Quick response needed – Deadline Monday Nov 30th.

For more background, here are some suggested comments. Feel free to copy and paste.

The draft Seattle 2020 Urban Forest Management Plan (UFMP) needs to be strengthened to more aggressively protect Seattle’s existing trees and urban forest citywide.

The first Seattle Urban Forest Management Plan in 2007 adopted a goal of 30% tree canopy cover by 2037 for Seattle. The 2016 Seattle Tree Canopy Assessment has Seattle’s tree canopy at 28%. But the 30% canopy goal is still set at 30% for 17 years from now. Meanwhile Tacoma in 2018 determined they had a 20% tree canopy cover and set a goal of getting to 30% by 2030.  Seattle needs to adopt a more aggressive goal and join Tacoma in setting 2030 as their target date to reach 30% tree canopy.

While tree canopy cover is an important metric to track trees, the data collected should also include 3-D slices to get an idea of canopy volume changes as well as tracking loss of large trees which provide the most ecosystem services to the city. Periodic 5 year assessment of canopy is an important tracking metric.

The 2020 UFMP needs to update the statement that the “replacement value of Seattle’s existing urban forest … is close to $5 billion dollars” to reflect current values. The figure of $4.99 billion dollars was from a 2012 Seattle’s Forest Ecosystems Values report when the tree canopy was estimated at 23% and is outdated. It would also greatly help to conduct a Natural Capital Assessment to get a better grasp on the ecosystem service value of the urban forest to the city.

The 2020 draft UFMP devotes only one page to the “importance of urban trees” while the 2013 Urban Forest Stewardship Plan devoted 5 pages. However, five pages are devoted to “challenges” and “competing uses.” Please devote more explanation to the benefits and documentation of the importance of urban trees like was done in the 2013 Plan.

The following clear Priority Actions listed in the 2013 Plan have been removed. They should be added back with their more detailed explanation.

• Priority Action – “Preserve existing trees. Because it takes decades for most trees to reach their ultimate size, trees already growing in Seattle generally provide immediate and ongoing benefits that cannot be matched by small/younger placement trees.” …Focus especially on Evergreen Trees…Mid-large trees…Forests, woodlands and tree groves…Unique wildlife habitat. Priority Action -Maintain existing trees…
• Priority Action – “Restore…”
• Priority Action – Plant new trees…”
• Priority Action – Increase awareness of the value and proper care of trees.

Eighteen Action items are mentioned in the current draft. One of the most important items is listed last and is not bolded as a priority item. “Update the City’s tree protection regulations.” Seattle City Council Resolution 31902 specifically says, “Submit legislation in 2020 for consideration by the Council.” The specific lack of emphasis on the need to update SMC 25.11, the City’s Tree Protection Ordinance, is unfortunately consistent with the city’s current 11 year delay in modernizing and updating the ordinance.

Unlike many other cities, in Seattle

• no permits are required to remove most trees on private property,
• tree replacement by developers of exceptional trees and trees over 24 inches DBH even when required by law since 2001 are usually not replaced,
• no in lieu fee is in place if trees cannot be replaced on site; significant trees removed are not required to be replaced,
• maximizing retention of existing trees during development is not required,
• arborists are not required to be licensed and sign off on knowledge of tree regulations,
• a separate detailed tree inventory prior to any development is not required and the list goes on and on.

Resolution 31902 passed by the Seattle City Council in 2019 lists a series of regulations and actions to be considered on protecting trees, however a complete list is not in this Plan. For example, the adoption of an in-lieu fee if trees cannot be replaced on site, would help to provide needed funds to plant trees in “low-income and low canopy neighborhoods.” As the 2016 City Canopy Study confirmed, in “Census tracts with lower counts of tree canopy more of the population tends to be people of color and lower income.” Portland, Oregon just amended their tree ordinance to charge a fee in lieu of $450/inch for all trees removed by developers that are over 20 inches DSH. In 2018 when the fee in lieu was for trees over 36 inches DSH, they collected some $1.44 million for their Tree Removal and Replacement Fund.

Key activity metrics conspicuously lack tracking tree removal and only note tree planting.  All metrics should be tracked on a quarterly basis and publicly posted on the city website. SDCI is not included in tracking tree replacement (or tree loss) in key activity metrics, even though this is mentioned elsewhere as one of their key priorities. Since all trees are supposed to be on a site plan for development, the information of existing trees, trees removed, trees replaced, in lieu fees paid and the location where replacement trees were planted should all be tracked.  As noted, SDCI’s private property oversight covers some 72% of the trees in Seattle and should be the entity doing the most tracking of tree retention, loss, and replacement, both during development and outside of development. They should do this by requiring permits to remove and replace trees as many other cities have been doing for years.

The elephant in the room, but not discussed in detail in the draft plan, is the push for increased housing density and construction in the city. Lots are literally being clearcut across the city. Many trees are being lost, including large old trees that provide the most benefits to people living and working in the city. The city and this plan are not attaching a cost to this loss of trees and their benefits or looking for ways to both build and protect more trees. SDCI is not even willing to incorporate the phrase requiring developers “to maximize the retention of existing trees” in landscaping plans. Meanwhile Portland, OR in 2018 amended their tree ordinance to require permits to remove any tree outside the building development footprint to reduce the unnecessary loss of existing trees. Seattle should follow suit and also aggressively work with builders to develop alternative building design plans that could save more trees.

It is a long overdue priority to address the race and social justice and environmental inequities occurring in communities of color and lower income communities. Inclusive community involvement is a vital part of the solution, but the same development pressures facing areas with lots of trees also affect these communities. As the 2013 Urban Forest Stewardship Plan noted, replanting of trees to compensate for large trees cut down will take decades to compensate for the benefits lost, no matter where they are planted in the city. The loss is even more significant to the communities that have low tree canopy to start with.