North State Climate Action
P. O. Box 990123
Redding, California 96099-0123
https://www.nsclimateaction.org
Email: ns4climate@gmail.com
May 29, 2023
Jeremy Pagan, Development Services Director (jpagan@cityofredding.org),
Jennifer Gannon (jgannon@cityofredding.org)
City of Redding
Subject: Recommendations for Tree Ordinance Revisions
North State Climate Action (NSCA) is a non-profit volunteer group in California’s far North State region, including Shasta and adjoining counties. Our mission is to promote solutions to the climate crisis through education, collaboration, and action in our communities.
Trees are a critical component for both mitigating and adapting to global warming. They provide shade, significantly reduce the urban heat island effect, and remove carbon dioxide from the atmosphere. Trees also provide wildlife habitat and reduce species loss, especially for birds. Additionally, without a dense tree canopy, there is greater sunlight reaching the ground, dryer soils, and higher fire danger. It is therefore important to preserve or replace trees that are lost due to development, where wildfires have burned, and in areas that have historically had little tree canopy.
The following are our recommendations for specific issues that need to be addressed in the revised tree ordinance being developed for the City of Redding.
1. Oak trees and other native trees on existing private residential or commercial property or on City property must be subject to the same requirements for removal as on undeveloped land. Likewise, when trees are removed in either developed or undeveloped areas, the City must require equivalent replacement or an in-lieu fee specifically reserved for tree replacement. It is critically important to recognize that trees should be protected as the first choice because new trees take many years to develop equal habitat and canopy to the ones removed.
2. When development is being planned in native tree habitat, the development design must place a high priority on layouts that will preserve existing trees, vegetation and fertile soil depth.
3. Trees 3 inches in diameter at breast height (dbh) or 54 inches above ground surface and larger of all species must be inventoried for location, size and health prior to beginning any site development designs. This will help in designing buildings and open areas with existing tree canopy incorporated rather than planting new trees after construction is completed.
4. Existing trees identified for preservation must be protected during grading by fencing and keeping equipment outside their drip line.
5. Native oak trees 5 inches dbh must be preserved. If they are removed or they die during construction, the developer must replace them onsite at a 4 to 1 ratio or pay a fee adequate to compensate for the loss of habitat, shade canopy, carbon sequestration and aesthetics. This provision will help eliminate excessive destruction of trees.
6. A designated portion of the in lieu fees must be used for planting and maintaining native trees in heat island areas of the City. The fees are to be based on the diameter of the tree and cost to replace and maintain new trees.
7. Only non-native smaller than 10 inches dbh and invasive trees should be exempted from permitting requirements. Larger non-native trees must be subject to the same requirements as native oak trees.
8. A minimum of ten percent of any in-lieu fees collected must be set aside for purchasing conservation easements or buying land for open space where tree preservation protections would be established.
9. Replacement trees must be native or drought tolerant non-invasive species.
10. The City tree ordinance must have a provision that the City will annually identify tree canopy equity tools, locations of needed shade trees, and funding sources, such as in-lieu fees, to implement measures to expand tree planting within disadvantaged communities and neighborhoods that lack desirable tree canopy coverage
Sincerely,
Tamra Plaga, Co-Chair
North State Climate Action Steering Committee