From: Steve Zemke2023 11:54 PM To: gordon.clowers@seattle.gov <gordon.clowers@seattle.gov>; Nathan Torgelson <nathan.torgelson@seattle.gov> Subject: Comments on Addendum to 2023 SEPA Determination of Non-Significance Tree legislation March 2023
Sent: Friday, April 7, Dear Gordon Clowers and Nathan Torgelson,
Description:
- item 2 does not list other zones that can remove 3 tree per year. Just saying all other zones is not something people can readily understand? Is it 1 zone or 5 zones. What are the other zones?
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item 3 – vague language -“or similar improvements associated with development” These items should be clearly identified.
Regarding zoning capacity calculation in dense zones;
Washington State is on the verge of state mandated upzoning by the state legislature which would mandate 4 plexes in all zones and up to 6 plexes in certain circumstances in Seattle and a number of other cities. No mention is made regarding the potential impact on trees that will occur if this happens. Seattle’s neighborhood residential zones currently is at 34% canopy cover while multifamily is at 23%.
The 2021 City of Seattle Tree Canopy Assessment Final Report in Appendix A notes notes that the neighborhood residential zone has 7034 acres of canopy while the multifamily zone has 933 acres.
Appendix B Table 2 notes that redeveloped parcels in the NR zone lost 33.6% of its canopy and redeveloped parcels in the multifamily zone lost 49.5% of its canopy.
Considering the likelihood of the state rezoning the NR to a multifamily zone the following statements are not accurate if HB 1110 or similar upzoning legislation passes in Olympia.:
Fact statement by the Addendum -The city’s research for the prior proposal indicated that about 92% of the estimated properties with trees greater than 24-inches diameter are located in neighborhood residential zone and 6% in lowrise and 2% in commercial.
You assume that multifamily and commercial zones will face “greater long-term pressure for redevelopment than NR zones.”
Based on the momentum for passage of HB 1110 that is simply not true.
You state that the 92% of properties with larger sized trees “may experience a lesser pressure.” Again this is just not likely. Builders are pushing up zoning of single family zones statewide and nationally. It’s already happened in Oregon. And its likely to happen in Washington.
The guaranteed 85% development area in the Ordinance will shift to the current NR zone and you have not even mentioned this despite legislation in Olympia last year and greater momentum this year. Legislation has passed the House and is in Senate Rules.
Current code allows more flexibility in tree protection site by site. The change is what the builders want predictability that they can remove most of the trees on a lot and maximize their profit while Seattle’s canopy declines. If the state Legislature passes HB1110 , there is no way Seattle can reach 30% tree canopy citywide. It will over time descend into low 20’s % canopy cover with an ordinance that guarantees 85% canopy cover.
Tree covenants need to be for the life of the building, not the tree. The code elsewhere requires hazard tree to be replaced. That includes dead trees. The covenant should be considered a “tree planting area” for the life of the building.
This DNS should be rewritten to address the issues raised above as to the impact of the state potentially rezoning our NR zone to multifamily zone. This would have a significant environment impact. It is not an unknown possibility. The city needs to evaluate what would be the impact on the tree canopy in the city if the state rezones to allow 4 plexes and 6 plexes in Seattle’s current NR zone.
Tree covenants need to be for the life of the building, not the tree. The code elsewhere requires hazard tree to be replaced. That includes dead trees. The covenant should be considered a “tree planting area” for the life of the building.
Steve Zemke Chair Tree PAC and Friends of Seattle’s Urban Forest