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Jeff Hayward_First Street Tunnel EA Comments 5.15.2013

Jeff Hayward_First Street Tunnel EA Comments 5.15.2013

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Published by bloomingdalecc
Flagler resident Jeff Hayward's comments on DC Water's First Street Tunnel plans impact on mature shade trees.
Flagler resident Jeff Hayward's comments on DC Water's First Street Tunnel plans impact on mature shade trees.

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Published by: bloomingdalecc on Jun 21, 2013
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1Emanuel BriggsFirst Street Tunnel EA CommentsDC Clean Rivers Project5000 Overlook Avenue SWWashington, DC 20032May 15, 2013Dear Mr. Briggs:I wish to submit to the public record the following comments and concerns with reference to the DCWater and Sewer Authority, DC Clean Rivers Project Division P – First Street Tunnel EnvironmentalAssessment dated April 12, 2013. I understand these comments to concern a Draft EnvironmentalAssessment report (hereafter referred to as “EA”) and I fully anticipate these comments to beconsidered in the preparation of a response, prior to finalization of the EA or decision by DC Water onthe alternatives presented in the EA.If DC Water should wish to contact me regarding this submission, please do so by emailat  jeffreywhayward@gmail.com or by phone at 202-294-7008. I do not request that my name bewithheld from the record and, on the contrary, would like my comments to factor into the public record.Comments will be submitted by topics and in sequential numbered order.I am most concerned about impact topics that were dismissed from further study, deemed as beingnegligible per study definitions, but which represent material and measurable impacts in the mediumand even long term. My request is that stated topics are given full consideration and are not dismissed.In addition, I raise comments about my concerns related to issues of process and planning, which needto be redressed in order to adequately reflect the community inputs and needs for full, effective, andfair consultation.
Vegetation (2.9.3)
I disagree with EA’s dismissal of the removal of vegetation, in particular urban street trees, as an impacttopic for further study. The cutting down of mature, well-developed trees of substantial size, inparticular those greater than 20” diameter at breast height and over 45’ in height, is an act of someconsequence. I draw specific attention to a cluster of 6 street trees growing on the west and east sidesof the north end of Flagler PL NW, which are between 19” and 25” diameter (23” average) and average50’ in height. These are older oak
(Quercus phellos),
(Acer saccharum) ,
and sweetgum
(Liquidambar styraciflua)
trees, estimated at more than 50 years age. There are substantial valuesrepresented in trees of such species, growth form and quality that are lost when such vegetation isremoved and which cannot be regained for a long time.Under the best scenarios, it would probably take 20-30 years for replacement trees to reach acomparable level of development to those being scheduled for cutting. While it is a requirement for DC
2street trees to be replanted after removal, there is no assurance that the seedling stock will be of sufficient size, vigor, and maintained carefully after planting to permit best growth. Even under optimalconditions of tending many new street trees die and grow slowly. These species are all relatively slow-growing hardwoods. It will therefore be 2035 or later before replacement trees can be consideredcomparable in value to those removed, which assumes a best-case scenario of full survival, healthygrowth, and good development.It is the
of these street trees to the homeowners and city that will be impacted and will result inimmediate loss and will result in cumulative loss over the ensuing years. According to the DCDepartment of Transportation,
 Assessment of Urban Forest Resources and Strategy 
, 2010, the urban treecanopy, including street trees, provide many environmental andsocial benefits, including reducingstorm-water runoff and the city’s carbon footprint, improvingair quality, providing habitat for wildlife,contributing to savings on energy bills, increasingproperty values, and enhancing quality of life. While allof these benefits are important, I will focus on monetary values.A study in Portland, Oregon, by the USDA Forest Service showed that a tree in front of a home increasedthat home’s sale price by more than $7,000 and that it also increased the value of the homes around it.(Donovan, 2010). Other references from the USDA Forest Service state that healthy, mature trees addan average of 10% to a property's value. The Maryland Department of Natural Resources
Forest HealthReport,
states that the value of a lot with trees averages 5-7% higher than a lot without, and theincrease in value can be as much as 20%. While the Council of Tree and Landscape Appraisers, who setthe industry standard for tree valuation methods, estimate that a mature tree can often have anappraised value of between $1,000 and $10,000. These six trees and their canopy are stationed in closeproximity to seven households.Looking at just one of these homes, the house at 134 Adams St NW, can illustrate the value at stake andthe potential economic impact of removing the vegetation that is overlooked by the EA. This propertywas sold in February 2012 for $640,000. The home is bounded on its western side by 3 mature sugarmaples of 19”, 24”, and 24” diameters and approximately 50’ in height. Considering the range suggestedby the Maryland DNR, at the low-end of the potential range of 5-7% of the sale value, these trees maycontribute between $32,000 and $44,800 of the value of the property of that single residence. However,as mentioned, these large, mature shade trees are situated near seven households, and representproperty sale value to each homeowner. Even taking a much lower amount, say $10,000 per householdbenefiting from these street trees, there is a potentially significant loss of property value at stake.There will be foregone value to the property owners (and assessed tax values to the District) on thenorthern end of Flagler PL NW and Adams ST NW that will be of at least medium-term and possibly long-term (particularly for those owners who must sell their homes in the short to medium-term, while thenew seedlings are developing and not mature (as small, young trees have much less value than fully-developed, older trees.)I request that the EA analyze the consequences of impacts of alternatives on removal of vegetation.
Visual Resource and Aesthetics (2.9.5)
I disagree with EA’s dismissal of impacts to visual resources and aesthetics caused by the removal of trees, as an impact topic for further study. In the city, trees are remarkable in being an object of beautyin themselves, but also working in concert with other trees they become a central landscape feature
3that defines our sense of space, softens the built environment, emphasizes the character of historicarchitecture, and thus functions as a visual resource.The quality from a visual perspective of a large, mature tree with a canopy that extends up and overmuch of a street and its houses is far more appealing than young, recently planted trees. Thereplacement trees, with 2” diameters and height of 8-10’ on average will take 20 to 25 years to restorethe present condition and aesthetics. It is wrong not to take this loss more fully into consideration in theEA.
Excellent visual resource of large, old trees on north end of 2200 block of Flagler PL NWLimited visual resource with small, young trees (planted inlast 5 years) at W and Flagler PL NW
I request that the EA analyze the consequences of impacts of alternatives on impairment of visualresources and aesthetics. 
Inadequate Assessment of Alternatives
The alternatives considered do not represent a full range of possible options for the central constructionelements of the First Street Tunnel. The alternatives thus are somewhat of a false dichotomy – betweendoing relatively little or building the First Street Tunnel. What the community expects is a considerationof the impacts from a range of possible options within Alternative B. So for the construction of thetunnel, what would be an Alternative B1, B2, or B3?For instance, there were three options presented by DC Water on the construction of an access road toMcMillan site. We ask for a similar range of options for the siting of the staging area and diversionstructures on Adams ST NW and Flagler PL NW. Within these options there should be different locations

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