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Comments to the Tree Commission concerning DiSC 2022

Screen Shot 2021-10-19 at 9.55.57 AMThe following was emailed to members of the Tree Commission this morning.  The Tree Commission is scheduled to discuss the revised MRIC/ARC/DISC project, now dubbed DiSC 2022, at its meeting this Thursday, Oct 21.  If you wish to comment on the project yourself, see instructions on the agenda for the meeting, located here.

Dear members of the Tree Commission,

I am writing to you as a former commissioner (10+ years) and Chair of the Open Space and Habitat Commission (OSHC), having completed my term last December. I was involved in analyzing what is now being called the DiSC 2022 project in all of its iterations, so I hope you find my comments helpful in your discussions.

I think it's great that you appointed a subcommittee to review all the materials, given that the changes are more extensive than the City has stated – this is not just a project that has been cut in half, as your subcommittee's analysis shows. I endorse your subcommittee's recommendations and encourage you to adopt them as a body in the strongest possible language, remembering that the only way to guarantee that a promised feature will be in the actual project is for it to be designated as a "baseline feature." A cautious route would have you even recommend that the relevant ordinances be satisfied (this was something that the OSHC did last time), since there is a history of the City Council bending its ordinances, including ordinances concerning trees (it is my belief that they did this in the recent Sutter parking lot decision).

It seems to me that the biggest change is represented by the developer's statement that, "after consulting with Tree Davis, rather than committing to a specific and arbitrary number, DiSC 2022 will instead focus on planting the right trees in the correct conditions to achieve the desired shade coverage and canopy performance. Developer remains committed to monitoring by a third-party arborist" (attachment 5, p. 1).  So, for the original DISC, the developer committed to 1800 trees – quite a bit less than the 4000 that your commission recommended – but instead of just cutting that number in half, they now promise only "desired shade coverage" for DiSC 2022.  But how much "desired shade coverage"? 15%? 30%? 50%? 80%?  What is the metric?  What is the means of enforcement?  Without a metric, it is not even possible to have a means of enforcement.  I have a hard time believing that Tree Davis intended to leave this open-ended.  I think the subcommittee's recommendations that speak to this issue deserve particular attention.

I am also deeply concerned that the developer is proposing to satisfy the shade coverage requirements with trees or solar panels – another point noted by your subcommittee.  But as I said to the City Council when they were considering what to do about Sutter's tree-cutting proposal, the value of trees is greater than their shade.  Here I quote Don Shor’s letter to the council concerning the Sutter proposal, published in the Davisite and elsewhere: “Shade trees provide habitat, nesting sites, and food sources for wildlife. They significantly cool their surroundings by transpiring water, reduce urban heat island effect, capture fine particle matter and mitigate gaseous pollutants, cool the air by evaporative cooling, and have known mental and physical health benefits."  Solar panels, as important as they are, are not equivalent to trees.

In our understandable desperation to do whatever we can to combat climate change, we risk undermining one of the very things we are trying to protect: the natural environment.  I take the phrase "urban forest" very literally and I think it is a well-chosen term.  A forest is an ecosystem, not just trees.  Trees, however, play the key role in our urban forest ecosystems by providing habitat and the other benefits that Don Shor described. Our climate change solutions must enhance our ecosystems, and we can only do that if we don't trade off trees for solar panels. If DiSC 2022 goes forward, it must go forward with a robust urban forest and solar panels.

So again, I urge you to strongly endorse your subcommittee's recommendations and to do what you can to ensure that this proposal is as robust as it can be for the trees – and if that means a second meeting, then please hold one if you can.  This is a huge project (even at half the original size) and it ought to be done right.


Roberta Millstein


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