DIR2012-00003 DIRECTOR'S INTERPRETATION
TIGARD DIR2012 -00003
DATE: June 18, 2012
CODE CHAPTER: 18.790 — Tree Removal
TOPIC: Tree Removal Permit Applicability
LOCATION: Sensitive Lands
I. REQUEST
The Tigard Development Code recognizes that some parts of the code may not provide adequate
guidance in some situations. It was not possible for the code's drafters to anticipate all land use
circumstances. To address this, Chapter 18.340 of the code authorizes the director to render an
administrative code interpretation to provide greater clarity.
City staff has received inquiries about whether tree removal permits are required to remove noxious
trees in sensitive lands. The Tigard Development Code is ambiguous on this matter and does not
provide clear direction. In order to address this circumstance, the following two sections analyze the
situation and establish an appropriate Director's Interpretation on how the code is to be
administered.
II. ANALYSIS
The City of Tigard, in partnership with Clean Water Services, engages in the restoration of sensitive
lands to implement the Healthy Streams Program, which supports the city's compliance with the
Metro Urban Growth Management Functional Plan (UGMFP) and Statewide Planning Goal 5
requirements. Restoration activities include the removal of noxious vegetation and replacement with
native vegetation, which improves water quality and wildlife habitat. Among the noxious vegetation
typically removed are several species of non -native trees such as English hawthorn, English holly
and sweet cherry.
Section 18.775.020.B of the Tigard Development Code (WC) lists the removal of noxious
vegetation in sensitive lands among the "outright permitted uses with no permit required." Further,
section 18.775.020.0 lists "stream and wetlands restoration and enhancement programs" and "non-
native vegetation removal" among the exemptions from sensitive lands permits. Also, Metro
Council adopted a "Nuisance Plant List" through Resolution 98 -2708, which exempts the removal
of nuisance /noxious vegetation, including trees, from within environmental areas regulated by
Metro under the UGMFP.
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However, section 18.790.050 of the TDC requires tree removal permits "for the removal of any tree
which is located on or in a sensitive land area as defined by Chapter 18.775 ". Section 18.790.050
does not differentiate between noxious and native trees regarding permit applicability.
Therefore, there is a conflict between Chapter 18.790 of the TDC, which requires permits for
noxious tree removal in sensitive lands, and Chapter 18.775 of the TDC, which exempts from
permits the same activity, as well as, the regulations adopted by Metro that essentially direct local
governments to exempt noxious tree removal from their environmental regulations.
Given the conflict between Chapters 18.790 and 18.775, the more specific regulations should apply.
Chapter 18.775 is more specific because it acknowledges the need to restore sensitive lands by
removing noxious vegetation. Chapter 18.790 applies more generally to tree removal and does not
differentiate between noxious and native trees in the same manner as Chapter 18.775. Therefore, the
exemption from permit requirements in Chapter 18.775 should supersede the permit applicability in
Chapter 18.790 for the removal of noxious trees.
In addition, while the City of Tigard does not have a list of noxious trees, it is in the process of
developing one through the Urban Forestry Code Revisions (UFCR) project. The draft list of
noxious trees being developed through the UFCR is substantially similar as the trees in the Nuisance
Plant List adopted by Metro through Resolution 98 -2708. Therefore, the specific trees that should
be considered noxious, and thus exempt from permit requirements, should be those listed in the
Nuisance Plant List adopted by Metro until such time as the city's list is adopted and made effective
through the UFCR.
III. INTERPRETATION
Trees in the Nuisance Plant List adopted by Metro through Resolution 98 -2708 shall be exempt
from tree removal permit requirements in Chapter 18.790.050. This interpretation shall be effective
until the UFCR is adopted by the Tigard City Council and made effective.
(O/41/Z
Susan Hartnett, Assistant Community Development Director Date
For Ron Bunch, Community Development Director
ATTACHMENT: NUISANCE PLANT LIST EXCERPTED FROM METRO
RESOLUTION 98 -2708
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Nuisance Plant List
Plants on this list can be removed without environmental or greenway review. Other local, state or
federal laws may still regulate removal of certain plants on this list. These plants may be native,
naturalized or exotic. They are divided into two groups: plants which are considered a nuisance
because of their tendency to dominate plant communities and plants which are considered harmful to
humans.
Indicator
Scientific Name Common Name Status
Dominating Plants
Acer platanoides Norway Maple NI
Ailanthus altissima Tree -of- Heaven NI
Alliaria officinalis Garlic Mustard
Chelidonium majus Lesser Celandine
Cirsium arvense Canada Thistle FACU+
Cirsium vulgare Common Thistle FACU
Clematis ligusticifolia Western Clematis FAC -
Clematis vitalba Traveler's Joy
Convolvulus arvensis Field Morning -Glory
Convolvulus seppium Lady's- Nightcap
Cortaderia selloana Pampas Grass
Crataegus sp. except c. douglasii Hawthorn, except native species
Daucus carota Queen Anne's Lace
Egeria densa* South American Waterweed OBL
Elodea densa South American Waterweed
Equisetum arvense Common Horsetail FAC
Equisetum telemateia Giant Horsetail FACW
Erodium cicutarium Crane's Bill
Geranium robertianum Robert Geranium
Hypericum perforatum St. John's Wort
Ilex aquafolium English Holly
Iris pseudacorus Yellow Flag OBL
Lemna minor Duckweed, Water Lentil OBL
Leontodon autumnalis Fall Dandelion FAC
Myriophyllum spicatum Eurasian Watermilfoil OBL
Poa annua Annual Bluegrass _ FAC
Polygonum coccineum Water Smartweed OBL
Polygonum convolvulus Climbing Bindweed FACU -
Polygonum sachalinense Giant Knotweed FACU
Prunus laurocerasus English, Portugese Laurel
Rubus laciniatus Evergreen Blackberry FACU+
Senecio jacobaea Tansy Ragwort FACU
Solanum dulcamara Blue Bindweed FAC+
Solanum sarrachoides Hairy Nightshade
Taraxacum officinale Common Dandelion FACU
Metro Native Plant List Page 19
Utricularia vulgaris Common Bladderwort
Various genera Bamboo sp.
Vinca major Periwinkle (large leaf)
Vinca minor Periwinkle (small leaf)
Xanthium spinoseum Spiny Cocklebur FACU
Harmful Plants
Conium maculatum Poison - Hemlock FACW-
Laburnum watereri Golden Chain Tree
Rhus diversiloba Poison Oak
Solanum nigrum Garden Nightshade FACU
Metro Native Plant List Page 20