DIR2008-00001 pik,01068-60
DIRECTOR'S INTERPRETATION
• . ;
t ARDi
DATE: February 26, 2008
CODE CHAPTER: 18.790 Tree Removal
TOPIC: How should the statement, "Protection is preferred over removal wherever
possible" in Section 18.790.030 be interpreted?
How can an applicant demonstrate that they have adequately considered
tree protection given code preference for protection over removal?
DIRECTOR'S INTERPRETATION:
I. Introduction
A tree plan is required when a development application is filed:
18.790.030 Tree Plan Requirement
A. Tree plan required. A tree plan for the planting, removal and protection of trees prepared by a certified
arborist shall be provided for any lot, parcel or combination of lots or parcels_ for which a development
application for a subdivision, partition, site development review, planned development or conditional use is filed.
Protection is preferred over removal wherever possible.
Historically, applicants have been required to identify all of the trees on the site, specify which will
be removed, and propose protection methods for those to be retained. Any or all trees could be
removed as long as they were appropriated mitigated.
This process does not prioritize protection over removal as required by Section 18.790.030.
In order to clarify the intent of the, "Protection is preferred over removal wherever possible"
requirement, a Director's interpretation is needed.
II. Interpretation
One of the primary purposes of Chapter 18.790 of the Tigard Development Code is to preserve
existing trees.
Therefore, a development application is required to demonstrate that the site analysis and
development plan protects the maximum amount of existing, viable trees (i.e. healthy and
sustainable individuals or stands).
The City recognizes that some tree removal is unavoidable in order to meet certain planning and /or
construction requirements as indicated in Section 18.790.010.
18.790.010 Purpose
C. Recognise need for exceptions. The City recognises that, notwithstanding these purposes, at the time of
development it may be necessary to remove certain trees in order to accommodate structures, streets utilities, and
other needed or required improvements within the development.
In order to determine that preservation of viable trees has been adequately considered, the tree plan
shall include a narrative that addresses the following:
1. How does the site, lot and /or building layout maximize tree retention?
2. How have improvements such as roads, driveways, utilities, and walkways been designed and
located to maximize tree retention?
3. Have tree compatible construction techniques been considered and utilized wherever
possible to maximize tree retention? (examples of tree compatible construction techniques
include but are not limited to tunneling for utilities, "no -dig" pavement installation, and use
of retaining walls in certain situations to limit root disturbance)
4. Is it possible to reduce the number of parking spaces to maximize tree retention?
5. Is it possible to reduce the total number of lots to maximize tree retention?
6. Could lot size averaging per Section 18.790.040(2) be utilized to maximize tree retention?
7. Could lot width and /or depth per section 18.790.040(3) be reduced in order to maximize
tree retention?
8. How have buildings and building footprints been designed to maximize tree retention?
9. Are offsite trees that may be impacted by development inventoried and adequately
protected?
10. Describe additional techniques not mentioned above that have /will be used to maximize
tree retention.
Failure to demonstrate that the proposed development will preserve viable trees wherever possible
may result in findings for denial of a development application.
This interpretation shall become effective immediately.
/
By: Tom Coffee
Community Development Director
Case Activity Listing 2/13/2009
` - G+ EL Case #: M11S2008 -00005 8:40:34AM
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M1S1020 Application received 3 /14/2008 None DONE ST 2/13/2009 The Home Builder's Association of
PLL Metro Portland Appealed the 2/26/08
Director's Interpretation of Chapter
18 790 -Tree Removal.
MIS1030 Case created 3/14/2008 None DONE ST 3/14/2008
ST
MIS1040 Planner assigned 10/1/2008 None DONE GBP PLL 10/1/2008
PLL
MIS1000 CASE REVIEW 5/13/2008 None HRNG GBP PLL 10/1/2008 5/13/08 public hearing is scheduled
MENU PLL before the City Council to consider
the appeal.
AT THE 5/13/08 PUBLIC
HEARING, THE COUNCIL
CLOSED THE PUBLIC HEARING
AND SCHEDULED 6/10/08 TO
RECONVENE TO REVIEW AND
DELIBERATE ON THIS ITEM
MIS1000 CASE REVIEW 6/10/2008 None HRNG GBP PLL 10 /1 /2008 6/10/08 public hearing is scheduled
MENU PLL before the Council, continued from
5/13/08
MIS2020 Approved 6/10/2008 None APRV GBP PLL 10/1/2008 On 6/10/08 the Council reconvened
PLL to consider this item and ultimately
concluded that the clarity of
interpretation of a Code that is v
could be construed as a "judge
making law from the bench" and that
it is vulnerable to a LUBA challenge
The Council pointed out that the
Tigard Tree Code will be completely
revised shortly following the
Comprehensive Plan update and thatg
that would be the proper place to
address this matter
A unanimous vote of Coucil present
was approved to uphold the appeal
Page 1 of 2 CaseActivity tpt
2/13/2009
Case Activity Listing
ACCEL/' Case #: M1S2008 -00005 8 40 34AM
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MIS2070 Case closed 10/1/2008 None CLSE PLL 10/1/2008
PLL
Page 2 of 2 CaseActivtty.rpt
DATE: 2/26/2008
CODE SECTIONS: 18.790.030
• 1 ; Tree Removal/Tree Plan Requirement
INTERPRETATION: TO CLARIFY THE INTENT OF "PROTECTION IS PREFERRED OVER REMOVAL
WHEREVER POSSIBLE" REQUIREMENT OF SECTION 18.790.030 - TREE PLAN
REQUIREMENT.
TOPIC: How should the statement, "Protection is preferred over removal wherever
possible" in Section 18.790.030 be interpreted? How can an applicant demonstrate that
they have adequately considered tree protection given code preference for protection over
removal?
I. INTRODUCTION
A tree plan is required when a development application is filed:
18.790.030 Tree Plan Requirement
A. Tree plan required. A tree plan for the planting, removal and protection of trees
prepared by a certified arborist shall be provided for any lot, parcel or combination of lots
or parcels for which a development application for a subdivision, partition, site
development review, planned development or conditional use is filed. Protection is
preferred over removal wherever possible.
Historically, applicants have been required to identify all of the trees on the site, specify
which will be removed, and propose protection methods for those to be retained. Any or
all trees could be removed as long as they were appropriated mitigated.
This process does not prioritize protection over removal as required by Section 18.790.030.
• In order to clarify the intent of the, "Protection is preferred over removal wherever possible"
requirement, a Director's interpretation is needed.
II. INTERPRETATION
One of the primary purposes of Chapter 18.790 of the Tigard Development Code is to
preserve existing trees.
Therefore, a development application is required to demonstrate that the site analysis and
development plan protects the maximum amount of existing, viable trees (i.e. healthy and
sustainable individuals or stands).
The City recognizes that some tree removal is unavoidable in order to meet certain
planning and /or construction requirements as indicated in Section 18.790.010.
18.790.010 Purpose
C. Recognize need for exceptions. The City recognizes that, notwithstanding these
purposes, at the time of development it may be necessary to remove certain trees in order
to accommodate structures, streets utilities, and other needed or required improvements
within the development.
In order to determine that preservation of viable trees has been adequately considered, the
tree plan shall include a narrative that addresses the following:
1. How does the site, lot and /or building layout maximize tree retention?
2. How have improvements such as roads, driveways, utilities, and walkways been
• designed and located to maximize tree retention?
3. Have tree compatible construction techniques been considered and utilized wherever
possible to maximize tree retention? (examples of tree compatible construction
techniques include but are not limited to tunneling for utilities, "no -dig" pavement
installation, and use of retaining walls in certain situations to limit root disturbance)
4. Is it possible to reduce the number of parking spaces to maximize tree retention?
5. Is it possible to reduce the total number of lots to maximize tree retention?
6. Could lot size averaging per Section 18.790.040(2) be utilized to maximize tree
retention?
• 7. Could lot width and /or depth per section 18.790.040(3) be reduced in order to
maximize tree retention?
8. How have buildings and building footprints been designed to maximize tree retention?
9. Are offsite trees that may be impacted by development inventoried and adequately
protected?
10. Describe additional techniques not mentioned above that have /will be used to
maximize tree retention.
Failure to demonstrate that the proposed development will preserve viable trees wherever
possible may result in findings for denial of a development application.
This interpretation shall become effective immediately.
By: Tom Coffee, Community Development Director
UPDATE:
3/14/08, the Home Builder's Association of Metro Portland Appealed the 2/26/08 Director's
Interpretation of Chapter 18.790 - Tree Removal, to the City Council. See land use file
MIS2008- 00005.
Council held a public hearing on the appeal on 5/13/08 and closed the public hearing and
scheduled 6/10/08 to reconvene to review and deliberate on this item.
On 6/10/08, the Council reconvened to consider this item and ultimately concluded that the
clarity of interpretation of a Code that is vague could be construed as a "judge making law
• from the bench" and that it is vunerable to a LUBA challenge. The Council pointed out that
s the Tigard Tree Code will be completely revised shortly following the Comprehensive Plan
update and that that would be the proper place to address this matter.
A unanimous vote of Council present was approved to uphold the appeal.