Tree Code Update

Dear Responsible Official:
The Snohomish Tribe of Indians appreciates the opportunity to review and comment on the City of Redmond’s proposed update to RZC 21.72, Tree Regulations. The Tribe supports the City’s recognition that trees are vital community assets that provide wildlife habitat, reduce stormwater runoff and erosion, improve water and air quality, reduce urban heat, and support a climate-resilient urban canopy. We also appreciate the express intent to protect Culturally Modified Trees, native handmade trees, landmark and heritage trees, groves, critical-area trees, and trees near streams and other sensitive areas.
Trees, plants, animals, healthy water resources, and the ecological relationships among them were paramount to the survival and well-being of our ancestors. Our people historically valued every tree, plant, and animal species as part of a living and interconnected landscape. Mature trees cannot be treated as interchangeable with newly planted saplings: they provide complex habitat, canopy, carbon storage, cooling, stormwater interception, soil stability, cultural meaning, and ecological functions that may take generations to replace.
Accordingly, the Tribe supports adoption of a strengthened tree code, but recommends that the City revise the proposal before adopting the ordinance. The present draft contains meaningful protections, yet several exceptions, discretionary standards, replacement provisions, and procedural gaps could allow substantial cumulative canopy and habitat loss.
In essence, the Snohomish Tribe of Indians supports Redmond's efforts to preserve and protect native mature trees and mature groves. However, the proposed code does not do enough to identify, document, and protect Culturally Modified Trees, which are also sometimes described within Native communities as Native handmade trees. Historically, mature trees were intentionally modified and hand-cut by Coast Salish people in particular ways to establish waypoints, provide direction, mark travel routes, and identify paths to sacred or culturally significant places. Such trees may be found throughout the Pacific Northwest along the edges of trails, rivers, shorelines, and Puget Sound. Because their significance may not be visible to an ordinary arborist or developer, the code should require cultural-resource review, Tribal and Indigenous consultation, and field assessment before mature trees in culturally sensitive locations are altered or removed.
1. Positive Provisions Supported by the Tribe
• Recognition of ecological functions. The purpose section correctly identifies wildlife habitat, stormwater control, erosion prevention, water and air quality, and heat-island reduction as core public benefits of trees.
• Protection priority for culturally important and mature trees. The draft places Heritage Trees and Culturally Modified Trees first in the retention hierarchy, followed by Landmark Trees, trees near critical areas, groves, and conifers.
• Protection of critical areas and wildlife structure. The requirement to retain hazardous trees as wildlife snags where feasible, leave woody material in place, and add nest boxes is environmentally beneficial.
• Tree-protection planning and construction monitoring. The requirement for arborist reports, Tree Protection Plans, fencing, inspections at key construction stages, and final compliance reporting is a strong foundation.
• Enforcement and restoration. The draft recognizes indirect tree damage, allows civil penalties, provides enhanced penalties for protected trees, requires restoration, and includes a five-year survival period for restoration trees.
2. Major Environmental Concerns and Requested Revisions
A. Require a true avoidance-first standard
The code should clearly require avoidance, minimization, restoration, and compensation in that order for every regulated removal, including private development, public projects, utilities, and programmatic permits. Phrases such as “maximum extent practicable,” “efficient development,” and “generally consistent” are too discretionary unless paired with measurable findings and written documentation.
Requested revision: Require a written alternatives analysis demonstrating that reasonable redesign, clustering, reduced grading, utility relocation, narrower access, cantilevering, and dimensional modifications were evaluated before removal is authorized. The City should make an independent written finding that removal is the least environmentally damaging feasible alternative.
B. Increase the minimum percentage of retained-tree credits
The draft generally requires only 35 percent of minimum tree credits to be satisfied through retention of existing trees, with additional exemptions for very small lots and where retention would reduce allowed impervious surface. This may permit removal of most mature trees while allowing small replacement trees or fees to satisfy the remaining obligation.
Requested revision: Require at least 50 percent of required tree credits to come from retained existing trees citywide, and a higher percentage—preferably 60 to 75 percent—on forested, riparian, critical-area-adjacent, or habitat-corridor sites. Exemptions should require a documented site-specific finding and should not apply to Heritage Trees, Culturally Modified Trees, groves, riparian trees, or trees that provide documented wildlife habitat.
C. Prevent cumulative removal through annual allowances
The residential removal allowance permits repeated annual removal while maintaining only a small minimum number of significant trees. Commercial, industrial, and multifamily sites may remove up to four significant trees per acre per year for thinning or landscape maintenance. Over time, these provisions could result in substantial cumulative canopy loss without development-level review.
Requested revision: Use a rolling five-year removal limit rather than a 12-month reset; require cumulative accounting across ownership changes, parcel subdivisions, and related applications; prohibit segmentation of removals; and require canopy-impact review when repeated removals exceed a defined threshold.
D. Strengthen protection for Landmark, Heritage, grove, and Culturally Modified Trees
The exception language allows removal where retention would preclude “reasonable development,” conflict with density goals, or create other development constraints. These standards are broad and could allow exceptional trees to be removed whenever full development yield is not achievable.
The City should not assume that all Culturally Modified Trees can be recognized through a standard arborist inspection. Identification may depend on cultural knowledge, landscape context, historic travel corridors, hand-cut features, and relationships to trails, rivers, shorelines, gathering places, and sacred areas. The ordinance should therefore require early cultural-resource screening and consultation before permit issuance, rather than relying on discovery after clearing has begun.
Requested revision: Establish a presumption of retention for Heritage Trees, Culturally Modified Trees, and intact groves. Removal should be limited to an imminent, non-correctable public-safety hazard or a constitutional reasonable-use circumstance after all feasible alternatives have been exhausted. Density maximization alone should not justify removal. Any proposed impact to a known or potential Culturally Modified Tree should require early notice to potentially affected Tribes and Indigenous communities, consultation with the Department of Archaeology and Historic Preservation, and assessment by a qualified cultural-resources professional.
E. Require archaeological and cultural-resource review before ground disturbance
The draft appropriately prohibits tree and root removal on known and unknown archaeological sites without state authorization. However, a prohibition alone does not ensure that unknown resources will be identified before roots are cut, stumps are ground, soils are excavated, or grading occurs.
Requested revision: Require cultural-resource screening before permits involving large trees, old-growth remnants, shorelines, streams, wetlands, terraces, and other high-probability settings. Where cultural-resource potential is moderate or high, require a professional archaeological survey and, when appropriate, on-site archaeological monitoring during tree removal, stump or root disturbance, trenching, and grading. Every permit should include an Inadvertent Discovery Plan, immediate stop-work requirements, protection of the discovery area, and notification procedures for the City, DAHP, law enforcement where human remains may be involved, and affected Tribes and Indigenous communities.
F. Preserve habitat connectivity and wildlife corridors
The proposal recognizes wildlife habitat but does not establish a clear requirement to retain connected canopy, understory, snags, coarse woody debris, or movement corridors. A project could technically meet tree credits while fragmenting a grove into isolated trees with reduced ecological function.
Requested revision: Require Tree Protection and Replacement Plans to identify existing habitat connections and retain contiguous groves, riparian linkages, stepping-stone canopy, understory, snags, and downed wood where safe. Replacement planting should prioritize expansion of existing habitat and connections among streams, wetlands, critical areas, parks, Native Growth Protection Areas/Easements, and other open space.
G. Improve replacement ratios and ecological equivalency
The replacement schedule can allow one small replacement tree for a mature significant tree and no replacement for many dead, dying, diseased, or hazardous trees under 30 inches DBH. Even a declining tree may provide substantial habitat, carbon storage, shade, and stormwater function. Numerical replacement does not equal ecological replacement.
Requested revision: Require replacement based on lost canopy area, species, condition, habitat value, and time-to-maturity—not DBH alone. Require higher ratios for native conifers, riparian trees, grove trees, wildlife trees, Landmark Trees, Heritage Trees, and Culturally Modified Trees. Hazard-tree removals should still require replacement unless the City documents that replacement would undermine ecological restoration or public safety. Require native, climate-resilient species appropriate to site conditions and prohibit ornamental substitutions where native forest function is being lost.
H. Narrow fee-in-lieu use and ensure timely, local mitigation
Fee-in-lieu is an important last resort, but it can separate tree loss from replacement in both place and time. The draft also allows applicants to elect fee-in-lieu for Landmark and Heritage Tree mitigation, which could make removal a predictable cost of development.
Requested revision: Allow fee-in-lieu only after the City independently verifies that both on-site and off-site planting are infeasible. Do not permit an applicant to elect fee-in-lieu for Heritage Trees, Culturally Modified Trees, groves, or riparian trees. Require collected funds to be spent within a fixed period, preferably three years, within the same watershed, drainage basin, or impacted neighborhood, with priority for canopy-deficient and environmentally overburdened areas. Publish annual reports showing funds collected, projects completed, survival rates, and remaining balances.
I. Extend maintenance, survival, and monitoring obligations
A five-year maintenance period is helpful but insufficient to ensure that replacement trees reach functional maturity. The draft also allows preserved-grove instruments to be extinguished when the Planning Official determines preservation is no longer appropriate, without clear criteria or public process.
Requested revision: Require at least ten years of monitoring and replacement for development mitigation trees, with financial assurance adequate to cover mortality and corrective work. Preserve groves and exceptional trees in perpetuity unless removal meets the same strict exception standards and receives public notice. Require replacement of dead or failing trees throughout the monitoring period and require survival performance standards, not merely planting.
J. Strengthen independent review and public accountability
Third-party review of exception requests is discretionary, and the expert is selected by mutual agreement between the applicant and City. This may undermine independent evaluation, particularly for Landmark, Heritage, grove, or culturally sensitive trees.
Requested revision: Make independent peer review mandatory for removal of Heritage Trees, Culturally Modified Trees, Landmark Trees, groves, critical-area trees, or ten or more regulated trees. The City—not the applicant—should select and direct the reviewer, while the applicant pays the cost. Require public notice and an opportunity to comment on major exception requests and programmatic permits.
K. Apply equivalent standards to City and utility projects
The draft applies mitigation requirements to public projects, but terms such as “efficient development,” mutually agreed project limits, and programmatic permitting could weaken site-specific review.
Requested revision: Require City and utility projects to meet the same avoidance, retention, replacement, cultural-resource, and monitoring standards as private development. Programmatic permits should have defined geographic and temporal limits, annual reporting, cumulative impact accounting, field verification, and project-specific review for exceptional or culturally significant trees.
L. Correct internal inconsistencies and unresolved placeholders
The draft contains unresolved citations and numbering placeholders such as “RZC 21.72.xxx,” references to exceptions under provisions that appear to contain exemptions, duplicated or misnumbered subsections, and inconsistent references to replacement sections. These defects create ambiguity and may impair enforcement.
Requested revision: Complete a full legal and technical cross-reference audit before adoption. All standards, tables, definitions, permit triggers, appeal procedures, and enforcement provisions should be internally consistent and readily understandable to applicants, staff, property owners, and the public.
3. Environmental Considerations and Recommended Protections
As part of the City’s consideration of this proposed development regulation, the Tribe asks the City to evaluate the ordinance’s probable cumulative impacts and reasonable alternatives, including:
● Citywide loss of mature canopy and the delay between removal and functional replacement;
● Fragmentation of wildlife habitat, riparian connections, groves, and ecological corridors;
● Changes to stormwater interception, soil stability, erosion, water quality, temperature, and climate resilience;
● Disproportionate canopy loss in neighborhoods that already have lower canopy or higher environmental-health burdens;
● Potential effects on archaeological sites, cultural landscapes, Culturally Modified Trees, and tribal cultural resources;
● Cumulative effects of annual removal allowances, exemptions, exception approvals, public-project removals, and fee-in-lieu mitigation;
● An alternative with stronger retention percentages, narrower exceptions, enhanced replacement ratios, longer monitoring, and mandatory cultural-resource safeguards.
These environmental considerations are directly relevant to the City's evaluation and adoption of the proposed tree regulations. The Tribe asks the City to address them through enforceable code revisions, clear permit standards, and mitigation measures sufficient to prevent cumulative loss of mature canopy, habitat, water-resource functions, and cultural resources.
4. Requested Revisions Before Adoption
1. Adopt an avoidance-first mitigation sequence with documented alternatives analysis and independent City findings.
2. Increase mandatory existing-tree retention and eliminate broad exemptions tied solely to maximizing density or impervious surface.
3. Create rolling cumulative-removal accounting and anti-segmentation provisions.
4. Establish strict, consultation-based protection for Culturally Modified Trees and other cultural resources.
5. Require Inadvertent Discovery Plans and archaeological review or monitoring in culturally sensitive and high-probability areas.
6. Protect connected groves, understory, snags, coarse woody debris, riparian vegetation, and wildlife corridors.
7. Use canopy- and function-based replacement ratios, prioritize native species, and extend monitoring and financial assurance.
8. Limit fee-in-lieu to a verified last resort and require transparent, timely, geographically connected mitigation.
9. Require independent peer review and public notice for major exceptions and programmatic permits.
10. Correct all numbering, cross-reference, procedural, and drafting inconsistencies before adoption.
11. Create a formal process for identifying and protecting Culturally Modified Trees, including Native handmade trees, through cultural-resource review, field verification, and consultation with affected Tribes and Indigenous communities before tree removal or ground disturbance.
5. Conclusion
The Snohomish Tribe of Indians supports the City’s goal of slowing canopy loss and creating a healthy, sustainable, and climate-resilient urban forest. We appreciate the inclusion of Culturally Modified Trees, wildlife habitat, critical-area protections, construction monitoring, and meaningful enforcement tools.
However, the ordinance should protect existing mature trees as irreplaceable ecological and cultural assets rather than relying primarily on replacement planting or monetary compensation. The Tribe requests that the City revise the proposal and its analysis to address the cumulative and site-specific impacts described in this letter. We respectfully request continued consultation as the ordinance is revised.

Thank you for considering these comments and for your continued commitment to protecting Washington’s environmental resources for present and future generations.

Adam Dallman
Chairman of Fish, Wildlife, and Environment Committee
Snohomish Tribal Council
Bachelor’s in Environmental Studies

 
Authorities and Source Materials
Proposed Redmond Zoning Code 21.72, Tree Regulations, Public Draft V1 (July 22, 2026). Primary proposal reviewed.
Growth Management Act, chapter 36.70A RCW, including RCW 36.70A.020, .070, .110, and .130, as applicable. Washington State Legislature.
RCW 27.53.060 and chapter 27.53 RCW (protection of archaeological sites and resources; permit requirements for disturbance). Washington State Legislature.

RE: Tree Code Update, Version 2 (RZC 21.72, Tree Protection, and RZC 21.78, Definitions) — Potential Loopholes

I submitted extensive technical comments on this draft through the questionnaire and at the July 29 drop-in office hour. This comment focuses specifically on a related issue: places where the current Version 2 language could be technically complied with while defeating the code's intent. I'd ask that these be reviewed and addressed before the October 14 public hearing.

1. Tree protection expires after five years for most housing types (RZC 21.72.160.B.1). For single-family homes, short plats, subdivisions, middle housing, and accessory structures, retained/replacement trees only must be maintained for five years after the certificate of occupancy. After that, "all trees on the property are subject to RZC 21.72.080, Regulated Tree Removal," unless part of a protected grove of three or more trees. This lets the very trees credited toward a project's tree requirement be legally removed once five years pass, with no clawback. Recommendation: require a permanent notice on title requiring replacement if a credited tree is removed at any time, not only within five years.

2. The one "permanent" grove protection can be extinguished at a single official's discretion (RZC 21.72.160.C). The recorded "in perpetuity" preservation agreement for groves "may be extinguished if the Planning Official determines that preservation is no longer appropriate," with no defined criteria, notice, or hearing. Recommendation: require written findings against defined criteria and review by the Hearing Examiner or Planning Commission, not sole staff discretion.

3. The small-lot exemption (RZC 21.72.090.C.1) has no anti-fragmentation safeguard. Lots of 3,000 square feet or less are exempt from mandatory retention, with no rule aggregating commonly owned or recently subdivided parcels, leaving room for a larger parcel to be subdivided specifically to escape retention requirements. Recommendation: aggregate commonly owned or recently subdivided parcels (e.g., within 5 years) for this threshold.

4. The bonding requirement meant to guarantee compliance cites a section that doesn't exist (RZC 21.72.060.G.2), referencing "RZC 21.72.xxxx, On-site Tree Protection," an unresolved placeholder. Recommendation: insert the correct citation and a specific bond amount/formula.

5. The waiver for the five-year prior-removal lookback (RZC 21.72.080.E.2.a) has no defined standard for what counts as removal "beyond an applicant's control," creating a path to clear trees and later claim a waiver. Recommendation: define this term as an exclusive list, excluding removals justified solely by the applicant's own hired professional.

6. Boundary-tree removal (RZC 21.72.080) can bypass standard review through a 30-day notice based on a self-asserted "50% or more of trunk" threshold, with no survey requirement, and the notice itself can be waived on a Qualified Tree Professional's (QTP) opinion. Recommendation: require a documented survey for disputed trunk-location determinations and limit notice waivers to hazards verified by the City's own arborist.

7. Repeated "view pruning" of up to 25% (RZC 21.72.160.D.2–3) has no stated frequency limit, creating a workaround to the topping ban through repeated stress to a tree over time. Recommendation: cap cumulative pruning at 25% within a rolling multi-year period, with QTP sign-off on tree health.

8. The entire mandatory retention percentage (RZC 21.72.090.C) hinges on the undefined term "healthy," unlike "Hazardous Tree," which has a precise, ISA-based definition. Recommendation: add an objective "Healthy Tree" definition using the same ISA-based framework.

Cross-cutting concern: Several of the above (items 5, 6, and 8) rely entirely on a written opinion from a Qualified Tree Professional who is the applicant's own hired consultant, with no apparent mechanism for independent verification by a city-employed arborist. I'd ask the project team to clarify whether such a mechanism exists or is planned, as it bears directly on how significant these gaps are in practice.

Thank you for considering these comments as part of the Version 2 review process.

I just submitted my completed questionaire. I included mention of two online tools for decifering the real monetary value of tree(s). You may be referencing these already, but if not, here is what I found that various municipalities have been using: itreetools.org (US Forest Service), and TreeEquityScore.org (American Forests).
Thanks for your efforts in regard to tree protection. I am impressed with the direction the city is taking. - longtime resident of Redmond

I would like to refer The Tree Team to this article concerning the planting of native trees Plant the Right Tree Seedlings | Department of Natural Resources.

Redmond’s soil is glacial till with compact clay mixed in with rocks. Our soil does not drain well and it is not alluvial soil which is a requirement for all native trees to thrive.

The proposed Tree Code Update is confusing.
So is your survey.

I am submitting this comment as a volunteer Forest Steward in the City of Redmond's Green Redmond Partnership program and a civic advocate who has reviewed Draft V1 of RZC 21.72 in full alongside the companion RZC 21.78 Definitions and the 2019 Tree Canopy Strategic Plan.

Draft V1 reflects genuine effort and contains several commendable provisions: the wildlife snag conversion requirement for hazardous trees in critical areas, the CRSVM species list requirement for replacement trees, the five-year lookback provision for pre-development clearing, and the conifer bonus credit. These deserve to carry forward into Draft V2. However, four structural issues require resolution before the code can function as intended.

First, the minimum tree credit rate table must be completed and published before Draft V2 public comment closes. Table 21.72.090-1 is the mathematical foundation of the entire credit system and is flagged in the draft itself as still undergoing testing and review. Without a complete version of this table, no property owner, developer, or Planning Commissioner can evaluate whether the code's retention requirements are achievable, reasonable, or sufficient to support the 40% canopy goal. Public comment collected before this table is finalized does not constitute meaningful community input on the code's core standard.

Second, the fee-in-lieu rate must be recalibrated upward. The proposed rate of $800–1,000 per tree will not cover the full lifecycle cost the draft itself describes — purchase, soil preparation, installation, five years of maintenance, and fund administration. Current market rates for installed replacement trees in the Seattle metropolitan area routinely exceed $1,500–2,500 per tree. A systematically undercapitalized Tree Canopy Fund will convert what should be a mitigation program into a tree removal subsidy, directly undermining the Strategic Plan's goal of closing the approximately 200-acre canopy gap at an estimated cost of $80,000 per acre.

Third, the credit rate structure inverts ecological logic in Critical Aquifer Recharge Areas. Table 21.72.090-1 assigns the lowest minimum credit requirements — 2 credits per 1,000 square feet — to All Other Zoning Districts, which includes commercial and industrial zones that overlap with CARAs. Trees in CARA-mapped areas perform irreplaceable groundwater recharge and contaminant buffering functions that no engineered system fully replicates. Groundwater supplies the City's drinking water, making aquifer protection a direct public health concern. The code should establish heightened, not reduced, retention requirements for development in CARA-mapped areas.

Fourth, the exception criteria require tightening to function as a genuine last resort. The dual-criteria structure in RZC 21.72.130.C and .D creates an internal inconsistency between provisions requiring that all conditions be met simultaneously and provisions listing independent disjunctive grounds for approval. The broadly worded "reasonable use" and "urban density" exception grounds are susceptible to routine invocation, effectively making retention requirements optional for any project that characterizes tree protection as an impediment to maximum density. The avoid-minimize-mitigate sequence described as the intent of the exception process should be codified as a strict sequential hierarchy, not a set of parallel alternatives.

Redmond's 2017 canopy baseline stood at 38.1% — already below the 40% goal — with net losses running 12 to 13 acres per year. North Redmond alone lost approximately 20 acres of canopy, roughly 8% of its neighborhood total, between 2009 and 2017. Development pressure from Redmond 2050, HB 1110 middle housing mandates, and light rail-oriented growth will intensify that trajectory. The updated tree code is the City's primary regulatory tool for reversing it. Getting Draft V2 right is worth the additional time it takes.

I agree with Redmond as to the value of our trees. But Redmond is a very irresponsible steward of these trees. If you are going to dictate that trees be prioritized and retained, then Redmond MUST step up to their responsibility during the full annual growth cycle. When I moved to Redmond in 1990, having street and storm cleanup was routine and basic part of Remond life. In the last 15 years, Redmond has grown critically irresponsible as to their dual role with trees: retain them, and maintain the city as needed when these trees go through their normal annual growth cycle. I demand that Redmond acknowledge this reality, evaluate the mess and problems this causes the many neighborhoods, and maintain all of Redmond as well as you maintain the Downtown Core. Regular street sweeping as dictated by the time of year and debris produced. Arrange a rapid and scalable response capability for for cleaning up after at least 5 windstorms a year. It is a fact that Redmond's trees produce an extreme amount of recyclable waste a year. It is a fact that this waste creates an undue and inordinate burden on the taxpayers of Redmond by inhibiting outdoor activities and requiring endless cleanup that should be borne by Redmond. This is a very basic duty of local government. Stop trying to solve regional problems with our tax dollars until you can meet all basic duties in the city.

I attended the 6/2/2026 Learning session. I shared my full comments via email so these are brief. As single unit owners in a large multi-family COA property we are in a grey zone. The code has been difficult to navigate due to our size being more aligned with commercial developed properties, but our needs are more aligned with single family properties. I appreciate the goals set forth in the proposed code changes and hope the final process is understandable and not overly burdensome for homeowners who are not in the professional construction or landscaping business. It is especially hard to find code compliant replacement trees at retail nurseries. I hope the proposed smaller size for single family replacement trees will extend to our situation.

I’ve reviewed the draft definitions, and I’ve annotated a copy with my comments and emailed them separately. Two largest concerns: first) many of the definitions are weak and I don’t see (how written) they support your code and its objective. Many appear to have been copied and pasted from online sources and have language that is not relevant or consistent with other parts of code. That leads to #2: as a tree professional, I’m bound to use ANSI A-300 standards and their accompanying BMPs, yet some definitions use language not consistent with the A-300 or BMPs. This is very confusing.

I am frustrated when code (and its definitions) is out of sync with code mandated methods. This is especially true for pruning and for risk assessment as outlined in the A-300.

I suggest you craft an objectives/purpose section for the definitions. Why are they there? how will you use them? How should I use them?

I look to them for clarity in assisting my client with code compliance. And that is difficult when they use language that is vague or outdated.

Thanks again for your consideration.

I participated in the 6/2/2026 Noon Team Meeting in regard to draft changes to the Tree Code. As a residential homeowner, I dealt with issues related to the existing tree removal permitting system in 2018, 2019 and 2020 and I am interested in modifications to the existing code because of the hassles and delays associated with getting those permits and having to wait over 2 years to plant new trees in my own back yard.

We had a large branch from a tall tree lean up against a neighbor's roof. While we were able to remove the branch, we needed a permit to remove the tree which obviously was not completely healthy. On our property, we were allowed to take down 2 healthy trees a year but in order to take down an obviously unhealthy tree, I was required to hire an arborist. I showed an arborist Redmond's pages long arborist report and I was told that it would cost me between $400 and $700 to have them complete the report. It seemed ridiculous to me that I was being required to pay up to $700 to get a report that would allow me to pay hundreds more to remove the tree that had a significant branch fall on a neighbor's roof. (It would be great if Redmond had an arborist on staff to save citizens hundreds or thousands of dollars in arborist repot fees.)

In addition, we wanted to remove 4 other trees from our back yard in order to plant 12 arborvitae trees. Because of the size of our lot (6022 143rd CT NE), I was allowed to only remove 2 trees a year. So, 3 consecutive Julys I had to fill out a tree removal permit form and deal with the hassle. I was also required to pay a higher fee to have the trees removed at 3 separate occasions rather than doing them all at one time. One of the trees we wanted to take down had a root that was damaging our back fence. Had we just cut out the root, it would have killed the tree and Redmond would have probably fined us for doing that.

What makes this all the more annoying is that we planted most if not all of these trees within a year of our moving into this house in 1987. So, even though we paid to plant the trees, we still needed to get Redmond's permission to remove them.

I can understand Redmond's interest in trees that are at the front of the house that face the street but trees that are in our backyard or trees that we paid to plant should not require a tree permit to remove.

I realize that few if any of my suggestions will be incorporated into the new tree code but I hope that serious consideration will be given to 1) Redmond having an arborist on staff, 2) not requiring multiple tree permits to be obtained for essentially the same project, 3) allowing a resident that wants to remove more trees than their lot size permits to do so if they are planting more replacement trees than they are removing, 4) allow removal of trees whose roots are damaging a fence. and 5) allow the removal of a tree that has had a significant branch fall on a neighbor's house.

Thank you for your consideration of this feedback.

"No exception needed if a Qualified Tree Professional determines the tree is dead, dying, or diseased." Define these terms: dying and diseased. More to the point, is the tree’s useful life as a retained amenity impacted significantly because it is dying or diseased.
Example: Every dogwood, apple and Serviceberry in the PNW is diseased, as are all the madrones. Most ‘diseased’ trees can tolerate some level of ‘disease’ (presence of a fungal/bacterial pathogen) and continue to grow and provide benefit.
I think the better approach is to quantify, using the condition table, a threshold for condemning a tree because it is dying or diseased.

"Hazardous trees may be removed with documentation from a Qualified Tree Professional Define hazardous." Many municipalities use ‘an overall risk rating of high or extreme’ (based on ANSI standards). Even a tree with an overall low risk rating is hazardous.

"Conifer/ Evergreen: Douglas Fir, Western Red Cedar,
Western Hemlock, Noble Fir, Shore Pine, etc."
"Deciduous: Big Leaf maple, Red Alder, Pacific Dogwood, etc. "

More clarity here please: the Western larch is a native conifer, and is also deciduous.
Pacific madrone is evergreen, nor is it deciduous

"Retention priority (highest to lowest):
• Culturally Modified Trees
• Heritage Trees
• Landmark Trees
• Trees near critical areas
• Groves
• Perimeter landscaping trees
• Coniferous/evergreen trees
• All other significant trees"

Can you add a priority for remaining useful life? Perhaps also include a minimum threshold for a ‘condition and viability’ rating from the matrix you propose to use.

Tree Protection Fencing. Are there specifications for this somewhere I can’t find? TPF should be chain link affixed to driven steel posts. None of that plastic netting crap

Definitions
"• TPZ: “Tree Protection Zone (TPZ)” means the circular area around a tree calculated as one foot of radius for every inch of d.b.h., or at least six feet, whichever is greater. The TPZ may instead be determined by a Qualified Tree Professional."

Consider introducing the concept that a TPZ can be other than a circle!! (a square or polygon)

Rare are sites these days where there is sufficient space to complete a circle around a retained tree with sufficient soil for an adequate TPZ. ‘Other-shaped’ TPZs allow for more creativity in using soil near a tree that can be protected as part of the root zone that would otherwise be ‘outside’ that circle.

Is there any thought to licensing and/or registering businesses that cut trees in Redmond? It seems like homeowners and tree cutting businesses might not have knowledge of the rules and needs for a permit, but if businesses were required to be licensed, they could be required to know the rules and not be clear-cutting a lot, as is happening in my neighborhood now. In many other businesses (i.e. gun sales, alcohol, and many others), it is up to the business to know the rules. Perhaps requiring that in the tree business would result in fewer landmark trees in neighborhoods being cut down. Thanks for your consideration.