Amendments Needed on Zoning Legislation in NR Zone in Seattle

Posted on by June 24, 2025

           Friends of Seattle’s Urban Forest

Amendments are Needed to Increase Tree Retention and Planting as We Build Needed New Housing in our Neighborhood Residential Zone 

The Seattle City Council is working to adopt its CB 120985 – Comprehensive Plan and Council Bill 120993 to implement WA State HB 1110 allowing 4 to 6 plexes in Seattle’s Neighborhood Residential zones. Council Bill 120993 needs amendments to protect and plant more trees where people live if Seattle wants to reach its 30% canopy goal, address urban heat island impacts, reduce air pollution and stormwater runoff, and keep our neighborhoods healthy where people live.

Please use the suggested comments below to send an e-mail to the Seattle City Council and Mayor Harrell. You can cut and paste the comments below, pick and choose from the comments, and add your own thoughts.

The Seattle City Council has set a deadline for Council members to submit proposed amendments this Thursday, June 26, 2025.

Here are the amendments we are asking Councilmembers to support:

  • Remove the “basic tree protection area” loophole in SMC 25.11.070 that lets developers remove large (Tier 2) trees. Use the tree protection area criteria in SMC 25.11.060 to give SDCI final authority on tree removals, not developers.
  • Give SDCI authority to decide on removal of Tier 3 and Tier 4 trees, not the developers as is currently done. Urban forests need to have trees of all ages to be sustainable and healthy.
  • Require lots have designated tree retention and planting areas.
  • Require a tree inventory and landscape plan be done at the beginning of the development process before approval of any building site plan is submitted.
  • The point system for planting trees on a lot allows all trees to be removed and replaced with saplings. Require that plans maximize the retention of existing healthy trees.
  • Require all trees removed over 6” DSH pay an in lieu mitigation fee for environmental services lost to the city, as well as replanting the removed trees either on site or pay for off site planting to sustain our urban forest benefits to the city and its inhabitants.
  • Set up a Tree Replacement and Preservation Fund independent from SDCI’s budget to collect in lieu mitigation fees and for public donations and grants to help maintain and plant more trees .
  • Require all new development projects, not just principal housing units, to have street trees. This includes ADU’s and building additions over 250 square feet.
  • Allow stacked flats to be built on all lots in the neighborhood residential zone, not just those over 6,000 square feet.  Stacked flats would allow more open space to retain and plant trees.
  • Give incentives to build housing units with common shared walls to increase open space on lots for retaining and planting trees for environmental equity, climate resilience, reducing air pollution and storm water runoff.
  • Consolidate urban forest oversight and maintenance in a Dept. of Climate and Environment with an Urban Forestry Division independent from SDCI and other city Departments. Our urban forest needs its own advocates
  • Amend canopy cover assessment in next Tree Canopy Study to include not just canopy area but also canopy volume.Neither the proposed Comprehensive Plan or CB 120993 give adequate oversight or protection for maintaining a thriving healthy urban forest over the long term. The current Tree Protection Ordinance was adopted prior to the current proposed Comprehensive Plan, WA state HB 1110  and new zoning proposed in CB120993. SMC 25.11 – the Tree Protection Ordinance needs to be reviewed and amended to address the increased loss of trees and urban forest ecosystem services under the current changes proposed.

 Send comments to Council@Seattle.gov and Bruce.Harrell@Seattle.gov

Thank you for submitting comments!

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Comments needed to Seattle City Council on CB120969 for saving setbacks and more

Posted on by May 22, 2025

  Comments to increase tree retention and planting during development Needed Now
to Seattle City Council Bill 120969

The Seattle City Council is adopting legislation on Wednesday this coming week to implement WA State HB 1110 which requires the city to allow developers to build 4 and 6 plexes in Seattle’s Neighborhood Residential Districts. We support the need to increase more housing supply in urban areas. We do not support clearcutting building lots to do this.  

One major concern is that  Seattle City Council Bill 120969 will significantly change the building code to reduce setbacks on lots without evaluating how this will impact the city’s ability to retain existing trees or set aside space to plant trees to meet tree code requirements. They say they can evaluate this later but also say they are not intending to update the The Tree Protection Ordinance, SMC 25.11., even though there are provisions needing updating. Other concerns are listed below.

A public hearing is scheduled on Council Bill 120969 on Monday May 19th with call in comments starting at 9:30 AM and in person comments at 4:00 PM. People will be given 1 minute to speak.  Find Mon May 19 Agenda and registration link here.    .

The Seattle City Council Select Committee on the Comprehensive Plan will consider amendments and vote on the CB 120969 on Wednesday May 21st. There will be no public comments on Wednesday but you can still e-mail comments, the sooner the better. The current amendments being considered can be seen on the agenda link here Please send an email with your comments on CB 120969 and/or sign up to speak if you can. Thanks for taking the time to comment!  Submit comments via e-mails to  Council@Seattle.gov and Bruce.Harrell@Seattle.gov.

Suggested Comments – feel free to copy these and add your own comments or write your own statement:

1. Please amend CB 120969 to keep the current setbacks of 20 feet in the front and 25 feet in the rear instead of 10 feet in the front and 10 feet in the back or zero feet if an alleyway. These reductions will not allow sufficient place to retain or plant most larger trees.

2. Amend the Seattle Tree Protection Ordinance section SMC 25.11.070 to remove the provision that the basic tree protection area cannot be modified during development. The International Society of Arboriculture and SMC 25.11.130 say it can be modified. 

3. Allow the Seattle Department of Construction and Inspections (SDCI) to ask for alternative site designs to save existing healthy trees where possible and create designated tree planting areas.

4. Remove the increased ability in CB 120969 for SDCI to allow building in critical areas, particularly steep slopes. 

5. Amend the replacement in lieu fee provision in SMC 25.11 to be like Portland Oregon has – an in lieu mitigation fee to compensate for tree services lost to the city with tree removal, like storm water runoff reduction, air pollution removal and heat island impact reduction.

6. Require street trees to be planted for all building construction, including ADU’s.

7. Require all building done under CB 120969 to comply with tree replacement and in lieu fees required under SMC 25.11.110

8. Set up the One Seattle Tree Fund proposed in Mayor Harrell’s Executive Order 2023-3, the One Seattle Tree Plan.                                 Thank you for submitting comments!

Steve Zemke – Chair Friends of Seattle’s Urban Forest
stevezemke@Friends.UrbanForests.org 
 
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Middle Housing options – more open space for trees with lot splitting on common walls

Posted on by January 6, 2025

What Seattle could do – Middle Housing using Land Division like Oregon allows to have less scattering of housing units, more space for trees

Posted on  by Steve Zemke

One Seattle Comprehensive Plan needs to include Middle Housing Land Division on shared common walls like Oregon does.  It would mean less scattering  of housing units on lots being developed, allowing more space for retaining and planting trees and nature in Seattle. We need our trees and urban forests for healthy neighborhoods  where we live.

Here seems to be an option for housing construction alternatives that current city documents have not considered that Oregon allows. Oregon has allowed 4 housing units per city lot since 2020. The concept of “expedited lot splitting” with 4 attached units on a large lot being split into smaller lots based on the common walls seems like a way to free up more land on the site to retain and plant more trees. Also would reduce building costs and heating/cooling costs with a common wall between units.

References below on a couple of ways to open up more space for tree retention and planting.

Middle Housing Land Divisions | Portland.gov What is a Middle Housing Land Division (MHLD)? An MHLD is an expedited land division of a lot or parcel to develop middle housing. “Middle housing” is a housing type that includes duplexes, triplexes, quadplexes, cottage clusters, and townhouses. MHLD provides an opportunity to increase housing supply in developed neighborhoods and can blend in well with detached single-family dwellings.www.portland.gov

Oregon bill on middle housing land division:

ORS 92.031 – Middle housing land division – Oregon Laws 92.010 Definitions for ORS 92.010 to 92.192 92.012 Compliance with ORS 92.010 to 92.192 required 92.014 Approval of city or county required for specified divisions of land 92.016 Sale or negotiation to sell lot or parcel prior to approval of tentative plan 92.017 Lawfully created units of land 92.018 Buyer’s remedies for purchase of improperly created unit of land 92.025oregon.public.law

Middle housing land division – Oregon City, Oregon:

Middle Housing Land Division | Oregon City, OR Oregon City City Hall 625 Center Street Oregon City, OR 97045. Phone: 503-657-0891 Hours: Monday to Friday 8:00am to 5:00pmwww.orcity.org

Courtyard housing was previously presented as a Seattle option in draft Seattle documents but not in the examples of most recent plans. This could involve the joining of several larger lots and positioning housing units such that a common area could be shared as open space – one way to plant trees or preserve a space for a grove of trees and areas where neighbors  and kids can get together other than public streets.

See Oregon City article below – “Cluster housing formerly known as cottage housing, includes group(s) of 4 to 12 smaller dwellings clustered together around a common green space; more than one such group can be developed on the same site. The dwellings themselves can be individual detached structures-often called cottages; attached structures such as townhouses, duplexes, and 3- to 4-plexes. The dwellings are clustered together facing each other across a courtyard, rather than arranged in a traditional grid along public streets. Dwellings share common amenities such as green space, parking areas, and community buildings.” See picture in article below.

Cluster Housing | Oregon City, OR Oregon City City Hall 625 Center Street Oregon City, OR 97045. Phone: 503-657-0891 Hours: Monday to Friday 8:00am to 5:00pmwww.orcity.org

Comments needed to Seattle City Council and Mayor regarding draft One Seattle Comprehensive Plan

Posted on by January 6, 2025


Comments needed on the One Seattle Comprehensive Plan!

This Friday Dec 20, 2024 at midnight is the deadline to submit official comments on Mayor Harrell’s draft One Seattle Plan to up-zone neighborhood residential zones. This proposed legislation is going to the Seattle City Council, which can consider amendments and adopt as part of Seattle every 10-year update of its Comprehensive Plan. This update is required by the State’s Growth Management Act. (Comments can still be sent in after Friday to the City Council and Mayor. The City Council must adopt its Comprehensive Plan by June of 2025.)

The plan further weakens the already compromised tree protections and replacement provisions in the 2023 Tree Ordinance.

You can comment by sending an e-mail to oneseattleplan.zoning@seattle.gov or by using our email below

Our main issues and proposed fixes are summarized at the bottom of this email.

We have prepared a sample e-mail you can send to all the Council member, city officials, and the zoning comment mailbox with our tree-related concerns and suggested changes.

Please send an email today to urge the Seattle City Council to comment on the One Seattle Comprehensive Plan.

SEND COMMENTS!

We have a pre-written e-mail you can quickly sent them. Feel free to add your own comments.

Thank you for supporting our urban forests!

Summary of our One Seattle Comprehensive Plan issues and proposed changes
Modify definition of basic tree protection area from SMC 25.11 
Tree Protection Ordinance The 2023 Tree Ordinance included the Master Builders definition of the basic tree protection area, requiring a tree protection area that is so large and inflexible that it that it allows developers an excuse to just cut down the tree. This is contrary to the International Society of Arboriculture guidance to save trees by reducing tree protection areas, when possible, to save trees. SMC 25.11.060 outlines how the “tree protection area” can be modified according to ISA standards. But SMC 25.11.070 then voids SMC 25.11.060. This issue should have been resolved in the “Omnibus bill” but was ignored. Trees that could be saved are not being saved.

Replace trees removed with trees with roughly equivalent canopy at maturity or pay a mitigation in lieu fee 
In SMC 25.11.090 of the Tree Protection Ordinance, it says that in all zones, for all Tier 1, 2, and 3 trees removed during development, they “shall be replaced with one or more new trees, the size and species of which will be determined by the Director; the tree replacement required shall be designed to result, upon maturity in a canopy cover that is at least roughly proportional to the canopy cover prior to tree removal.” The rezoning proposal for tree planting in the NR zone that uses a point system does not at all comply with SMC 25.11 or discuss mitigation in lieu fees to plant trees elsewhere. The proposed amendment to use the “private property tree point requirements under subsection 23.44.024” does not deal with any equivalency in tree canopy loss or mitigation fee in lieu based on tree DSH as in SMC 25.11. The 30% tree canopy citywide goal is not attainable by significantly reducing tree protection and replacement in all zones.

Urge passage of a Parks and Recreation impact fee to help offset tree loss 
The proposal does not discuss the impacts of tree loss in the neighborhoods that could be offset with increased parks.  We need to do as many other Washington State cities already do and enact a Parks and Recreation Impact fee! Some 70 cities in Washington State charge impact fees.Prioritize buildings with connected units, rather than spreading out and building 4 or 6 separate buildings on lots. The comp plan draft de-emphasizes 4plexes, and instead promotes unconnected townhouse units and detached ADU’s, rather than saving space for trees by combining all housing units into one building. One building with 4 units would allow more space for trees and tree protection. 4plexes make more sense in a dense city, especially with smaller lots. Trees are essential for healthy neighborhoods.

Create tree planting and retention areas 
Seattle should promote specified tree retention and tree planting areas on lots like Portland, Oregon has done. Oregon has required 4plexes on lots since 2020 and Portland has been able to save more large trees with their option of setting aside 20% of the lot for tree planting retention areas in multifamily zones and 40% in residential areas. Let’s do the same in Seattle.

date 12/17/2024

Help Save Seattle’s Large Trees – Amend 2024 SDCI Omnibus Bill – Council bill 120823

Posted on by September 13, 2024

Comments needed on 2024 SDCI Omnibus Ordinance – Seattle City Council Bill 120823   8/29/2024

The SDCI 2024 “Omnibus bill” had a public hearing on Wed. Sept 4, 2024, at 2 PM in the Seattle City Council Land Use Committee.  It is now scheduled for a vote on Wed Sept 18th at 2 PM in the Land Use Committee. You can send comments to Council@Seattle.gov and Bruce.Harrell@Seattle.gov

There are several areas where conflicting statements exist in the omnibus bill that need to be corrected relating to SMC 25.11 Tree Protection Ordinance. 

  Remove all language stating that “the basic tree protection area cannot be modified”.

The most glaring error has to do with having 2 definitions of what a tree protection area is.

  • The SDCI 2024 omnibus bill needs to be corrected to remove all language or references that state “The basic tree protection area cannot be modified” including in Section 25.11.070.

The first definition in SMC 25.11.130 of the “tree protection area” is one used by the International Society of Arboriculture as well as the Northwest Society of Arboriculture. It is one that is flexible and designed to help save trees when possible. Its use and implementation are outlined in SMC 25.11.060 – Requirements for trees when development is proposed. 

In SMC 25.11.130 definitions, the “tree protection area” is defined as “means the area surrounding a tree defined by a specific distance, in which excavations and other construction-related activities must be avoided unless approved by the Director. The tree protection area is variable depending on species, age and health of the tree, soil conditions, and proposed construction.”

The Master Builders via their attorneys,  Helsell Fetterman, wrote in their “May 23rd, 2023 letter to the Seattle City Council” urging a second definition – “basic tree protection area” using the radius of the tree protection area as 1 inch diameter of the tree equaling 1 foot of the radius area.” In a separate comment they recommended that “The basic tree protection area cannot be modified” which was incorporated in SMC 25.11.070 – Tree Protection on sites undergoing development in Neighborhood Residential, Lowrise, Midrise, Commercial, and Seattle Mixed Zones.  

The full impact of that statement that “The basic tree protection area cannot be modified” is in contradiction to the Tree Protection Ordinance’s goal to protect as many trees as possible and SMC 25.11.060 which says the tree protection area can be reduced by the Director to save trees. The goal of the Master Builders was to allow developers to decide whether to remove Tier 2 trees rather than the city.

The problem is the language “The basic tree area cannot be modified.”  turns the decision over to the developers as to whether to save Tier 2 trees on developing sites. Modifying the tree protection area as outlined in detail in SMC 25.11.060 would save more Tier 2 trees.  Why is the city not acting in the public interest to save more large trees during development when it is possible by following the recommendations of how to create workable tree protection areas by the International and Pacific NW Society of Arboriculture rather than turning tree removal over to developers to decide?

SDCI actually agrees more trees could be saved when they state in in TIP 242A Seattle permits – Tree Requirements Associated with Development, dated July 8, 2024  that: 

“A Tier 2 tree may be removed if necessary for the construction of new structures, vehicle and pedestrian access, utilities, retaining walls, or other similar improvements associated with development. Tree removal under this scenario will not be authorized if there are viable alternatives to proposed development that would allow retention of the tree including adequate protection of the tree during construction according to SMC 25.11.060.”

In the same tip in their Dec 18, 2023 version they stated:

“The basic tree protection area, delineated using the “trunk diameter method” to determine if Tier 2 tree removal is allowed, is likely larger than necessary to protect most trees during development and is not required during construction.” 

 “The area of the outer half of the tree protection area may be reduced up to 35%”

 “Remember that the actual tree protection needed to protect the tree during development is always smaller than the basic tree protection area, leaving more room to fit your design on site.”

Remove 25.11.020 Exemption D in its entirety

  • 25.11.020 Exemptions: D. ((Trees located in an Environmentally Critical Area)) Tree removal as part of an Environmentally Critical Area tree and vegetation plan as provided in 25.09.070 except that tree service providers conducting work on these trees must comply with the tree service provider registry requirements of Section 25.11.100. 

This language “Trees located in Environmentally Critical Areas” was not in the previous ordinance (before the 2023 version) but is in the current version. It creates a whole new exemption to the ordinance. It emerged in one of the draft 2023 versions without public input and needs to be removed which is what the omnibus bill does. The whole Section D exemption should be removed. Why should removing and planting trees as part of a tree and vegetation plan be exempt from SMC 25.11?

Support following amendment in “SDCI Omnibus bill”:

  • 25.11.060A.4.b The tree protection area shall not be reduced more than 35% of the outer half of the tree protection radius unless an alternative tree protection area or construction method will provide equal or greater tree protection and result in long-term retention and viability of the tree as determined by a certified arborist.

Remove the following amendment in the “SDCI Omnibus bill”:

  • Footnote 1 in Table A for 25.11.050 In all other zones, all trees may be removed when development is proposed.

This is not a minor amendment but covers many other zones not mentioned in the Tree Protection Ordinance, including the Industrial Zone which has an exceptionally low tree canopy. There has been no analysis of the impact of this statement and the exclusion of trees in all other city zones from the requirements of the Tree Protection Ordinance. The fact that the other zones are not mentioned in SMC 25.11 means there is no requirement for tree replacement or in-lieu payments or requiring tree service providers removing trees in these zones being registered with the city.

The following statement in Table A for 25.11.050 Tier 2 trees during development – part of a permit needs to be amended to add SMC 25.11.060:

  • “Approval for removal is part of overall development permit consistent with Sections 25.11.060, 25.11.070, or 25.11.080”

Add “trees” to applications for lot boundary adjustments

  • SMC 23.28.020 – Application for approval of lot boundary adjustment
  1. A plot plan as appropriate showing the location and dimension of existing structures and trees in relation to the proposed lot boundary adjustment.

Steve Zemke – Chair Friends of Seattle’s Urban Forest

Remembering How Waldo Woods was saved in Seattle in 2010

Posted on by May 20, 2024

MLCC – Press Release – Waldo Woods Permanently Preserved

March 17, 2010

FOR IMMEDIATE RELEASE

** Waldo Woods Permanently Preserved **

(SEATTLE, WA) – The Maple Leaf Community Council Executive Board is pleased to announce the permanent preservation of Waldo Woods.

Ordinance 116794 was passed by the Seattle City Council Monday, March 8. Confirmation was received today that Seattle Mayor Michael McGinn has signed the legislation. This ordinance represents the last step in the process where the Seattle Parks Department takes possession of a conservation easement for Waldo Woods. The effect of the conservation easement is the permanent preservation of Waldo Woods, an urban grove of mature, native Douglas firs.

“When we started this process nearly four years ago,” stated Waldo Woods Working Group head David Miller, “we didn’t know whether we’d be successful or not. Through the support of hundreds of people from across Seattle, today we’ve managed to permanently save this unique grove of trees.”

The Maple Leaf Community Council applied for a King County Conservation Futures grant three years ago in the hopes of saving Waldo Woods, an intact and healthy 80 tree grove on the eastern 1/3 of the Waldo Hospital property at 15th Avenue NE and NE 85th Street in the north Seattle Maple Leaf neighborhood. The council succeeded in its pitch, and secured a $300,000 grant from King County to preserve Waldo Woods.

In March 2009, the Maple Leaf Community Council won a court case proving the Seattle Department of Planning and Development (DPD) did not adequately assess the significant environmental impact and harm to surrounding residents from the planned demolition of historic Waldo Hospital. Shortly after the loss in court, the developer planning to remove the building and most of the trees and replace them with forty townhomes averaging $650,000 each terminated their plans.

That’s when the Menachem Mendal Seattle Cheder (MMSC) Day School stepped in and bought the property with the intention of remodeling the building into a new school. They agreed to preserve Waldo Woods, and worked closely with the Seattle Parks Department and the Maple Leaf Community Council to make that happen. MMSC will trade over $600,000 in development potential for the $300,000 in King County Conservation Futures money, using this money to help remodel Waldo Hospital into their new school.

“Our community generated enough visibility for this project to result in today’s outcome,” noted Maple Leaf Community Council President Marc Phillips. “We’re very proud our effort, joined by other groups across the city, also resulted in better tree grove preservation rules for all of Seattle.”

Conservation easements do not actually transfer ownership of the property, only the development rights on that property. MMSC retains ownership of the property and will make a portion of Waldo Woods accessible to the public. MMSC, Parks, and the Maple Leaf community will cooperate to manage and maintain Waldo Woods on an ongoing basis.

The Maple Leaf Community Council would like to thank Seattle City Councilmembers Richard Conlin, Nick Licata, Tim Burgess, Tom Rasmussen, Sally Clark, and Sally Bagshaw; King County Councilmember Bob Ferguson; Seattle Parks Superintendent Tim Gallagher; MMSC’s Mark Goldberg; Parks Department staffers Chip Nevin and Don Harris; David Mann from the law firm of Gendler & Mann; Kathy George formerly with Cassady Law; and the hundreds of people from across Seattle who wrote letters, attended dozens of meetings, and donated money. Without considerable support from these people, this would never have happened. A special acknowledgement to Mayor Michael McGinn and the entire Seattle City Council for rapidly moving this legislation through the process.

# # #

Contact:

Maple Leaf Community Council Waldo Woods Working Group subcommittee
David Miller, Chair
Maple Leaf Community Council Executive Board
Marc Phillips, President

Seattle’s draft 2045 Comprehensive Plan

Posted on by May 20, 2024

The following comments to Seattle’s draft 2045 Comprehensive Plan are in regards to legislation passed last year by the Washington State Legislature on Comprehensive Plan requirements.

  1. In the Climate and Environment Section, p 149, of the draft One Seattle Comprehensive Plan,  the heading Tree Canopy, should be changed to Urban Forest and Tree Canopy. 
  2. Discussion – Seattle’s urban forest and  tree canopy is fundamental… add “climate resiliency”

Rationale for adding urban forest is legislative amendments noted in text below. Highlighting is mine (SZ) for pointing out specific sections. Underlined areas are new to the State Growth Management Act.

The Washington State Legislature in 2023 passed E2SHB 1181 – AN ACT Relating to improving the state’s climate response through updates to the state’s planning framework.

Section 1.(14) Climate change and resiliency. Ensure that comprehensive  plans, development regulations, and regional policies, plans, and  strategies under RCW 36.70A.210 and chapter 47.80 RCW adapt to and mitigate the effects of a changing climate; support reductions in  greenhouse gas emissions and per capita vehicle miles traveled; prepare for climate impact scenarios; foster resiliency to climate  impacts and natural hazards; protect and enhance environmental,  economic, and human health and safety; and advance environmental  justice. …

Section 3.(3) The comprehensive plan of a county or city that is required or chooses to plan under RCW 36.70A.040 shall consist of a map or maps,  and descriptive text covering objectives, principles, and standards used to develop the comprehensive plan. The plan shall be an internally consistent document and all elements shall be consistent with the future land use map. A comprehensive plan shall be adopted and amended with public participation as provided in RCW 36.70A.140. Each comprehensive plan shall include a plan, scheme, or design for each of the following: (1) A land use element designating the proposed general  distribution and general location and extent of the uses of land, where appropriate, for agriculture, timber production, housing,  commerce, industry, recreation, open spaces and green spaces, urban and community forests within the urban growth area, general aviation  airports, public utilities, public facilities, and other land uses.  The land use element shall include population densities, building intensities, and estimates of future population growth. The land use element shall provide for protection of the quality and quantity of groundwater used for public water supplies. The land use element must give special consideration to achieving environmental justice in its goals and policies, including efforts to avoid creating or worsening environmental health disparities. Wherever possible, the land use element should consider utilizing urban planning approaches that promote physical activity and reduce per capita vehicle miles traveled within the jurisdiction, but without increasing greenhouse gas emissions elsewhere in the state. Where applicable, the land use element shall review drainage, flooding, and stormwater runoff in the area and nearby jurisdictions and provide guidance for corrective actions to mitigate or cleanse those discharges that pollute waters of the state, including Puget Sound or waters entering Puget Sound. The land use element must reduce and mitigate the risk to lives and property posed by wildfires by using land use planning tools, which may include, but are not limited to, adoption of portions or all of the wildland urban interface code developed by the international code  council or developing building and maintenance standards consistent with the firewise USA program or similar program designed to reduce  wildfire risk, reducing wildfire risks to residential development in high risk areas and the wildland urban interface area, separating human development from wildfire prone landscapes, and protecting  existing residential development and infrastructure through community wildfire preparedness and fire adaptation measures.

2nd change – In the Land Use Element General Development Standards: 

 Policies LU 4.8 Use following phrasing.  

 Use urban forest and tree requirements to preserve and enhance the City’s physical, aesthetic and cultural character and to enhance the value of the trees and urban forest in addressing stormwater management, pollution reduction, climate resiliency and heat island mitigation.

Steve Zemke

Friends of Seattle’s Urban Forest

SHB 1078 fails to pass in 2024 WA Legislature

Posted on by May 17, 2024


SHB 1078 failed to get voted out of the Washington State Legislature this year. Below is the e-mail we sent Legislators. We will be working on this issue to get it passed next year.

E-Mails Needed to support  tree replanting by developers! 

We need your help. Substitute House Bill – SHB 1078 is stuck in the House Appropriations Committee in the Washington  State Legislature.  It would  require the Washington State Department of Natural Resources (DNR) to establish optional model ordinances and recommendations for the use of tree banks to replace trees removed during development, including criteria for siting tree banks to replant trees and providing best practices for maintaining newly planted trees.

We continue to advocate that developers maximize the retention of existing trees during development. Increased  density requirements, however, are  making it more difficult to retain trees on building sites. This bill is urging cities to replant new trees to increase climate resiliency and environmental equity when trees cannot be saved on building sites.

While SHB 1078 is an important step in pushing for tree replacement requirements, the use of the term “tree banks” is confusing and has different meanings, including trees in nursery situations and tree stock development. We urge the terminology change from “tree banks” to “tree replanting areas”.

We are urging  Legislators to replace the definition of “Tree Banks” in the bill with the following:

“Tree Replanting Areas” can be designated by a community to replace trees removed that cannot be retained or replanted on site. To compensate for tree loss, tree replanting programs shall provide for the payment of a fee in lieu to cover the cost of buying, planting, maintaining, and watering replacement trees to ensure their survival.” Please send an email today to urge the House to add these changes and to pass SHB 1078 this session!

Don’t Clearcut Seattle has a pre-written e-mail you can quickly sent them. Feel free to add your own comments. 
EMAIL STATE REPRESENTATIVES
Thank you for supporting our urban forests!

Questions regarding One Seattle Comprehensive Plan draft EIS

Posted on by January 31, 2025

Questions regarding One Seattle Comprehensive Plan draft EIS – May 6, 2024

  •  What is your estimation of planting needs and time frame to replace canopy lost during development (over 5 year periods as tracked by the city’s canopy study)? The Tree Protection Ordinance refers to “tree replacement required shall be designed to result, upon maturity, in a canopy cover that is at least roughly proportional to the canopy cover prior to tree replacement.” Would you agree that in most cases removing an 80 year old tree will take probably 80 years to replace? 
  • Is canopy replacement equivalence even possible with replanting since removed trees, which if not removed, would have increased growing according to scientific articles? It would appear that you’ve lost any canopy growth that would have occurred if the tree had not been removed. 

How many acres are available and suitable for planting trees in each of the following public areas – the city’s right of ways, Natural Areas and Developed Parks?

  • How many trees and what size (small, medium and large size) will need to be planted in the city every year to make up for trees and canopy removed during development on lots?
  • What is acreage is needed and available to plant trees on private property?
  • When will it be possible to reach the 30% citywide goal?
  • What potential is there for more than 30% tree canopy in Seattle over time?
  • Is up to 40% canopy coverage, over time, as proposed in the previous Comprehensive Plan possible with intense planting? 
  •  What is the projected loss in canopy volume over the next 20 years as big conifer trees and others are removed?
  • Canopy volume, especially of coniferous trees during our rainy season, is a critical factor in reducing stormwater runoff, particularly in the rainy season in Seattle. Is their loss really possible to replace in a reasonable amount of time?
  • What is the projected increase in stormwater runoff and what costs are associated with on site and alternative city water management policies of stormwater and pollutant runoff as a result? 

As to commenting on other tree potential mitigation measures, add:

  • Amend the Tree Protection Ordinance to require developers to maximize the retention of existing trees 6″ DSH and larger through the whole development process, not just platting and short platting as required now. Existing trees are the survivors and are providing ecosystem services now. 
  • Give the SCCI Director the ability to ask for alternative site designs to save trees.
  • Support building higher and building attached units to allow for tree retention and planting areas like Portland, Oregon has with 20% areas for multifamily and 40% for its 1-4 unit family zone. Zones like the industrial zone are allowed to remove all trees during development under the current ordinance.
  • Amend the Tree Protection Ordinance to require the ordinance to apply to all city land use zones.
  • Remove the “basic tree protection area” loophole in the current Tree Protection Ordinance that allows developers to unnecessarily remove almost all large trees on lots. It is not standard arboriculture practice according to the Northwest Chapter of The American Arboriculture Society. 

Steve Zemke for TreePAC and Friends of Seattle’s Urban Forest

Comments on Draft EIS for One Seattle Comprehensive Plan

Posted on by January 31, 2025


Sent: Monday, May 6, 2024 4:44 PM
To: PCD_CompPlan_EIS@seattle.gov <PCD_CompPlan_EIS@seattle.gov>
Subject: Comments on Draft EIS for One Seattle Comprehensive Plan

Seattle Office of Planning and Community Development, 600 4th Ave, Floor 5 

Seattle, WA 98104 

Response to Analysis of Plants and Animals in Section 3.3 of the One Seattle Comprehensive Plan draft EIS – lot coverage issue and building will be different than in the past and result in greater loss of large and other size trees. Numbers are given of housing units anticipated to be built. How many more canopy acres over time will be lost based on building projections in each of alternatives?

Page 3.3.7 in the Draft EIS states “Notably, most canopy loss was not associated with development activities; only 14% of the canopy loss occurred on parcels that underwent development during that period. 

This is based on a false methodology assumption used in the 2021 City of Seattle Tree Canopy Assessment Final Report.

“Methodology: To assess the impact of development (building) on tree canopy, the SAL team analyzed canopy changes on parcels that were redeveloped between 2017 and 2021 and compared them to parcels where no development projects were completed during this time. “Redeveloped parcels” were defined as sites that began and completed construction of new buildings that added residential units or new commercial buildings within the identified timeframe.” 

 This is faulty methodology – compare it to number of housing units built in Seattle during this time period. Here is a CITY of Seattle chart on Development and Growth Information. Housing Units built are based on the year the project is completed, not projects started and completed in any 1 year or 5 year period. The same methodology should be used for tree loss.  Look at canopy number on start of canopy period and end of period. Look at canopy loss on all projects completed in that 5-year period. 

 The actual canopy loss per project completed in the NR zone in the 2021 Tree Canopy Assessment was 39.8%. In multifamily the canopy loss per project was 49.5%.

The problem with comparing past loss to potential future loss is that zoning is going to change and the difference between single family housing units and ADU’s and placing 4-6 units on what is now residential lots to the equivalent of multifamily lots is that a lot more lots will potentially have 4-6 plexes on them with even less room for trees. The LR zones right now are guaranteed 85% development area of a lot and 100% lot coverage development area for MR, Seattle Mixed and commercial lots.  An analysis needs to be done based on projected building goals and projected canopy to be lost and what amount of tree retention and planting is required to increase canopy to 30% goal by 2037. The goal needs to be increased afterwards if planting areas are available and more trees are retained rather than being removed. Climate resiliency, environmental equity, public health, ecosystem services, and sustainability suggest that efforts would be beneficial to maximize efforts to increase canopy area above 30%  over time.

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