Response to Ingraham High School Classroom Addition Draft SEPA Checklist Jan 2018

Friends of Seattle’s Urban Forest -Response to Ingraham High School Classroom Addition Draft SEPA Checklist Jan 2018

Westward View into Northwest Tree Grove at Ingraham High School

Healthy Madrone Shoot arising from Stump #110 – labeled “protect potential for new growth” when previous addition was built in 2011.

To right of NW addition to school is 23.5 in DBH Douglas fir in Northwest Grove area to be cut down along with smaller fir trees planted as mttigation for previous addition

The tree analysis and plan outline and other appendix information was not posted on line as of the community meeting on Thursday January 11, 2018.  I first received a copy of the full draft SEPA Checklist with Appendix  from the school district on Friday Jan 12, 2018 .  Because  the appendix to the SEPA analysis was not online or easily available, as was acknowledged at the January 11, 2018 meeting,  you need to extend the comment period. In this day and age the public should not have to go to the Broadview Public Library or the School District Office or pay to be sent a copy of the complete document even if it was clear that more information was available. It was not immediately clear to me that an Appendix was missing and that  I would have to search it out to see the information used to fill out the checklist. I do not believe I am alone in experiencing concern that the full document was not readily available.

The second major problem is that part of the proposed construction area is in the “Northwest Tree Grove”which was designated as an “uncommon plant habitat” by a Seattle Hearing Examiner” as a result of a previous SEPA evaluation for the BEX III classroom addition on the West side of the school. This is not mentioned in the SEPA Checklist.

The third major problem is that no mitigation is proposed for the removal of the trees on the north lawn or the 22.5 inch DBH Douglas fir (#109) tree proposed being removed or for at least 4 “non significant” Douglas fir trees planted as mitigation for the previous BEX III Project or the Madrone sapling growing out of #110 “stump – Protect Potential for New Growth ” also identified in the BEX III Project or other trees planted for mitigation but that died and were not replaced. The city is working to increase tree canopy and this project is decreasing tree canopy.

Further detail:

The tree report and the draft SEPA analysis  neglect completely to mention that the west end of the  proposed new building will intrude into the Northwest Tree Grove area that went through a school district and Seattle Hearing Examiner process when they built the BEX III addition on the west side in the Northwest starting in 2009 -2011.  The Seattle Hearing Examiner Ann Watanabe in a May 4, 2009 decision declared that the “Northwest Grove is an uncommon plant habitat under the SEPA policy …The northwest grove is uncommon account of the conifer/madrone/salal association which is present, and the relative scarcity of that association” In 3 areas new madrone shoots are currently  growing. One of these is from stump  (tree 109) which would be removed by the current proposal. See attached photos.

The intrusion into the Northwest Grove starts just west of the sidewalk entry from N 135 to the Westside addition built under BEX III.  This area includes 2 separate areas where mitigation Douglas firs were planted. One spot has 2 Douglas firs and the other has 2 Douglas firs along with salal and Oregon grape clumps. Additional mitigation trees, Douglas fir and western red cedar  were planted in this area and other parts of the Northwest Grove but died and were not replaced.

In addition to removing a tall 23.5 inch DBH  Douglas fir (tree 109 )from this Northwest Grove area  they are removing a healthy madrone shoot with 2 stems  totaling 2.75 inches DBH. This shoot is coming out of a stump (Tree #110) that was labeled in BEX III as   “stump -Protect Potential for New Growth”  in the Seattle School District Ingraham High School Renovation, Demolition and New Construction Second Addendum to Revised 2008 SEPA Checklist Nov 19, 2009. There are only two other areas in the Northwest Grove where madrone shoots are coming up. (see photos) It is not clear how trees and an area deemed to be protected can now be removed.

Other trees will also be cut down and cleared from the North lawn area. A number of these were also part of the mitigation for the BEX III intrusion into the Northwest Grove.   But nowhere in the tree report by Tree Solutions,which also did the arborist report in 2009 for the intrusion into the Northwest Grove of trees for the BEX III project,  is any mitigation being proposed for any of this new tree removal except re-planting street trees being removed under this project, which the city explicitly requires.

Nowhere is there mention of the previous intrusion into the Northwest Grove, its impact on the Northwest Grove size and tree removal then and protections and mitigation measures put in place as a result for that project. The Seattle School District is once again intruding into the Northwest Grove as delineated in BEX III which was designated as an “uncommon plant habitat” under SEPA. This time they has proposed no  mitigation for this new project or acknowledged that they are removing mitigation put in place for the previous project or acknowledged that many of the trees and shrubs planted as mitigation for BEX III have died on the school campus and have not been replaced in the Northwest Grove or elsewhere on the school campus.

The School District needs to implement a more environmentally sensitive and responsive plan than what is being proposed.  They need to honor the previous mitigation agreed to and propose serious mitigation for the  new actions that are sustained. They need to replace canopy lost on an equivalent basis with new trees and replant trees and vegetation that died  since BEX III was completed that was part of that mitigation process  agreed to for that project.

Steve Zemke

Chair – Friends of Seattle’s Urban Forest

Chair – TreePAC

Note – Comment period has been extended to Jan 29, 2018.

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