Monday, May 6th at 5 PM is the Deadline to Submit Comments on the EIS and One Seattle Comprehensive Plan drafts

Under the State’s Growth Management Act, cities and counties have to update their 20-year Comprehensive Plans for growth every 10 years. Seattle is in the process of updating its 2045 Plan now. The 2045 draft One Seattle Comprehensive Plan and draft Environmental Impact Statement (EIS)were released in March. See all documents related to the One Seattle Comprehensive Plan here.

The deadline to submit public comments on these plans is this Monday May 6th at 5 PM.

E-mails are needed to the city urging a higher priority to saving Seattle’s existing trees and canopy which are providing climate resiliency and health benefits now rather than allowing developers carte balance to clearcut lots and pay a fee for the city to plant trees elsewhere that decades later, if they survive, may provide benefits.  Yes, we need housing, but we need trees to provide healthy neighborhoods where people live and work. We can have both if we plan and work together to keep Seattle the Emerald City.

Seattle needs to build some 100,000 new housing units, according to state projections, to meet growth over the next 20 years. They also must comply with new state legislation requiring them to allow 4 plexes across the city and six-plexes within 1/4 mile of frequent transit.

The city has prepared 5 alternative development scenarios which are presented in their draft EIS. This e-mail is to provide you with some information on how the plan will impact Seattle’s trees and urban forest and help you pick which alternative you would like to see the city choose.

We are asking you to send one e-mail responding to two things – which alternative you prefer and cutting and pasting our suggested questions for more details on what the impacts will be of the different scenarios.  After evaluating the public comments, the city will pick one alternative and do a final EIS on it.

Click on this link to see the draft EIS Proposal and Alternatives. Discussion with maps of the alternatives goes from page 2-22 to 2-55.

Here is a summary of housing units proposed with the 5 alternatives:

Alternative 1 -no action baseline – 80,000 new housing units
Alternative 2 Focused – 100,000 housing units
Alternative 3 Broad -100,000 housing units
Alternative 4 Corridor 100,000 housing units
Alternative 5 Combined 120,000 housing units

Here are some selected comments on the 5 Alternative Choices and impacts on plants and animals from the draft EIS:

Alternative 1 – No Action  – ” would be expected to result in a lower potential for development-related tree canopy cover loss than any of the action alternatives, both citywide and in the individual analysis subareas. Based on the amount of area where development or redevelopment may result in losses of vegetated areas, Alternative 1 would also likely have the lowest potential for short-term and long-term decreases in the diversity and/or abundance of plant and animal communities in areas where development or redevelopment projects occur.”

Alternative 2 – Focused – “Under Alternative 2, about 3,000 acres of currently lower-density parcels may be converted to higher-density uses(neighborhood centers), the smallest area of conversion among the action alternatives (Exhibit 3.3-4). Growth would be focused in neighborhood centers. Among the action alternatives, Alternative 2 would thus have the lowest potential for development-related impacts to vegetation (including loss of tree canopy cover) citywide.”

Alternative 3 – Broad – “Compared to Alternative 2, a substantially larger area of currently lower-density parcels— approximately 32,500 acres—maybe converted to higher-density uses in urban neighborhood areas (Exhibit3.3-4). Such parcels would be distributed throughout the city.  Based on the amount of area where currently low-density parcels may be converted to higher density uses, Alternative 3 would be expected to have the higher potential for loss of tree canopy (and, by extension, a higher potential to impede progress toward the City’s canopy cover goal) than Alternatives 2 and 4”.

Alternative 4 – Corridor – “The area of currently lower-density parcels that may be converted to higher-density uses in corridor areas would be approximately 20,500 acres—more than under Alternative 2 (3,000 acres) and less than under Alternative 3 (32,500 acres) (Exhibit 3.3-4).  The distribution of the areas likely to experience development-related canopy cover loss would be less focused than under Alternative 2 and less widespread than under Alternative 3. As a result, in areas with relatively high proportions of existing canopy cover, the impacts of Alternative 4 would also likely lie between those of Alternatives 2 and 3. Among the action alternatives, Alternative 4 would thus result in a moderate potential for loss of tree canopy cover.”

Alternative 5 – Combined – “Under Alternative 5, approximately 33,700acres of currently lower-density parcels may be converted to higher-density uses—more than under any of the other alternatives (Exhibit 3.3-4).14 These areas would be distributed throughout the city. As such, all areas with relatively high proportions of existing canopy cover would be likely to experience additional canopy loss.  Even though Alternative 5 would convert more lower-density parcels to higher-density uses, the potential for development-related canopy cover loss would likely be lower than under Alternative 3. This is because Alternative 5 would focus more development in neighborhood centers and corridors, rather than distributing it in urban neighborhoods throughout the city. Development or redevelopment projects in neighborhood centers and corridors would be expected to result in less canopy cover loss than would projects in areas classified as urban neighborhoods. Alternative 5 would thus have a lower likelihood than Alternative 3 of impeding progress toward the City’s canopy cover goal, but a higher likelihood than Alternative 2 or Given the highest number of homes produced and the broadest range of areas affected, Alternative 5 would tend to have the highest potential for loss of tree canopy.”

Alternative 1 is do nothing different and has the least houses produced. It is not being considered as a growth option.
Of the 4 growth alternatives, Alternative 5 would have the most canopy loss, then Alternative 3, then Alternative 4, then alternative 2 has the least canopy loss of the 4 alternative growth alternatives.

Alternative 2 and 4 concentrate growth more in existing built up areas or along corridors and have less canopy loss as a result.

*Pick which option you support and make this your first comment. Feel free to add your own comments to support your decision.

*Second comment section. Copy and paste below items:

Suggested questions and comments.  You can also add our own comments and links to news articles and urban forestry and climate science articles that help explain your concerns and position. See plants and animals section in draft EIS pages1-33 to 1-39  for more information.

P 3-3-29-30 Please analyze the potential impact of the 5 options on Seattle plants and animals. This is a Seattle EIS, not a regional or state EIS.  Saying “unlikely to result in appreciable impacts on regional populations of plants or animals”‘ and “none of the alternatives would be expected to result in impacts that would reduce the likelihood of survival or recovery of a plant or animal species in the wild” is avoiding commenting on the specific impacts on Seattle plants and animals.

• p 3-3-30 Saying that “none of the action alternatives would be expected to have significant, unavoidable adverse impacts on tree canopy cover.” is not backed up by facts but speculative at best. The new tree protection ordinance increases the potential for tree removal and loss in several ways. One is that all the zones that can undergo development under the ordinance state that the newly defined “basic tree protection area cannot be modified” despite Portland, Oregon and the Northwest Society of Arboriculture saying it can be modified to save trees. This and current guaranteed lot coverage of 85 – 100% for multifamily lots and above and rezoning to occur in the Neighborhood Residential zone means more trees, especially large ones, will be removed.   What is your estimation of potential canopy acreage loss (over 5 year periods consistent with the city’s canopy studies) with increased development and density in each alternative?
• What is your estimation of tree planting needs and a time frame to replace the equivalent lost canopy area and volume (over 5 year periods as tracked by the city’s canopy studies)?
• Is canopy area and volume replacement equivalence even possible with replanting since removed trees, if not removed, would have increased growing according to scientific articles?What is the acreage available and suitable for planting trees in each of the following public areas – the city’s right of ways, Natural Areas, and Developed Parks?
• How many trees and what size will need to be planted in these areas every year to make up for trees and canopy removed during development on lots? How many trees and what size for all canopy loss?
• What is the available acreage available to plant trees on private property?
• When will it be possible to reach the 30% citywide goal?
• What potential is there for more than 30% tree canopy in Seattle over time?
• Is up to 40% canopy coverage, over time, as proposed in the previous Comprehensive Plan possible?
• Canopy volume, especially of coniferous trees during our rainy season, are critical factors in reducing stormwater runoff. What is the projected loss in canopy volume over the next 20 years as big conifer trees are removed?
• What is the projected increase in stormwater runoff and what costs are associated with on site and alternative city water management policies of stormwater and pollutant runoff as a result?

As to commenting on other tree potential mitigation measures, add:

• Amend the Tree Protection Ordinance to require developers to maximize the retention of existing trees 6″ DSH and larger.
• Give SCCI Director the ability to ask for alternative site designs to save trees.
• Support building higher and building attached units to allow for tree retention and planting areas like Portland, Oregon has with 20% areas for multifamily and 40% for its 1-4 unit family zone.
• Amend Tree Protection Ordinance to require ordinance to apply to all city land use zones.
• Remove the “basic tree protection area” loophole in the Tree Protection Ordinance that allows developers to unnecessarily remove almost all large trees on lots.
• Require developers to submit a Tree Inventory and

Please send your comments on the draft EIS to:

PCD_CompPlan_EIS@seattle.gov 
and council @seattle.gov

Comments on the draft Comprehensive Plan itself should be sent to:

OneSeattleCompPlan@seattle.gov or Use Engagement HUB

Just released  Seattle Urban Forestry Commission  – Adopted UFC feedback on draft one Seattle Plan