Seattle Urban Forestry Commission Letter to City Council on MHA Legislation Regarding Mitigation for Tree Loss.

January 9, 2019.
MHA Council Committee
City Hall
600 4th Ave
Seattle, WA 98124
RE: Amendments to MHA Ordinance
Dear Councilmembers,
The Urban Forestry Commission (UFC) would like to provide additional input as you undertake amendments for the Mandatory Housing Affordability (MHA) Ordinance.

The UFC is concerned about the feedback loop between all the different pieces of tree
protection legislation currently being considered. The Tree Protection Ordinance (currently on hold) affects Green Factor, its Director’s Rule, and the MHA Ordinance.

The UFC still feels mitigation measures proposed on the MHA EIS are not enough, especially being that the Tree Protection Ordinance is on hold. Available space for trees is being significantly reduced as part of MHA. The UFC believes the City needs to be more intent in protecting existing trees and requiring tree replacement. Other efforts that would support successful tree protection would include:
1. Clearly defining what a tree is (as done in version D7 of the Draft Tree Protection
2. Including protection for all significant trees 6” in diameter and larger (not just
exceptional trees) removed during development in all zones.
3. Establishing a fee-in-lieu option to fund tree replacement when it’s not possible to do
on site.
4. Replacing significant trees removed on site or paying an in-lieu fee to the City to
cover replacement and maintenance costs in the neighborhood or elsewhere in the city
as needed (SMC 25.11.090).
5. Establishing the tree replacement requirement to be calculated based on canopy
volume lost and tree species and size at maturity (in 20 years).
6. Setting a minimum canopy cover requirement per property, including Residential Small
7. Capturing all data on significant tree retention, loss, and replacement into the City’s
8. Properly funding enforcement for tree protection to be effective.
9. Considering previous input provided by the UFC on the Green Factor Director’s Rule
letter of recommendation and Draft MHA Ordinance recommendations, which was
based on the current draft DR and additional changes might be warranted.

The UFC would like to propose specific language changes to SMC 25.11.090 (A), as follows:

Each exceptional significant tree (six inches DBH and larger) and tree over two (2) feet that is removed in association with development in all zones shall be replaced by one or more new trees, the size and species of which shall be determined by the Director; the tree replacement required shall be designed to result, upon maturity in 20 years in a canopy cover volume that is at least equal to the canopy cover volume prior to tree removal. Preference shall be given to on-site replacement. When on-site replacement cannot be achieved, or is not appropriate as determined by the Director, preference for off-site replacement shall be on public property a fee-in-lieu shall be paid to the City to replace and maintain the tree or trees in the neighborhood where they were removed or elsewhere as needed in the city. The City shall enter all significant trees on site, trees removed, and trees replaced into SDCI’s current database system; noting tree species, common name, DBH, height, condition and location,

The UFC would be happy to work with Council to help explore creative ideas and solutions to support Seattle’s urban trees as our city grows and gets denser as well as coordinating the different elements to tree protection regulation currently being considered by the City.


Weston Brinkley, Chair                   Steve Zemke

cc: Mayor Durkan, Nathan Torgelson, Samuel Assefa, Jessica Finn Coven, Michelle Caulfield, David Driskell, Mi Podowski, Maggie Glowacki, Chanda Emery, Brennon Staley, Vera Giampietro, Urban Forestry Management Team, Urban Forestry Core Team, Sara Maxana, Aaron Blumenthal, Eric McConaghy, Yolanda Ho, Amanda Hohlfeld

see original document here – Re: Amendments to MHA Ordinance 

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