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

Draft EIS for Seattle 2035 Comprehensive Plan Gives Urban Forest Short Shift

Seattle is currently undergoing an update of its Comprehensive Plan. The update to deal with growth projections over the next 20 years is required under the State’s Growth Management Act. The projections are that Seattle will see a significant increase of 120,000 new residents, 115,000 additional jobs and 70,000 new housing units. A draft EIS has been prepared for public comment with a closing date of June 18th.

It was the determination of Seattle’s Urban Forestry Commission that the draft EIS did not adequately address the impacts of the projected growth on Seattle’s urban forest and its goal in the near term to reach 30% canopy cover by 2037.

The draft EIS for the 4 alternative growth scenarios by 2035 can be seen by clicking on the following link:

draft EIS Seattle 2035 Comprehensive Plan

You can also go to DPD’s 2035 Seattle webpage for more information

Comments on the draft EIS should be sent by email to: by June 18, 2015.

You can also go online and submit comments on DPD’s feedback page

The Seattle Urban Forestry Commission has reviewed the draft EIS and submitted comments. The full text of their letter can be seen here:

SUFC –Comments on the Draft EIS for the Seattle 2035 Comprehensive Plan

The summary is printed below, followed by the full text of the letter:

In summary, the Commission believes that the draft EIS does not address a number of impacts that could be caused by the different growth scenarios as a result of tree canopy loss from increased development. Much more analysis is given to view impacts and noise impacts while ignoring potential significant impacts caused by increased tree canopy loss.

SMC 25.11 is seriously outdated and needs updating like many other cities including Portland, Oregon; Lake Forest Park, WA; Atlanta, GA; and Vancouver, BC have done to protect and increase their green urban forestry infrastructure. So called protection of exceptional trees under SMC 25.11 is based on a complaint system and is unfortunately not protecting exceptional trees.

The Urban Forest Stewardship Plan cannot address reaching a 30% canopy goal without adequate information as to the amount of canopy that is being lost during development. The Commission recommended DPD to implement an Urban Forestry Canopy Impact Assessment for all their projects and so far has not responded to the Commission’s letter of recommendation or indicated any intention to do so.

And eliminating by oblique reference the long-term, aspirational canopy goal of 40% as adopted by the Seattle City Council in the current Comprehensive Plan without any discussion of its impact on Seattle’s future urban forest is unacceptable. The long term 40% canopy goal should remain in the plan and reference that the 30% goal by 2037 is a stepping stone to the larger goal and not the final goal.

Full text of the letter:

June 10, 2015.

Gordon Clowers

Department of Planning and Development

700 5th Avenue, Suite 2000

Seattle, WA 98124

RE: Comments on the Draft EIS for the Seattle 2035 Comprehensive Plan

Dear Mr. Clowers,

The Seattle Urban Forestry Commission wishes to address the following concerns about the draft Environmental Impact Statement (EIS) for the Seattle 2035 Comprehensive Plan.

1. Impacts on the Urban Forest due to Increased Density

The draft EIS does not evaluate the impacts on Seattle’s urban forest by adding 120,000 new residents, 115,000 new jobs, and 70,000 housing units to Seattle by 2035. Only one page’s worth of print out of the approximately 400 pages is devoted to potential impacts on the urban forest and it basically says that there is no problem because we have the Urban Forest Stewardship Plan and provisions in SMC 25.11. It is the Commission’s view that this is not accurate. The draft EIS provides no direct or detailed evaluation of the yearly or cumulative loss of urban forest canopy due to development and growth and the associated impacts on air pollution and human health, noise, storm water runoff, wildlife habitat, open space, or heat island effects.

The draft EIS on p 3.5-11 states: The Urban Forest Stewardship Plan’s goal’s and the implementing regulations in SMC 25.11 would apply to development that occurs under all EIS alternatives and would help to mitigate for the potential removal of all trees and reduction of canopy cover with future development. In this respect, the growth patterns examined under all alternatives would be able to be implemented while remaining consistent with the UFSP’s goals.”

Unfortunately, there is no environmental analysis of the specific impacts or costs associated with canopy loss occurring during development. There is no analysis of how much canopy loss would occur and what the cost would be or who would pay for replacing canopy lost during development. The current City Comprehensive Plan calls for no net loss of canopy. If the City does not know how much canopy is being lost through development it cannot accurately assess whether it is meeting the no net loss goal let alone gaining canopy each year.

The Urban Forestry Commission addressed this issue on the need for more detailed data from DPD on tree loss in a letter adopted June 25, 2014.

The letter stated in part:

“The Commission has discussed several ideas to improve submittal documentation and final reporting for projects under DPD’s permitting.

Currently, the City, through OSE and the Urban Forestry Interdepartmental Team, keeps track of the number of trees planted and removed on public property every year. The Commission recommends tracking trees lost on private property undergoing development to assist in determining where we are gaining or losing trees and canopy. This would add information to the overall city canopy coverage assessment data. By knowing more about canopy trends on different types of land, we can better direct policy and programming to ensure we are on track to meet our 30% goal.

What would help the City better understand what is happening with tree canopy protection and enhancement is to require that all development projects submit an Urban Forest Canopy Impact Assessment prior to any construction project being approved. The Urban Forest Canopy Impact Assessment would include a map of the property with the trees numbered, canopy area of trees drawn, and trees to be removed clearly labeled. Under current guidelines it would minimally require that all trees 6 inches DBH (diameter at breast height) or larger be inventoried on the property. The suggested data points required would be:

Species: speaks to size of canopy and amount of storm water benefit.
DBH: speaks to age of tree and canopy coverage.
Tree Height: speaks to canopy volume and amount of environmental benefit.
Canopy Width (area): speaks to canopy volume and amount of environmental benefit.
Tree Condition: speaks to overall forest health and environmental impacts.
Photographs of the trees on the parcel and adjacent properties.
Canopy coverage as a percent of area pre- and post-project development.

  •  Landscape Plan Requirements could include calculations for percent canopy coverage at 20 years and soils volume provided for each tree.
  •  The annual UFSP Progress Report to the Mayor and City Council could include canopy coverage for different development zones.

Implementing some or all of these operational steps would greatly help to evaluate whether or not we are doing enough to reach our 30% canopy goal.”

Inadequate Tree Protection in Current Code

A second issue is that the Commission believes that the current tree protection ordinance in SMC 25.11 is inadequate to meet the goals of achieving a 30% canopy by 2037. It has so stated in several letters to the Seattle City Council and Mayor, including the letter dated July 15, 2014.

In that letter the Commission stated:

In 2009, City Council issued Resolution 31138 instructing “…the Department of Planning and Development to submit legislation by May 2010 to establish a comprehensive set of regulations and incentives to limit the removal of trees and promote the retention and addition of trees within the City of Seattle on both private and public property…” >

We would like to reiterate the statement made in our August 2010 recommendation: Bold action, consistent with Resolution 31138, is needed to achieve Seattle’s tree canopy coverage goal of 30% by 2037. And because the majority of trees in Seattle are in residential property, an updated tree ordinance is key to implement the 2013 Urban Forest Stewardship Plan as adopted by City Council last September.

DPD released a first proposal in 2010 and a second proposal in 2012. It is now almost five years since the Resolution and DPD is still working on a tree ordinance for trees on private property. There was a significant amount of time and energy invested by the community in this process. This length of time tends to frustrate the public as they look for guidance on tree measures.

We urge you use your leadership in Council’s Seattle Public Utilities and Neighborhoods Committee to:

1. Encourage DPD to resume work on this important element of a comprehensive urban forestry strategy for Seattle with a more defined timeline than the one currently shown on their website.

2. To develop an improved public education and outreach approach that engages Seattle’s diverse stakeholder communities.

3. Require a reporting of how the new proposal addresses the DPD specific elements of the Resolution: a. The 15 elements of Section 1;

4. b. The four elements of Section 2; and

5. c. The section for requirements for institutions, City facilities, public facilities, and schools.”

It is now another year later and there has been no further action on passing an updated tree ordinance.

3. Removal of the Current 40% Canopy Cover Long-Term, Aspirational Goal

The third issue the Commission is concerned with is that the Draft EIS said that the Seattle 2035 Comprehensive Plan would eliminate the City’s long-term goal of a 40% tree canopy in the current comprehensive plan and replace it with the Urban Forest Stewardship Plan goal of 30% by 2037.
That seems to be the intent of the language on p 3.5-1 that says “Adjusting the quantitative tree canopy goal in the Environment Element to be consistent with the 2013 Urban Forest Stewardship Plan.” That would reduce the current overall long-term goal of 40% in the Comprehensive Plan by 25%. There is no discussion of the impact of that change both in the short-term or long-term and the ability to pursue a 40% aspirational goal after 2035. A long-term goal of 40% canopy cover and a 2035 goal of 30% canopy by 2037 is a step toward that larger goal.

The Commission addressed the issue of the long-term canopy goal of 40% in its comments on the current Comprehensive Plan in a letter dated May 11, 2011.

The language proposed by the Commission was adopted by the Seattle City Council and is in the current Comprehensive Plan under ENVIRONMENT ELEMENT H Seattle’s trees E23:

“Achieve no net loss of tree canopy coverage, and strive to increase tree canopy coverage to 40 percent, to reduce storm runoff, absorb air pollutants, reduce noise, stabilize soil, provide habitat, and mitigate the heat island effect of developed areas.”

Additional comments

  • The 2013 Urban Forestry Stewardship Plan is not listed in the references.
  • The benefits of trees mentioned on p 3.5-11 under the heading Urban Forestry Stewardship Plan fails to mention a number accepted benefits of trees including documented health benefits of a healthy urban forest; reducing storm water runoff; impacts on wildlife habitat; and impacts on birds, insects, other animals and associated plants.

In summary, the Commission believes that the draft EIS does not address a number of impacts that could be caused by the different growth scenarios as a result of tree canopy loss from increased development. Much more analysis is given to view impacts and noise impacts while ignoring potential significant impacts caused by increased tree canopy loss.

SMC 25.11 is seriously outdated and needs updating like many other cities including Portland, Oregon; Lake Forest Park, WA; Atlanta, GA; and Vancouver, BC have done to protect and increase their green urban forestry infrastructure. So called protection of exceptional trees under SMC 25.11 is based on a complaint system and is unfortunately not protecting exceptional trees.

The Urban Forest Stewardship Plan cannot address reaching a 30% canopy goal without adequate information as to the amount of canopy that is being lost during development. The Commission recommended DPD to implement an Urban Forestry Canopy Impact Assessment for all their projects and so far has not responded to the Commission’s letter of recommendation or indicated any intention to do so.

And eliminating by oblique reference the long-term, aspirational canopy goal of 40% as adopted by the Seattle City Council in the current Comprehensive Plan without any discussion of its impact on Seattle’s future urban forest is unacceptable. The long term 40% canopy goal should remain in the plan and reference that the 30% goal by 2037 is a stepping stone to the larger goal and not the final goal.

Thank you, for the opportunity to comment.

Leif Fixen, Chair
Steve Zemke

Keeping Cheasty, and All Seattle’s Natural Areas, Healthy for Urban Nature


The Thornton Creek Alliance has sent the following letter to the Seattle Park Board Commissioners questioning the pilot project proposal to open a large section of the Cheasty Green Belt and Natural Area to active sports use by mountain bikes.
Seattle Park Board of Commissioners
100 Dexter Avenue North
Seattle, Washington 98109
Re: Keeping Cheasty, and All Seattle’s Natural Areas, Healthy for Urban Nature
Greetings Park Board Commissioners:
We hope that after hearing all the points of view, and after your own experiences in meeting with the public, you will do the right thing for Seattle’s few remnants of urban forest and save this one for the present and future enjoyment of our diverse neighborhoods and swelling population.  Thornton Creek Alliance (TCA) strongly supports foot trails and ADA standard trails in natural areas.  We want everyone have the lovely opportunity to enter our natural areas, walk through them, enjoy watching wildlife, and participate in forest restoration.  These are gifts only a forest can give.  How else will people of all backgrounds and income levels get to experience our forests first-hand if they are sliced up and modified to accommodate the various interests of successions of ‘activity activists’? 
Please note that the April 2, 2015 Parks staff recommendation to you has very little in common with the single perimeter trail and three-year pilot project that the city council unanimously approved last August.  The Parks recommendation makes the mountain biking community and a subset of Chesty neighbors happy, but it is not at all supported by another subset of neighbors, and it is generally condemned by Forest Stewards and everyone else who loves quiet study and restoration of these parcels of land that make up a scant 15% of Parks’ property.  Note also that the ‘activity activists’ have only begun arguing for the changes they want to make to Cheasty, changes that will require yet more clearing in this very narrow natural area.
The December outreach meeting with the under-served communities must be considered invalid for the simple reason that there was no educational component.  How could these communities be expected to know ahead of the meeting why natural areas have been preserved and developed in the first place?  Of course they liked everything they thought was on the table when they had no clear understanding of what was being taken off.
Parks is recommending bike trails for the reasons given below. (By this logic no Seattle natural area is safe from consideration.)  Yet, note that all of these goals can be achieved without bicycles in natural areas, and in fact, a great many more goals could be reached with bicycles omitted.
• The trail will provide recreational opportunities for currently under-served communities, providing families with the opportunity to experience nature and recreation in their own neighborhood.  
• This project will provide a link between the Rainier Vista community and North Beacon Hill. 
• The trail responds to environmental issues within the Cheasty greenspace and has been designed to work with the geology of the property. 
• There is strong community support for the trail. 
• Volunteer restoration work is a high priority for the surrounding community and there is a strong commitment to this project and the maintenance necessary to maintain the trails. 
• Our City is experiencing unprecedented growth. We need to look at creative ways to provide recreational opportunities in our urban environment.
One has to wonder why the goals refer to a ‘trail’ when in fact two concentric trails, plus access trails, are now proposed, and even more are on the horizon.  Additionally, these goals reflect no acknowledgement of the many considerations and reservations put forth by various PAT members or anyone else who contributed to the discussion.  Ditto for the entire recommendation letter.  How is this appropriate?
We certainly agree that Parks has done a lot of outreach around the Cheasty bike plans, and we truly appreciated the opportunity afforded by the Mini Summit discussion of natural area policies three weeks ago.  However, the talk in the hall has been of ‘inclusion illusion’, and this Parks staff recommendation seems to bear that out.
TCA supports a policy of right activity, right place.  Sports equipment, including bicycles, works well in a wide variety of park venues and elsewhere, but it does not belong in our natural areas which can be activated in much more appropriate ways.  For example, we could begin now to build momentum for a 2016 ‘Seattle Summer of Nature’, and invite everyone in to explore and learn about the hidden life of our natural areas.
Thank you for your thoughtful consideration of this matter.
Ruth Williams, President
Thornton Creek Alliance
Post Office Box 25690
Seattle, Washington 98165-1190
 THORNTON CREEK ALLIANCE (TCA), founded in 1993, is an all-volunteer grassroots, nonprofit organization of 100 members dedicated to preserving and restoring an ecological balance throughout the Thornton Creek watershed. Our goal is to benefit the watershed by encouraging individuals, neighborhoods, schools, groups, businesses, agencies, and government to work together in addressing the environmental restoration of the creek system including:  water quality, stabilization of water flow, flood prevention, and habitat improvement through education, collaboration, and community involvement.


Parks Grasslands Mowing Impacting Ground Nesting Birds


The following letters were posted on Seattle Parks and Open Space Advocates  listserve and raise an important issues affecting ground nesting birds in Seattle and other parks.

Subject: Stop the mowing of nesting bird habitat in Discovery Park! 

Dear City and Parks Department officials,

For the second consecutive year, we are writing to demand that Seattle Parks Department cease destroying Savannah Sparrows by mowing over their nests on the Parade Ground meadow at Discovery Park. The area is not a golf course, playground, or off-leash dog run. Park facilities managers must be required to consult naturalists on staff to determine appropriate maintenance and problem-solving measures. Otherwise the purpose and goals of the park are undermined – with potentially devastating consequences for years.
The Savannah Sparrow is a small grassland bird that travels from as far as southern Mexico to nest here.  Of those that survive the trip, large numbers of parent birds and their nestlings will die if the mowing in Discovery Park and other park meadows continues. Indiscriminate mowing will also deprive late breeders of nest sites and habitat for months.
We are longtime volunteers at Discovery Park. In fact, we credit the park’s nature programs and the encouragement of its talented naturalists for having turned us into avid birders. We now give back as best we can by participating in the monthly bird census at Discovery Park and helping to lead some of the migratory bird walks each spring and fall.
Discovery Park is a jewel that needs to be managed with educated and informed care to encourage the wildlife and natural habitat. Please intervene immediately to suspend mowing of Discovery Park meadows and to establish a pro-habitat maintenance policy for all city properties.
Helen Gilbert Henry Noble Seattle, WA 98115

Follow up Letter: Savannah Sparrows under attack again! ‏ 

Hi Tweeters –
Some folks have asked for clarification on the issue of timing of meadow mowing by the Parks Department, the effects of mowing on ground nesters, and how widespread the problem is.
We know for sure it is a problem at Discovery Park and the mowing is happening there right now at the Parade Grounds meadow while Savannah Sparrows are nesting. I am also concerned that since the city doesn’t have a policy, parks that are less closely monitored than Discovery Park, such as Magnusson which has no on-site naturalists, are probably having the same problem with no one noticing. In addition to Savannah Sparrows, ground nesters include juncos, Pacific Wrens, Common Yellowthroats and Song Sparrow. See this article about the topic (ironically reposting from Seattle Parks Dept.) from a few years back.
It’s my understanding that activities such as mowing meadows and large scale disturbances of nesting areas (including brushy areas that may have many invasive plants but are also prime nesting spaces) should be curtailed between mid-March and July.
Below is the letter that Henry Noble and I sent to the city. We also used the Mayor’s message web page to contact him.

Open Position – Seattle Urban Forestry Commission

Press Release: from Seattle Urban Forestry Commission

SUBJECT – Hydrologist or similar professional sought for Seattle Urban Forestry Commission


10/8/2014 4:00:00 PM Sandra Pinto de Bader (206) 684-3194

Hydrologist or similar professional sought for Seattle Urban Forestry Commission

SEATTLE – City Council is looking for a new Urban Forestry Commission (UFC) member to fill Position # 4 (hydrologist or similar professional). A hydrologist or similar professional, preferably with expertise in the study of natural drainage, climate or air quality, or a combination thereof is preferred. The term would start December 1, 2014 and would extend through December 1, 2017. This position is appointed by the Mayor, and confirmed by City Council, for a renewable, three-year term.

The nine-member UFC consists of a wildlife biologist; an urban ecologist; a representative of a local, state, or federal natural resource agency or an accredited university; a hydrologist; a certified arborist; a representative of a non-profit or non-governmental organization; a representative of the development community or a representative from a non-city utility; and an economist, financial analyst, or Washington State license real estate broker.

The City of Seattle set the bold goal of achieving 30 percent tree canopy cover by 2037 to increase the environmental, social, and economic benefits trees bring to Seattle residents. The Seattle Urban Forest Stewardship Plan (UFSP) is a comprehensive strategy for increasing Seattle’s tree canopy cover to meet the 30 percent target. The UFSP lays out goals and a broad range of actions to be implemented over time to preserve, maintain, and plant trees as well as restore the public forested areas remaining in the city. More information about Seattle’s urban forest program can be found at

The Urban Forestry Commission was established in 2009 by Ordinance 123052 to advise the Mayor and City Council concerning the establishment of policy and regulations governing the protection, management, and conservation of trees and vegetation in the City of Seattle. Commission meetings are held twice a month on the first and second Wednesday from 3:00 p.m. to 5:00 p.m. Commission members generally must commit approximately 10 hours per month to Commission business and serve without compensation. Additional information about the Urban Forestry Commission can be found at

Applications are due November 10, 2014.

To be considered, please send a letter of interest and resume to Sandra Pinto de Bader ( To send a paper submittal, address it to: Sandra Pinto de Bader, Urban Forestry Commission Liaison, Urban Forestry Commission, Office of Sustainability and Environment, City of Seattle, 700 Fifth Avenue, Suite 1868. PO Box 94729, Seattle, WA 98124-4729.

For more information, please contact Sandra Pinto de Bader, Urban Forestry Commission Liaison, at (206) 684-3194 or via email at


Can Seattle Reach a 30% Tree Canopy Goal by 2037?

Seattle’s Urban Forest Stewardship Plan calls for Seattle reaching a 30% canopy goal by 2037. Seattle’s current tree canopy is about 23%.

The UFSP states that Seattle’s land are is 54,379 acres.

A Seattle canopy cover of 30% canopy = 16,314 acres.

Seattle’s current canopy cover of 23% canopy = 12,507 acres.

16,314 acres – 12,507 acres = 3807 additional acres of canopy cover needed by 2037.

3807 acres / 23 years = 165.52 acres of new canopy needed every year to reach 30% canopy goal by 2037

Portland, Oregon in their city-wide Tree Policy and Regulatory Improvement Project report, June 2011, calculated that planting 900 medium size canopy trees (on average) would generate only 12 acres of future canopy growth annually.

165.52 acres/ 12 acres X 900 trees = 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.

Detailed analysis of Portland’s calculations is in Volume 1 – Recommended Draft Report to City Council Dec 2010 starting on page 144 – Tree Canopy Benefits, Financial Impacts and Budget Proposal” Portland calculated that their tree ordinance would for the same amount of money spent on just planting trees on 12 acres, they could generate about 140 acres of canopy per year.

Currently Seattle has no requirement to replace most trees cut down as a result of development on private property except as part of green factor which can mostly be met by other means. Seattle public trees that are removed are replaced on a 2 for 1 basis but the process does not specifically address tree size. While the Seattle Comprehensive Plan calls for a no net loss of tree canopy every year there is no overall city department or entity that is tracking the net loss or gain of trees citywide each year.



revised 8/14/2014

Action Needed – Help Save Seattle’s Trees!

The Seattle metropolitan area urban forestry canopy has decreased from about 40% in 1972 to only about 23% today in the city of Seattle. And every neighborhood has seen the loss of trees both one by one and in larger numbers when development occurs.

What is needed is stronger protections for our urban forest and its trees. Trees help reduce storm water runoff; remove pollutants from the air, including CO2; provide habitat for birds, insects and other wildlife; calm traffic on our streets, increase property values, help in reducing heat in the summer and cold in the winter; and create more livable neighborhoods and business districts among other things.

With increased development and population growth, Seattle is losing its trees. While other cities around the Northwest, like Portland, Oregon and Lake Forest Park, WA have recently strengthened their tree ordinances, Seattle has actually proposed legislation to significantly decrease protections for trees. Rather than an open process involving the public to draft new legislation, the Seattle City Council has asked the Department of Planning and Development (DPD) to draft new legislation. Unfortunately they have a conflict of interest in their mission which is to help people build and develop, not protect trees.

Unfortunately the first two drafts proposed by DPD were written to give developers and others a free reign to do whatever they wanted and proposed no longer protecting significant trees and tree groves or even limiting how many trees could be removed in a year. They instead proposed that public education and incentives were all that is needed.

Please contact your Seattle City Councilmembers and the Mayor and let them know you want our trees and urban forest to be protected by passing stronger protections, not reducing them.

Tell the Mayor and the City Council to:

1. Maintain and expand protections for exceptional trees and tree groves.
2. Require permits to remove trees on both public and private property like other cities are doing and the Seattle Department of Transportation (SDOT) already does in the planting strips.
3. Require 2 week posting of tree removals which SDOT already does.
4. Require regulations to cover both public and private trees as Portland, Oregon is doing.
5. Consolidate tree oversight in a new Department of Forestry or the Office of Sustainability and the Environment, not the Department of Planning and Development.
6. Require that a Canopy Impact Assessment be done on all development projects, evaluating the impact of tree removal on the city goal of reaching 30 % canopy cover by 2037.
7. Require equivalent tree replacement either on or off site for all trees removed so there is no net loss of canopy as per the City Comprehensive Plan.
8. Give priority to planting native trees and vegetation to help preserve native plants and wildlife.
9. Emphasize habitat protection, retention of soils and ecological processes
10. License and train all arborists and tree cutting operations, impose fines and suspension for violations.

e-mails –;,;;;;;;;;

You can help in our efforts to protect our trees and urban forest by joining with us. Add your name to our e-mail contact list by contacting us at Friends of Seattle’s Urban Forest, c/o Steve Zemke – Chair, 2131 N 132nd St, Seattle. WA 98133, , 206-366-0811. Our facebook page is at Friends of Seattle’s Urban Forest and our website is at .


Updated Portland Oregon Tree Ordinance to be Effective Jan 1, 2015

Portland Oregon has enacted a far reaching update of their regulations on protecting trees and their urban forest.  Originally slated to be effective in 2013 it will now be law as of January 1, 2015.

Here is the link to the current adopted  Portland, Oregon Title 11 Tree regulations as updated Jan 23, 2013 with an effective date of Jan 1, 2015. The link is to the Citywide Tree Policy Review and Regulatory Improvement Project Report  entitled Title 11 Trees  and includes the code language passed along with additional commentary on facing pages.

An earlier report by the Citywide Tree Policy and Regulatory Improvement Project is available also in a document entitled Recommended Draft Report to the Portland City Council  December 2010 details the issues and process that was involved in coming up with their new regulations.

Portland’s adopted regulations will now cover  trees on both public and private property including during development. As Portland explains in their ordinance it was enacted to:

“enhance the quality of the urban forest and optimize the benefits that trees provide. Desired tree benefits include:
1.Providing oxygen and capturing air pollutants and carbon dioxide;
2.Maintaining slope stability and preventing erosion;
3.Filtering stormwater and reducing stormwater runoff;
4.Reducing energy demand and urban heat island through shading of buildings and impervious areas;
5.providing visual screening and buffering from wind, storms and noise;
6.Sustaining habitat for birds and other wildlife;
7.Providing a source of food for wildlife and people;
8.Maintaining property values and the beauty, character and natural heritage of the city; and
9.Meeting the multi-purposed objectives of the Urban Forest Plan, including reaching and sustaining canopy targets for various urban land environments.”


How Trees are Lost in Seattle – Case Study – 3636 Ashworth Ave N

There are many reasons why trees are lost in Seattle despite efforts to protect them.  The following is another example of why our interim tree ordinance needs to be updated. It lacks the protections many other cities have and does not protect existing trees from being cut down needlessly.

And it points out why the Department of Planning and Development (DPD) is the wrong city department to have in charge of protecting trees. Seattle needs a city department like the Office of Sustainability and the Environment with a clear mission statement to be an advocate for saving trees and not have conflicting missions like DPD does. DPD’s primary mission is to help developers build projects and has publicly stated that their policy is to protect trees unless they limit the development potential of a lot. But even that statement is false when you look at the following example.

They are giving no protection to a large 25 inch Douglas fir even when there are clearly alternative ways to build the proposed garage on this site  without removing the tree.Check out this picture. The garage is to be build on the right side of the lot between the red markers in the center of the picture. DPD’s response is that it has no ability to save this tree despite clear alternatives.


There is an equal amount of space to move the garage to the left of the stairs coming down to the sidewalk or just to the right of the stairs.  Either of these two options would clearly allow the garage to be built and still save the tree. Note also that building the garage does not add any additional parking but is actually a net loss as it will remove two on street parking spaces.

Check out  DPD’s response to the next door neighbor Nancy Rottle’s inquiry and request to save the tree in the following e-mails. And check out the actual application file and note that there is no official recording of the below e-mails and DPD’s response although one would think this would be in the public record as a complaint.

Also note that there is no assessment of the impact of the garage or project on Seattle’s urban canopy or Seattle’s Comprehensive Plan’s goal of no net loss of trees. There is no  requirement to try to save trees whenever possible or to replace trees lost as a result of this project.

From: Nancy Rottle <>
 Nancy D. Rottle, RLA, ASLA
Associate Professor, Department of Landscape Architecture

Director, Green Futures Research and Design Lab
ScanlDesign Endowed Chair in Built Environments
Adjunct Associate Professor, Departments of Architecture and Urban Design and Planning 
College of Built Environments 
Box 355734  University of Washington
Seattle, WA 98195-5734
voice 206.685.0521
From: Nancy Rottle <>
Subject: Project 6376676
Date: December 12, 2013 11:17:49 AM PST
Hello Andy,
I am a neighbor of this project and I also teach urban design at the UW.  I am dismayed at the some of the guidance that the applicant has gotten for this project as I believe that it is actually counter to the current goals of DPD and the City’s Comprehensive Plan and am hoping that there might be some recourse to the applicant’s current plan.
The project is a lot boundary adjustment to a property that has historically been an 8-dwelling apartment building in a single family zone. The through-lots face Ashworth Avenue and Carr Street, with the Carr Street lot serving as the parking lot for the apartment which fronts onto Ashworth.  The property was recently sold and the applicant plans to build a house on the parking lot site and therefore requested the lot boundary adjustment in order to have a lot large enough to allow construction of the additional house. In order to compensate for the parking loss, DPD required the applicant to provide a minimum number of off-street parking spaces.  To make this work, the applicant is proposing four parking spaces on the existing parking lot, and a single space in a bunker garage constructed on Ashworth Ave.
My concern is with the proposed construction of the parking bunker on Ashworth Avenue.  My concerns are:
            1) The proposed garage location is in an Environmentally Critical Area (I believe) and will necessitate the removal of a large Douglas fir tree which is growing above the proposed garage location. This tree is a keystone in a grove of trees* which provides valuable bird habitat in the neighborhood, and may legally constitute a “grove” under the City’s definition. The tree provides additional benefits of stormwater control (we are in a combined sewer neighborhood), heat island mitigation, air purification and carbon sequestration, as well as contributes to  neighborhood aesthetics.
            2)  With the construction of the single car garage, a parking spot on the street will be lost, so there would be no net gain of parking in the neighborhood. This is an RPZ zone where there there is neighborhood concern about loss of parking spaces. (Ironically, the proposed bunker location will require the removal of the RPZ sign for the curb cut).
            3) The snout garage will undoubtedly degrade the character of the street; neighborhood design guidelines have discouraged use of these garages as they make the street less attractive and less pedestrian-friendly.
            4) The substantial cost of installing the parking garage will undoubtedly be borne by the apartment dwellers, increasing housing costs.  This apartment complex has been an affordably priced alternative in a central neighborhood and it would be a shame to lose this resource. Again, there is irony in that the approval of small lots in traditional single family zones is done in part in the assumption that creating more housing will keep it more affordable — yet this requirement would likely raise the cost of the apartment rental (and certainly the new house that the applicant will build will not be “affordable” — but that is another issue).
While the City, and specifically DPD, are promoting walkable, affordable neighborhoods and stewardship of the public-private urban forest — I could point out policy documents but I’m sure you’re aware of these — the developer’s proposal to construct this garage is in response to DPD’s requirement for a minimum number of parking space, which however does not actually create any additional parking space in the neighborhood, but does have other significant adverse effects that are counter to the City’s goals.
I wonder if there might be other solutions that could be suggested to the developer, who I’m guessing would prefer to avoid the considerable expense and bother to construct this garage.  For example, in lieu of constructing the off-street space, the developer could be required to provide:
            – Payment for residents’ permanent use of the RPZ zone;
            – Purchase of bus passes for apartment residents; and/or
            – Purchase of electric bicycles and provision of bike parking.
These options would address all four of the concerns listed above. (If the cost of constructing the garage is $40k, that could be $5k allocated per unit, which spread over 20 years would be $500 per year.)  You would probably have additional good ideas for how to actually achieve DPD’s and other City agencies’ common and multiple goals.
Another option would be to require or at least suggest the garage be built on the north side of the lot, where it wouldn’t require the removal of the Douglas fir and wouldn’t adversely affect the on-street parking loss (since there is fire hydrant just to the north that currently prevents on-street parking in this location). That solution would address concerns 1 and 2 above.
I would love to discuss this with you but thought it would be most efficient to send this mail first. I did speak with Emily Lofstedt and since she is just following the letter of the code and not in a position to creatively address the bigger picture she recommend that I talk with you.  Is there a good time and phone number that I can reach you?
Thank you for your consideration of my request,
Nancy Rottle, RLA
3632 Ashworth Avenue North
Seattle, WA 98103
* This tree may qualify as Exceptional as it is part of a continuous canopy of trees larger than 12″ dbh.  These trees are not represented on the applicant’s survey.
From: Nancy Rottle []
Sent: Tuesday, December 17, 2013 12:59 PM
To: McKim, Andy
Cc: Lofstedt, Emily
Subject: Fwd: Project 6376676
Hello Andy,
I wanted to check back to ensure that you received my message below and to arrange a time to talk with you about this project.  Is there a time that I could talk with you this week?  Please let me know the best time/number to call.  I have spoken with several neighbors who are concerned about the guidance that DPD is giving the applicant.
Thank you for your consideration and service,
Nancy Rottle, RLA, ASLA
On Dec 17, 2013, at 2:55 PM, McKim, Andy wrote:
Hello, Ms. Rottle.
I have received your messages, but needed to look into your questions before getting back to you.
In this case, we determined that the east portion of the property, fronting on Carr Place N, could qualify for development as a separate building site under the lot area exceptions provided in the Land Use Code for Single Family zones (Seattle Municipal Code Section 23.44.010.B), so long as five parking spaces legally provided on that property for the existing building could continue to be provided on the site of that building.  An application for a lot boundary adjustment was submitted, applying our Director’s Rule 13-97 which allows the adjustment of a lot line between two legal, undersized lots, so long as their sizes remain the same.  The applicant has proposed to relocate the parking spaces so that they will be on the same lot as the existing building after the lot boundary adjustment.  As you note, one of the proposed spaces will be a bunker garage accessed off of Ashworth Avenue North.
The zoning approvals that are required for this – approval of a lot boundary adjustment and zoning review of the relocated parking and the new garage – all are “Type I” approvals under our Land Use Code, meaning they involve little discretion.  In the case of Type I reviews, we have no authority to impose conditions to address impacts, or to consider whether the proposed development is consistent either with adopted policies or with good planning principles.  If the proposal meets the standards of the code, we are legally obliged to approve it.  Although the points you raise, for example about costs and visual impacts associated with the garage and the importance of retaining mature trees, may well be valid, we are not able to condition or reject a permit application on these bases if the proposal meets the letter of the code.  Also, even if the applicant wished to voluntarily pursue one of the alternatives you suggest (payment towards an RPZ, bicycles or bus passes) we have no authority to accept one of these in lieu of a code-required parking space.
I will share your message with code development staff as you raise points I think they may want to take into consideration as they prepare future amendments to the Land Use Code.  However, any changes made could not be applied retroactively to this project.
I have checked into a few of the specific questions you have raised.  You are correct that a small portion of the property is mapped as an Environmentally Critical Area due to steep slope, however, one of our geotechnical experts has concluded that the proposed work is far enough away from the ECA that the ECA is not of concern for our review.  I have also checked with our tree expert.  Based on the information available to us, including the site plan submitted and our aerial photos, there does not appear to be a grove within the meaning of our standards (our Director’s Rule 16-2008).  Addition information has been requested from the applicant regarding the individual Douglas fir tree you have asked about.
I know this isn’t the answer you hope for, but I hope it helps to clarify the scope of our review.  You may view the Land Use Code provisions and Director’s Rules mentioned in this message online at and
Andy McKim
Land Use Planner – Supervisor
From: Nancy Rottle <>
Subject: Re: Project 6376676
Date: December 23, 2013 1:07:24 PM PST
To: “McKim, Andy” <>
Cc: “Lofstedt, Emily” <>

Hello Andy,

Thanks for your response. I do have several questions that I would love to discuss with you, but first it would help me to understand the basis of the 5 “code-required parking spaces.”  If the existing code were applied without any discretion, wouldn’t DPD have needed to require 8 parking spaces for the 8-unit apartment?  How was the opinion rendered that 5 spaces were adequate, if not at the discretion of DPD?  Why 5 and not 4, or 7, or 8?
Secondly, the site with the proposed location of the garage is in approximately the center a mapped critical area, and the garage would need to be built upon that steep slope, so I do not understand how the geotech could have reasonably made the decision that the proposed work (of the garage) is “far enough away from the ECA” — this is simply impossible.
Also, there are indeed (8) 12″ diameter trees within a connected canopy of trees, including the Douglas fir in question, and there are significant trees missing on the applicant’s survey even adjacent the property line. What would be required to verify this possibility?  Do I need to go to the expense of hiring a licensed surveyor, or can I map them myself? (I am a licensed landscape architect).
Thank you for your assistance and I do apologize for causing you any trouble — I’m sure you are quite busy.  However, this issue of codes and interpretation of codes that are counter to adopted policies (and with good planning principles) should be of concern to all in DPD and to our elected leaders.  I am grateful that you will  forward this example of Seattle’s codes being essentially out of compliance with City policies to code development staff.
I would appreciate a response from you with regard to my above questions, and I would also still like to talk with you via a phone call if you can be available.
Nancy D. Rottle, RLA, ASLA

Associate Professor, Department of Landscape Architecture

Director, Green Futures Research and Design Lab
ScanlDesign Endowed Chair in Built Environments
Adjunct Associate Professor, Departments of Architecture and Urban Design and Planning
College of Built Environments
Box 355734  University of Washington
Seattle, WA 98195-5734
voice 206.685.0521
From: Nancy Rottle [
Sent: Monday, January 06, 2014 10:12 AM
To: McKim, Andy
Cc: Sugimura, Diane
Subject: Fwd: Project 6376676
Hello Andy,
I know the last two weeks have been holiday, but I haven’t heard back from you and would still like to discuss the City’s requirement that a single car garage be built in an Environmental Critical Area, which will remove parking spaces from the street (which I’ve just had confirmed is two spaces rather than one) and require the removal of a large (25″ DBH) Douglas Fir.  I’ve also gotten an opinion that the removal of the fir and construction of the parking garage will jeopardize my adjacent 24″ fir.  There is also the likelihood that the 25″ fir that would need to be removed would be considered an Exceptional Tree as it is part of a connected group of trees greater than 12″ DBH.
Is there some recourse to this requirement by the City that there be a single car bunker garage constructed, which is counter to City policies regarding walkability, housing affordability, and urban forest stewardship? 
Can we please discuss the possibility of relieving this requirement?  
Thank you for your consideration,
Nancy Rottle, RLA
On Jan 6, 2014, at 12:22 PM, McKim, Andy wrote:
Hello, Ms. Rottle.
Sorry for the delay; I have been waiting for additional information about the trees.  A staff member with expertise in that area will visit the site this week.
Our maps of steep-slope Environmentally Critical Areas are advisory, and we rely on additional topographic information that is available to us.  Although there is a steep slope mapped in the vicinity of this site, our geotechnical engineer has evaluated the proposal and determined that the work is not in a steep-slope ECA.  From looking at our maps, it appears to me that the steep slope on this property is minor and likely the result of grading for the street, in which case it would likely be exempt from steep-slope ECA standards under Seattle Municipal Code Section 25.09.180.B.2.b.
Regarding the number of parking spaces required to be provided on the site of the building:  We determined that the east portion of the property, fronting on Carr Place N, could qualify as a separate legal building site and be separately developed in accordance with a lot area exception provided at SMC 23.44.010.B.1.d.  However, under that section, if a parcel has been used to meet the legal parking requirement for a building on a neighboring parcel, that parking must be replaced on the same parcel as the building it serves in order to free the other lot up for separate development.  The general code requirement for an eight-unit building would be eight spaces.  The parcel fronting on Carr Place is developed with a garage and a surface parking area.  At times it appears that more than five cars have been parked there, but we determined that the area could accommodate only five spaces meeting code standards.  For that reason the legal building site approval was conditioned on the relocation of five parking spaces.
Although I understand your point that provision of a new curb cut from Ashworth Avenue effectively eliminates street parking, we cannot prevent the applicant from taking access to parking in that manner, so long as code development standards are met.  There also is no means, under the code, for us to waive a portion of the parking requirement in order to prevent such a curb cut.  The applicants could seek a variance from the parking requirement, but we cannot compel them to do so, and there is no assurance that a variance would be granted if applied for.  In recent years the City has reevaluated some of its parking requirements, and I anticipate that this will continue to be a subject of discussion.  I will pass the points you have made along to our code development staff for their consideration as codes are revised.  However, our review of this individual project must be based on whether it complies with the standards that are now in the code.
Andy McKim
Land Use Planner – Supervisor
From: Nancy Rottle [] 
Sent: Monday, January 06, 2014 12:55 PM
To: McKim, Andy
Cc: Sugimura, Diane; Lofstedt, Emily; nancy rottle
Subject: Re: Project 6376676
Hello Andy,
Thanks for your response. I still have a few questions:
With regard to the code requirement for the number of parking spaces, as you indicate it is 8 spaces, which the apartment building now provides.  Six (6) of these spaces are in the parking lot and are marked as such (and I have often observed seven cars parked in the lot.)  There are six cars parked there right now, with plenty of room to spare.  As you noted in your Opinion Letter of July 29, only five spaces in the parking lot would be legal based upon the need to back into the non-arterial of Carr Street. However, since there are also two spaces in the garage — which is not served by the same drive as the parking lot — why aren’t these spaces required to also be replaced?  Your letter states that these spaces would “need to be relocated to a legal space on Lot 22 in order for Lot 7 to be freed for separate development.”  If you are following the letter of the code, why aren’t 7 spaces required?
On the other hand, many multi-family projects in Seattle these days are being exempted from providing parking.  Can you tell me how this is made possible?
Also, can you please tell me when the staff member with tree expertise will be visiting, or put me in touch with that person, so that I can arrange to be there?
Thank you,
From: “McKim, Andy” <>
Subject: RE: Project 6376676
Date: January 6, 2014 2:33:01 PM PST
To: Nancy Rottle <>
Cc: “Sugimura, Diane” <>, “Lofstedt, Emily” <>, nancy rottle <>, “Amrhein, Seth” <>
Hello, Ms. Rottle.
We counted the garage spaces when we determined how many legal spaces could fit on the portion of the property that had been used for parking.
There have been specific code amendments eliminating parking requirements for residential uses in urban centers or station area overlay districts, and in commercial or multifamily zones in urban villages close to frequent transit (Section 23.54.015 Table B) and for single-family residences in Single Family zones on lots less than 30 feet wide or less than 3,000 square feet in area with no alley access (Section 23.54.015.B.1.5.)  However, none of these circumstances apply to the property you have asked about.
Seth Amrhein is the staff member who will be visiting the site to observe the trees.  It is possible that he will be there today.  His number is 206-386-1981.
Andy McKim
Land Use Planner – Supervisor

Current Regulations Regarding Removing Trees on Private Property in Seattle

Here is what is currently in place as to removing trees in Seattle as of November 2013.  .

The “interim” tree ordinance passed in 2009 by the Seattle City Council is the governing ordinance. It came about because of the loopholes in removing trees in Seattle exposed by two citizen battles.  Protecting trees in the Northwest Grove at Ingraham High School in North Seattle and saving Waldo Woods in the Maple Leaf area.

Here is the Seattle City Council’s press release when they passed the interim ordinance:
This lists a fine of up to $5000 for violating the ordinance.

Actual ordinance: Council Bill 116404

Three  DPD  memos further explain the requirements:

Tree Protection Regulations in Seattle:
This states that no exceptional trees may be removed on developed property over 5000 square feet.

Designation of Exceptional Trees:
This one clarifies what an exceptional tree is and has a list of tree sizes for trees.  For example it states that for Douglas firs,  trees larger than 30 ” in diameter are exceptional and may not be removed unless they pose a hazard.

Seattle Permits -Removal of Hazard Trees – includes Hazard Tree Removal Application

The interim ordinance  is clearly lacking as large trees continue to be  cut down without regard for their size.  There is also no requirement for replacement trees.

Seattle has been working on updating the tree ordinance for four years now.  The Seattle Department of Planning and Development has come up with several drafts which have not been acceptable to members of the public and others.  DPD’s approach has been contrary to the direction of the Seattle City Council which wanted stronger regulations to protect trees.DPD currently does not require or enforce getting permits to remove most trees in the city.  They have operated what they call a complaint system which doesn’t work because there is no way to stop someone cutting down a tree and a complaint after the fact doesn’t save any trees.

DPD’s draft proposals for this reason were also not viewed  favorably by the Seattle Urban Forestry Commission.  The next draft of  a proposed tree ordinance was to be released in Jan or Feb 2014.  This is now most likely up in the air as the current Mayor, Mike McGinn, was defeated in the Nov election and  the new Mayor, Ed Murray,  is likely to view this issue with fresh eyes..

Any new ordinance to be successful needs to require permits to remove any tree over 8 – 10  inches in diameter and require a  two week posting of all proposed tree removals so any conflicts can  be addressed. Also unless replacement of trees cut down is required, either on site or off site, Seattle will continue to lose canopy.  This is despite the Seattle Comprehensive Plan stating a yearly goal of no net loss of canopy..

Cities like Portland, OR; Vancouver, WA, Lake Forest Park,WA and Kirkland, WA currently require permits to remove large trees. Permits are currently required by SDOT to prune or remove trees in the right of way and by DPD to remove hazard trees (although  there is little or no evidence this is working).