Calls for Action on Two Upcoming Issues Affecting Portland’s Trees!
Together with other Portland tree, nature, climate, and equity groups, Trees for Life Oregon is ratcheting up pressure on the City Council to address climate crisis with policy and practice changes, not just rhetoric. Help us keep up the pressure by speaking up for existing large trees and space to plant new ones at these important upcoming hearings.
HEARING #1
On Wednesday, May 18 from 6 p.m. to 7 p.m., the Water Bureau is holding a public hearing on its new administrative rule that contains a provision requiring that trees be 10 feet away from water pipes that are 24-inches in diameter or larger.
SE Division Street and 28th Avenue. Photo: Doug Klotz
Background: An administrative rule does not require City Council approval. In fact, the Water Bureau has been implementing this rule since 2016. The photo shows an example of the concrete-jungle result of this rule as it applied to the Division Streetscape Project. This rule could effectively eliminate a significant portion of street-tree planting spaces in Portland, potentially in already tree-deficient areas that are low-income and more racially diverse. Read the draft administrative rule here. The relevant section is on p. 14, #9. Footnote 1 states that the Portland Water Bureau, with Urban Forestry, will “determine if different design methods or construction techniques are possible to allow an exception” to the 10-foot separation rule. But this process presents a barrier to devising creative techniques up front that would allow trees to be preserved or planted. (Note that Appendix J “Trees and Water Assets” is listed on p. 3 but does not appear in the document. According to Urban Forestry, that appendix will come at a later time, after the Bureau and UF develop a better toolbox to help alleviate Water Bureau’s concerns.) Finally, also on p. 14, #9, the Portland Water Bureau Standard Drawings refer to P-846, which contains a note stating that trees to be planted 10 feet from a water pipe 24 inches or greater “must be a species expected not to exceed 12 inch diameter breast height (DBH) at maturity.” Like the 10-foot-separation rule itself, this size limit on newly planted trees will, in effect, undermine the City’s efforts to increase canopy.
Action needed: Register to testify at the Wednesday, May 18, 6-7 p.m. Zoom hearing at this link (scroll down to the blue banner link to register), which also contains more information. Keep your testimony to five minutes or less. Or submit written public comments by 5 p.m. on May 20 to hellowater@portlandoregon.gov.
Suggested Talking Points:
—Ask the Water Bureau to justify this rule. According to Urban Forestry staff, this rule assumes that street tree roots grow in all directions as they would in an open field, but urban trees face constrictions that keep most roots out of streets. It’s unusual for tree roots to grow under streets because that area is compacted; roots seek favorable air and water conditions, which they find under sidewalks and in adjacent yards. “When we see excavations in streets, we typically see roots end at the curb line,” says UF staff. Also, Water Bureau concerns that trees would block access to emergency water pipe repairs appear unwarranted, because Urban Forestry says that it removes street trees or cuts roots on an emergency basis for other bureaus and will do the same for Water Bureau as needed. Moreover, says Urban Forestry, newly planted trees are carefully chosen not to cause sidewalk damage, let alone under-street pipe damage.
—Ask the Water Bureau to defer considering all tree-related provisions—the 10-foot separation rule, the 12-inches-at-maturity rule, all other tree-related provisions, and the yet-to-be-drafted Appendix J—until it shares analysis with the City and the public showing why these provisions are needed. And ask the Water Bureau to share with City bureaus and the public information about where the rule’s impacts will occur—along what streets and across how many tree-planting spaces—as well as the provision’s potential impacts on future tree canopy and how these impacts could exacerbate existing tree canopy inequities and associated effects such as heat-related health and mortality.
HEARINGS #2 AND #3
On Thursday, May 19, at 9:30 a.m. the Urban Forestry Commission will be holding a public hearing on proposed technical amendments to Title 11, the tree code. Please support these amendments.
And on Tuesday, May 24, at 5 p.m., the Planning and Sustainability Commission will also be holding a public hearing on these same proposed technical amendments to Title 11. Please testify at one or both of these hearings and make sure to send (the same) written testimony to both commissions.
Background: Portland Parks & Recreation’s Urban Forestry is proposing technical amendments to Title 11, the tree code. These amendments constitute phase 1 of a multi-year, 3-phase initiative to update the Urban Forest Management Plan that informs the tree code and then to revise the code itself. The scope and impact of these technical changes are not as significant as the substantive amendments we hope will be considered in a few years when the City is slated to undertake broader code changes. However, we urge you to support the work that Urban Forestry is putting into these technical changes. Read the proposed amendments and learn more here.
Action needed: On Thursday, May 19, at 9:30 a.m., testify at the Urban Forestry Commission Zoom hearing on the proposed amendments. To provide oral testimony, sign up by Wednesday, May 18th at 3:30 p.m. by emailing urbanforestrycommission@portlandoregon.gov. The Zoom link can be found here. Or email written testimony to urbanforestrycommission@portlandoregon.gov with "Title 11 Amendments" in the subject line. Written testimony must be received by the time of the hearing and must include your name and address.
And/or on Tuesday, May 24 at 5 p.m., testify at the Planning and Sustainability Commission’s Zoom hearing on the same code amendments. For oral testimony, you must register here by 5 p.m. on Monday, May 23. The start time for this agenda item will be shared once confirmed at https://www.portland.gov/bps/psc/events. Email written testimony to the Planning and Sustainability Commission at psc@portlandoregon.gov with "Title 11 Amendments" in the subject line. Written testimony must be received by the time of the hearing and must include your name and address.
Suggested Talking Points:
—Thank the city and UF staff for investing in Title 11 updates that will make it more effective in helping preserve and enhance our urban forest. Trees can save lives as we face climate crisis, and recent studies (here and here), show city canopy loss.
—Recommend approval of these amendments. They clarify that trees are critical infrastructure and they improve code transparency and enforceability.
—Ask that the City Council initiate and fund a comprehensive Title 11 update sooner rather than later. That update is currently scheduled to start in 2024. There’s no time to waste! Every day Portland is losing precious large trees because of a weak, outdated code. Urge the UFC and PSC to ask the City Council to move forward quickly to update its 2004 Urban Forest Management Plan, a process slated to start in mid-2022 that will guide the subsequent tree code revisions.