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.