts or costs associated with canopy loss occurring during development. There is no analysis of how much canopy loss would occur and what the cost would be or who would pay for replacing canopy lost during development. The current City Comprehensive Plan calls for no net loss of canopy. If the City does not know how much canopy is being lost through development it cannot accurately assess whether it is meeting the no net loss goal let alone gaining canopy each year.

The Urban Forestry Commission addressed this issue on the need for more detailed data from DPD on tree loss in a letter adopted June 25, 2014. http://www.seattle.gov/Documents/Departments/UrbanForestryCommission/FinalIssuedDocuments/Recommendations/ADOPTEDDPDReportingLetter062514.pdf

The letter stated in part:

“The Commission has discussed several ideas to improve submittal documentation and final reporting for projects under DPD’s permitting.

Currently, the City, through OSE and the Urban Forestry Interdepartmental Team, keeps track of the number of trees planted and removed on public property every year. The Commission recommends tracking trees lost on private property undergoing development to assist in determining where we are gaining or losing trees and canopy. This would add information to the overall city canopy coverage assessment data. By knowing more about canopy trends on different types of land, we can better direct policy and programming to ensure we are on track to meet our 30% goal.

What would help the City better understand what is happening with tree canopy protection and enhancement is to require that all development projects submit an Urban Forest Canopy Impact Assessment prior to any construction project being approved. The Urban Forest Canopy Impact Assessment would include a map of the property with the trees numbered, canopy area of trees drawn, and trees to be removed clearly labeled. Under current guidelines it would minimally require that all trees 6 inches DBH (diameter at breast height) or larger be inventoried on the property. The suggested data points required would be:

Species: speaks to size of canopy and amount of storm water benefit.
DBH: speaks to age of tree and canopy coverage.
Tree Height: speaks to canopy volume and amount of environmental benefit.
Canopy Width (area): speaks to canopy volume and amount of environmental benefit.
Tree Condition: speaks to overall forest health and environmental impacts.
Photographs of the trees on the parcel and adjacent properties.
Canopy coverage as a percent of area pre- and post-project development.

  •  Landscape Plan Requirements could include calculations for percent canopy coverage at 20 years and soils volume provided for each tree.
  •  The annual UFSP Progress Report to the Mayor and City Council could include canopy coverage for different development zones.

Implementing some or all of these operational steps would greatly help to evaluate whether or not we are doing enough to reach our 30% canopy goal.”

Inadequate Tree Protection in Current Code

A second issue is that the Commission believes that the current tree protection ordinance in SMC 25.11 is inadequate to meet the goals of achieving a 30% canopy by 2037. It has so stated in several letters to the Seattle City Council and Mayor, including the letter dated July 15, 2014. http://www.seattle.gov/Documents/Departments/UrbanForestryCommission/FinalIssuedDocuments/Recommendations/ADOPTEDDPDOrdinancetoCMBagshaw071514final.pdf

In that letter the Commission stated:

In 2009, City Council issued Resolution 31138 instructing “…the Department of Planning and Development to submit legislation by May 2010 to establish a comprehensive set of regulations and incentives to limit the removal of trees and promote the retention and addition of trees within the City of Seattle on both private and public property…” >

We would like to reiterate the statement made in our August 2010 recommendation: Bold action, consistent with Resolution 31138, is needed to achieve Seattle’s tree canopy coverage goal of 30% by 2037. And because the majority of trees in Seattle are in residential property, an updated tree ordinance is key to implement the 2013 Urban Forest Stewardship Plan as adopted by City Council last September.

DPD released a first proposal in 2010 and a second proposal in 2012. It is now almost five years since the Resolution and DPD is still working on a tree ordinance for trees on private property. There was a significant amount of time and energy invested by the community in this process. This length of time tends to frustrate the public as they look for guidance on tree measures.

We urge you use your leadership in Council’s Seattle Public Utilities and Neighborhoods Committee to:

1. Encourage DPD to resume work on this important element of a comprehensive urban forestry strategy for Seattle with a more defined timeline than the one currently shown on their website.

2. To develop an improved public education and outreach approach that engages Seattle’s diverse stakeholder communities.

3. Require a reporting of how the new proposal addresses the DPD specific elements of the Resolution: a. The 15 elements of Section 1;

4. b. The four elements of Section 2; and

5. c. The section for requirements for institutions, City facilities, public facilities, and schools.”

It is now another year later and there has been no further action on passing an updated tree ordinance.

3. Removal of the Current 40% Canopy Cover Long-Term, Aspirational Goal

The third issue the Commission is concerned with is that the Draft EIS said that the Seattle 2035 Comprehensive Plan would eliminate the City’s long-term goal of a 40% tree canopy in the current comprehensive plan and replace it with the Urban Forest Stewardship Plan goal of 30% by 2037.
That seems to be the intent of the language on p 3.5-1 that says “Adjusting the quantitative tree canopy goal in the Environment Element to be consistent with the 2013 Urban Forest Stewardship Plan.” That would reduce the current overall long-term goal of 40% in the Comprehensive Plan by 25%. There is no discussion of the impact of that change both in the short-term or long-term and the ability to pursue a 40% aspirational goal after 2035. A long-term goal of 40% canopy cover and a 2035 goal of 30% canopy by 2037 is a step toward that larger goal.

The Commission addressed the issue of the long-term canopy goal of 40% in its comments on the current Comprehensive Plan in a letter dated May 11, 2011.

http://www.seattle.gov/Documents/Departments/UrbanForestryCommission/FinalIssuedDocuments/Recommendations/AdoptedCompPlanUpdateRecommendation051111.pdf

The language proposed by the Commission was adopted by the Seattle City Council and is in the current Comprehensive Plan under ENVIRONMENT ELEMENT H Seattle’s trees E23:

“Achieve no net loss of tree canopy coverage, and strive to increase tree canopy coverage to 40 percent, to reduce storm runoff, absorb air pollutants, reduce noise, stabilize soil, provide habitat, and mitigate the heat island effect of developed areas.”

Additional comments

  • The 2013 Urban Forestry Stewardship Plan is not listed in the references. http://clerk.seattle.gov/public/meetingrecords/2013/plus20130911_18d.pdf
  • The benefits of trees mentioned on p 3.5-11 under the heading Urban Forestry Stewardship Plan fails to mention a number accepted benefits of trees including documented health benefits of a healthy urban forest; reducing storm water runoff; impacts on wildlife habitat; and impacts on birds, insects, other animals and associated plants.

In summary, the Commission believes that the draft EIS does not address a number of impacts that could be caused by the different growth scenarios as a result of tree canopy loss from increased development. Much more analysis is given to view impacts and noise impacts while ignoring potential significant impacts caused by increased tree canopy loss.

SMC 25.11 is seriously outdated and needs updating like many other cities including Portland, Oregon; Lake Forest Park, WA; Atlanta, GA; and Vancouver, BC have done to protect and increase their green urban forestry infrastructure. So called protection of exceptional trees under SMC 25.11 is based on a complaint system and is unfortunately not protecting exceptional trees.

The Urban Forest Stewardship Plan cannot address reaching a 30% canopy goal without adequate information as to the amount of canopy that is being lost during development. The Commission recommended DPD to implement an Urban Forestry Canopy Impact Assessment for all their projects and so far has not responded to the Commission’s letter of recommendation or indicated any intention to do so.

And eliminating by oblique reference the long-term, aspirational canopy goal of 40% as adopted by the Seattle City Council in the current Comprehensive Plan without any discussion of its impact on Seattle’s future urban forest is unacceptable. The long term 40% canopy goal should remain in the plan and reference that the 30% goal by 2037 is a stepping stone to the larger goal and not the final goal.

Thank you, for the opportunity to comment.

Sincerely,
Leif Fixen, Chair
Steve Zemke