Send an e-mail regarding the SEPA Analysis of Seattle’s draft Tree Protection Ordinance

The Seattle Department  of Construction and Inspections (SDCI)  issued a Determination of Non-Significance for their draft Tree Protection Ordinance update.
We are not impressed with their SEPA checklist evaluation that removing big trees and then planting little trees is a possible way to increase tree canopy.
They set a date to comment on the SEPA document and then said the comment period was extended for a month and then said that the date you can appeal the DNS is based on the first comment period, not the extended one. Many people, including us, thought once they heard the comment period was being extended thought they had more time to respond.
AN appeal to SDCI Director Torgelson, said sorry for the confusion but the appeal date stays the same. Seems SDCI really doesn’t care that they presented a contradictory commenting process that confused people and disengaged people from the process. Frustrating – yes.
Despite this, let’s move on – send in your comments  as soon as you can.
Here is some information to help:
 Washington State Dept. of Ecology -SEPA Review for Non-project proposals
Here is a  list of possible issues to cite in your comments. Problems with SDCI’s DNS – SEPA process:
  • does not credibly explain how removing large older trees and replacing them with small new trees can increase canopy.
  • does not discuss potential loss of tree groves and associated loss of bird habitat by not including street trees in definition of a grove
  • does not discuss impact of not including industrial zone or downtown areas which are high areas of urban heat island impact
  • does not mention that 2022 urban canopy results are being evaluated right now and will soon be available to compare tree loss with 2016 canopy study
  • does not discuss negative impact of reducing data tracking lost by excluding trees 6-12″DBH trees from developer site plans
  • Resolution 31902 asked to require replacement of 6″ DBH and larger trees. SEPA does not discuss numbers or percentage of trees that would cover at 6’DBH and larger versus those 12″ DBH and larger It’s 18% at 12″ BH versus 45% at 6 inches
  • does not discuss or define what normal and routine pruning is and its impact on tree canopy
  • does not discuss problems and costs with city entering data from site plans into Accela database versus requiring developers to enter data via Excel spreadsheets as Portland, Oregon does. Accompanying documents claim it is hugely expensive to process tree permits without discussing what costs are elsewhere for other cities
  •  Does not note that many other cities locally require permits to remove 6″ DBH trees.
  • does not mention or provide evaluation of data collected from last several years on tree retention, tree loss and replacement and entered into Seattle Accela database system
  • does not evaluate current or proposed ordinance’s impact on reaching 2037 30% tree canopy cover or aspirational 40% in current comprehensive plan.
  • Does not note there is no plan on how to reach 30% canopy goal by 2037 in place
  • removes black cottonwood, bitter cherry, and Lombardy popular, from tree grove protection but does not discuss how this will impact canopy goals or wildlife.
  • Does not discuss impact removing trees during bird’s nesting season
  •  does not mention or evaluate impact of up zoning in Seattle for light rail as present and future plans will affect tree loss retention
  • does not evaluate pacific flyways for migrating birds or other habitat or trailways for wildlife that are affected by tree loss
  • item 7 does not mention preparation of comprehensive plan and possible middle housing legislation which would severely impact tree canopy.
  • item 11 says there is no specific proposal site or development proposal. Should state history of development in Seattle and expected growth of housing and other development as it impacts tree loss and replacement
  • Study cited on “DBH Distribution in America’s Urban Forests: An Overview of Structural Integrity{” noted in its text that it included no cities in the Pacific Northwest footnote page 19
  • table on page 19 and reference to number of trees affected by proposals does not include total number of trees in city The estimate of 175,000 trees -for single family, multiple family and commercial does not really match up with statement on OSE website and Seattle’s Forest Ecosystem Values, which says Seattle has 4.35 million trees and treelike shrubs. Some 60% of Seattle’s tree canopy is currently in single family zones.
  • Does not mention 2 statistically valid polls each of whom with over 600 respondents,  showing strong support for updating Seattle Tree Ordinance while citing their input from 29 listening session participants (8 of whom were from the building community and 2 additional homeowners who were architects)   and feedback from 6 representatives of BIPOC and low-income groups.
Pick and choose from the above. Feel free to write in your own words what to send in.
Note as above that they did not adequately analyze many issues and possible impacts of the draft ordinance
Urge they do an Environmental Impact Statement for the draft ordance.to better research and explain the impacts.
Send comments to gordon.clowers@seattle.gov as soon as you can for the DNS on the SEPA
Steve Zemke
Chair – Tree PAC
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