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


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