August 11, 2017
Dear Ms. Lazic,
Okay, I give up. Having spent hours futilely waiting for pages to refresh themselves so that I could actually enter comments, I have stopped trying to submit comments using the county’s online tool for the draft Public Spaces Master Plan (PSMP). If the county truly wanted the public to submit comments on this voluminous document, it is a mystery to me why such an inadequate public comment tool was selected. I have also asked why the comment period was limited to the July–August time frame, as this is high vacation season when most citizens are out of town on vacation. I was told that it was either collect comments now (July-August) or never due to the “schedule” that was set — but there has been no explanation as to why such an impractical and counter-productive schedule (from a public engagement standpoint) was adopted in the first place. Since the deck seems to be stacked against providing comments, tt would appear that the county does not truly want public comment or feedback on this document. Am I surprised? No. Disappointed? Yes.
Though it is certainly long and exhaustive document in certain respects, the draft PSMP is a paradox full of contradictory and diametrically opposing goals and directives, treating all public spaces the same and making NO DISTINCTION between how sensitive natural lands/resources (trees, indigenous plants and animals, wildlife habitat, riparian areas, streams, watersheds, etc.) should be cared for and preserved/conserved/restored vs. how barren concrete courtyards between buildings should be treated. Under this plan, they are the same, which says a lot about how biased against nature that Arlington County government and elected officials are.
For example, priority actions 3.1 and 3.2 call for updating the Natural Resources and Urban Forest Master Plans. Fine. But these plans are subordinate to the PSMP. So the priority actions 1.2.2, 1.2.7 and 1.3, which call for parkland development, functionally preempt any true preservation/conservation/restoration priorities or goals contained in the Natural Resources and Urban Forest Master Plans. Those of us who value nature have watched in horror as the county has successively cut down mature trees and covered natural and open space — including in public parkland and in purportedly protected Chesapeake Bay Act resource protection areas (RPAs) — with tons of additional concrete, asphalt and built infrastructure. It’s as though DPR’s prime directive is to wage an all-out war against nature. Over 100 mature trees are to be destroyed on the Lubber Run Park/Community Center site alone.
Likewise, priority action 1.6 (Ensure high-quality visual and physical access to the Potomac River, Four Mile Run and their tributaries) directly UNDERMINES action 3.3 (Protect, restore, and expand natural resources, particularly riparian corridors along County waterways). We all know what ensuring “high-quality visual and physical access” — it means more chainsaw massacres of existing trees and vegetation and paving over every scrap of land humanly possible even though these areas are next to important surface waters that are already stressed and degraded.
Arlingtonians have made it crystal clear where their priorities lie. They choose the preservation/conservation/restoration of nature as their priority, which is NOT supported by this draft PSMP. See Figure 17 below, which is based on the “statistically valid” public survey conducted in 2016:
<PSMP 7-11-17 Draft Figure 17.jpg>
Yet in the draft PSMP, hiking is — remarkably — NOT INCLUDED as a type of recreation to which priority should be given, unlike every other sport under the sun. Arlingtonians place a high priority on investment is trails, natural areas and wildlife habitats, but I see NO priority given to these functions in the PSMP priority actions or really any actions stated in the PSMP. Why is nature and preservation/conservation/restoration NOT GIVEN ANY PRIORITY in the draft PSMP?
On page 21, the Community Facilities Study (2015) is mentioned. UNBELIEVABLY, the most important recommendation with respect to parks and public spaces is NOT EVEN MENTIONED: “Establish a land acquisition fund.”
Likewise, there is no mention of the changes to S-3A zoning (the zoning designation for most public parkland), which removes height limits and set-back requirements when building school buildings on public parkland. Zoning staff has openly signaled its intent to REMOVE ALL height limits and set-back requirements for ALL types of uses/buildings constructed on public parkland. This represents one of the largest threats to Arlington’s remaining natural lands and wildlife habitat. But the draft PSMP is SILENT ON THIS ALARMING THREAT that would open the floodgates to dense redevelopment of all public parkland.
Arlington Public Schools is mentioned largely in passing. However, Arlington’s public parkland and green spaces are increasingly being consumed by APS to build new schools rather than building up/under/over on its own sites. The news school on the Thomas Jefferson site will be built on public parkland. There will be a net loss of public parkland with the Wilson School-Firehouse redevelopment plan. Again, the draft PSMP is SILENT ON THIS ALARMING TREND.
Arlington has so little in the way of natural land and natural infrastructure remaining. And yet, the draft PSMP provides only meaningless lip service and toothless protections for these dwindling but critically important assets. Preservation/conservation/restoration of Arlington’s natural lands and waters, saving and restoring critical wildlife habitat, and preserving its remaining mature tree canopy and restoring the larger tree canopy should be a prominent element of the PSMP. But it is treated as more or less an afterthought. This is unacceptable.
The goal of the PSMP should be to reduce the loss of mature trees, which provide several important services — including the interception, detention, infiltration and evapotranspiration of storm water. Trees, particularly mature trees filter pollutants from the air, reduce summertime temperatures, release oxygen back into the atmosphere, and filter pollutants from storm water. They hold the soil in place to prevent erosion and they do all of running on free solar power. Trees, and particularly our few remaining mature trees, are our best weapon to fight air and water pollution and to mitigate the urban heat island effect and climate change. And yet Arlington County dismisses their value because they are god-given rather than man-made.
Though the PSMP talks a lot about the value of trees, it provides NO MEANINGFUL PROTECTIONS for Arlington’s remaining tree canopy. On page 43 of the PSMP, the 40% tree canopy coverage figure is from 2011 and is OUTDATED. A more current figure could and should be determined using the iTree analysis data collected in 2016 or other current remote-sensing data that can be obtained from other reliable sources.
<Important Ways Trees Retain Stormwater Runoff.jpg>
When it comes to trees, SIZE MATTERS. And mature trees provide exponentially greater benefit than younger, smaller trees. According to Eric Kuehler of the USDA Forest Service, “Tree Canopy Retains Rainfall”:
<Tree Canopy Retains Rainfall.jpg>
The USDA Forest Service in cooperation with the University of MA also developed tree “nutrition” labels to highlight the value of individual trees based on size and species. Below are the labels for a 27-inch-diameter red maple vs. a 14-inch-diameter pin oak:
<Tree Facts Red Maple.jpg>
As you can see, the 27-inch tree intercepts nearly twice storm water as the 14-inch tree. Large, mature trees play a crucial role in stormwater management and reduce the risk of flooding — yet the PSMP sets NO PRIORITY ACTIONS for their preservation.
The PSMP contains little or no information collected in Arlington’s 2016 iTree Ecosystem Analysis, I highly recommend adding this information to the PSMP: https://arlingtonva.s3.dualstack.us-east-1.amazonaws.com/wp-content/uploads/sites/13/2017/02/iTree-2016-Written-report.pdf
These two charts are particularly relevant:
<Percent of trees by size.jpg>
<Trees – Avoided Runoff and Dollar Value.jpg>
As you can see, smaller trees now predominate. Arlington’s tree canopy loss has been well documented — a 1% per year loss of tree canopy (total of 3% loss) between tree canopy surveys performed in 2008 and 2011. If this rate of loss has been sustained into 2017, then the current canopy coverage stands at just 35%:
<Tree Canopy Loss 2008-2011 – from 43 to 40 Percent.jpg>
<Acres of Canopy Change by Watershed 2008-2011.jpg>
Source: Adopted 2014 Stormwater Master Plan — https://arlingtonva.s3.dualstack.us-east-1.amazonaws.com/wp-content/uploads/sites/31/2014/05/SWMP_FINAL_Sept2014.pdf
I could go on and on for days about the shortcomings of the draft PSMP. I will stop here but will repeat my main objection: There is an inherent bias against the preservation/conservation/restoration of Arlington’s natural lands and resources in this draft PSMP — critical and valuable natural assets. Arlington’s own statistically valid survey documents that the majority of Arlingtonians want to make investment in its natural resources and lands to be a priority. Yet, the draft PSMP treats this imperative as if it were optional. Arlington County government has more than sufficient evidence of the degradation it continues to inflict on what remain of our natural environment, which has been severely degraded and is hanging on by a thread. If Arlington County truly believes in climate change, then it MUST take active steps toward relieving the urban heat island effect instead of fueling it, as it has done for the past 30 years.
A good first step would be to update its identification of critical natural resources, natural lands, wildlife habitat, riparian areas (including Chesapeake Bay Act resource protection areas) and other ecologically sensitive areas and assets, to catalogue the remaining inventory of its mature trees and then to provide concrete guidelines and directives to preserve/protect/conserve/restore these valuable assets. These natural assets have a valuable and crucial role to play in offsetting the urban heat island effect, improving the local environment and supporting human health. I also recommend elevating the Natural Resources Management Plan and Urban Forest Master Plan to make them full-fledged components to the county’s Comprehensive Plan rather than subordinating them to the PSMP. The goals/priority actions/protections to support nature must be given a priority in the PSMP and implemented in actual practice — a change from today’s reality. Only in this way will Arlington begin to reverse its long-standing trend of favoring development (even of its most sensitive natural lands and resources) and degrading its environment
With kind regards,
Suzanne Smith Sundburg