The City of Los Angeles has launched a program to repair our broken sidewalks. As part of a settlement of the Willits class action lawsuit, a sidewalk repair program (SRP) called Safe Sidewalks LA began 3 years ago, and as a result, hundreds of large trees have already been removed, even though an environmental impact report (EIR) had not been conducted. We all want our sidewalks repaired, but we cannot afford to lose our urban tree canopy.
Through this 30-year SRP program, close to 13,000 large, mature trees are projected to be removed and replaced with 15-gallon saplings.
On December 26, 2019, the Sidewalk Repair Program Draft EIR was finally released. Here is a link: https://sidewalks.lacity.org/environmental-impact-report. The NCSA Trees Committee has serious concerns that this lengthy report is not informed by science and ignores the City’s own Dudek report, which cites tree preservation as critical for the health of our city and its inhabitants.
The goal of this draft EIR is to “streamline” the implementation of the sidewalk repair program and enable trees to be removed without challenge. We have concerns about the rush to remove trees without adequate due process, public involvement, and consideration of more sustainable approaches. We know there are hardscape alternatives to tree removals, such as bulb-outs, that are utilized in other cities to divert the sidewalk around the tree in order to retain it that are not proposed for Los Angeles. Visit www.seattle.gov/Documents/Departments/SDOT/Trees/TreeSidewalksOperationsPlan_final215.pdf to learn more.
Although new young trees will be planted, the projected return to the tree canopy baseline as it existed prior to the program will not occur for 30 years. The report ignores or fails to evaluate numerous health and environmental impacts that result from tree removals. These include an increased heat island effect, a decline in air quality, loss of wildlife, and loss of stormwater capture. No mitigation of ecosystem services loss is addressed in this EIR because trees are considered a design element rather than an ecosystem service provider.
Trees take decades to grow to maturity, and the report anticipates a new tree mortality rate of only 8%, which we believe is overly optimistic, particularly given that budget and capacity constraints may make proper maintenance and irrigation of young trees extremely challenging. The City of Santa Monica’s chief forester reported at the City of Los Angeles’s 2019 Tree Summit that they experience 20% mortality with street tree saplings, and their urban forestry program is highly regarded. The City of Los Angeles’s replacement-tree list excludes important large-canopy tree species, and it is the large trees that provide greater ecosystem services than smaller trees. It is these valuable species that are frequent candidates for removal.
We are now in an important public comment period that ends on April 24, and we are asking you to take action by sending a letter with your comments to Shilpa Gupta at Shilpa.Gupta@lacity.org before the deadline (See sample below).
cc: (from BOE) Julie.Sauter@lacity.org, Robert.Vega@lacity.org, email@example.com, firstname.lastname@example.org, email@example.com
cc: StreetsLA - firstname.lastname@example.org, email@example.com
cc: all councilmembers, and the Mayor
Shilpa Gupta, Environmental Supervisor I
City of Los Angeles Public Works, Bureau of Engineering
Environmental Management Group
1149 S Broadway, Suite 600, Mail Stop 939
Los Angeles, CA 90015
Re: Public comments for Sidewalk Repair draft Environmental Impact Report
Dear Shilpa Gupta:
The _________________ Neighborhood Council appreciates the extension of the public review period for the Citywide Sidewalk Repair - Draft Environmental Impact Report, so that we may submit the following comments:
INSERT YOUR LANGUAGE HERE - WHY IS THIS IMPORTANT TO YOUR COMMUNITY
Public participation is an essential part of the CEQA process, and thus we request and expect to see our comments/questions responded to and incorporated into the final EIR.
DRAFT EXAMPLES: The (your NC name here) requests:
1) that every possible effort be made to retain and protect existing healthy mature trees by implementing alternative designs, paid for by the program, so that no more than 30% of the total projected trees currently slated, are actually removed.
2) that only those trees absolutely necessary to be removed for sidewalk repair be removed, not whole blocks of trees that are not causing problems.
3) that all trees removed for the sidewalk repair program be mitigated at a ratio of 4:1 with species of equal size at maturity and located in the same neighborhood as those removed.
4) that the EIR be amended to consider tree removal a significant adverse impact with binding mitigation measures that restore the canopy level much sooner than 30 years.
5) that every tree removal continue to have the due process of notification through an Urban Forestry Division tree removal notice and that removal of 3 or more trees at a given site continue to have a Board of Public Works hearing.
6) that newly planted trees are guaranteed good quality soil and amendments, as well as frequent irrigation, for a minimum of 3 years and longer as needed by species, in order to guarantee survivability.
(include mailing address & cc's)