August 8, 2017
Long Range Planning Supervisor
Department of Parks and Recreation
Dear Ms. Lazic:
Thank you for the opportunity to comment on the Public Spaces Master Plan Draft. We believe the draft Public Spaces Master Plan can be improved in four important ways.
First, our main substantive concern is that the Plan does not address adequately the severity of the loss of tree canopy already impacting our county and the attendant reduction in the numerous benefits that a protected natural environment brings to our community, our people, and the wildlife that share Arlington with us. We, like a growing number of Arlingtonians, are very concerned about the rapid pace of removals. On July 26, we hosted a meeting of more than 40 Arlington residents actively involved with tree preservation to identify and discuss these issues. We found strong, unanimous support for the proposition that trees should be protected as well as many thoughtful ideas for improving the urban forest over time. While the Priority Action 1.6 (p.97) states that “nearly two-thirds (64 percent) of respondents indicated they would support maintaining and preserving existing trees and natural areas — the highest rated improvement to the parks and recreation system.”, Action 1.6 includes no items to address this at all. This is a glaring omission to any open space plan. Action Plan 3.4.2 vaguely proposes to only “Promote the planting, preservation, and maintenance of canopy trees on public and private land” with no measures for success.
Second, the Plan’s organization is confusing and key aspects of the Context do not appear to be consistent with Strategic Directions, Action Plan and Physical Vision Plan. The draft presents three aspects of a vision, six major objectives, five key recommendations, five priorities, and multiple unnumbered sub-recommendations. Better integration could yield a small number of high-level goals, each supported by specific, measurable objectives. A better organized Plan would be better understood, and more effectively implemented. For instance, with regard to preserving Arlington’s urban forest, there is a recognition that residents consider this is a priority (Priority 1.6) but a surveying the tree canopy is not scheduled in time to provide essential information in defining the context and the goals needed for natural areas. Similarly, to properly balance between recreational and other priorities, these connections across the Plan must be recognized Plan.
Third, you have already heard many ideas on improving the Plan, including preserving the trees at Lubber Run, preserving trees in Donaldson Run, and converting one of the softball fields in Aurora Highland Civic Association to a public park space that is not for organized sports, among many others. Drawing on their insights of the attendees at the July 26th meeting and our own work to preserve trees in Arlington, we have compiled a first set of comments for consideration. The Plan should much more explicitly incorporate the protection and development of Arlington’s tree canopy into the management of public spaces in general. This will increase its value to county residents.
Some specific comments on the recommendations in the 2005 Public Space Master Plan are also very relevant to the current draft plan, including:
- (page 42: priority 2, recommendation 1.2) – Protection of mature trees should be included as a central goal of a land acquisition policy. Moreover, to advance the goal of tree preservation, land acquisition policy should incorporate a “Life Cycle of Ecology” as follows using the transfer of development land rights process:
(a) Arlington County establishes seed funding account, and replenishes as needed;
(b) Arlington conducts planning and site selection;
(c) Arlington County buys a lot offered by a resident;
(d) Arlington County pays market value for the property (not eminent domain, not condemnation value) in order to make the property seller whole;
(e) Arlington County then uses some of the cash in the seed fund to remove the existing residence, the driveway, lead walkways, patios, garages and sheds, to include removal of residential utility supply lines (water, sewer, gas); and plant native species to preserve these natural spaces throughout the county.
(f) The newly acquired property is protected with a conservation easement;
(g) Then Arlington County transfers the development/density rights to the Transfer of Development Land Rights bank – making it available to developers to purchase for additional residential density on properties within designated TDR-receiver zones;
(h) Recognizing that the TDR’s may sit in the TDR bank for some time it is essential for the County to continue to provide seed funding for this program;
(i) When the TDR is purchased by a developer, then the funds from that sale are reinvested into the seed fund to promote the purchase of additional properties.
- (page 43: priority 3, recommendation 1.3, sub-recommendation 1) – Protection and enhancement of trees should be added as a guiding principle to the Four Mile Run Restoration Master Plan.
- (page 44: priority 4, recommendation 2.1; page 50: objective 3, recommendation 3.2, sub-recommendation 1) – Trees should be acknowledged as the most important kind of natural resource about which data needs to be collected, managed, and evaluated in data bases and GIS systems. The need for better data and analysis has two aspects. The first involves the need for more current data on the tree canopy in Arlington. Time series data reflects a rapid, and possibly accelerating, loss of trees; because the data currently available is woefully out of date, however, here is no accurate way to assess the extent of the problem. A second aspect involves the failure to adequately account for the environmental and economic benefits of trees in planning decisions made in the County. We can’t be good stewards of our natural resources if we don’t adequately value our trees.
- (page 47: objective 2, recommendation 2.2) – The County’s policy of striving to have a sustainable urban forest should be elevated in the Plan and supported with specific, quantifiable objectives (e.g., percent change in canopy, number of new plantings, survival rate of new plantings, initiatives to review and update incentive policies related to the protection of mature trees, and a more robust invasive species removal process, etc.).
Fourth, another difficulty we have with the Plan relates not only to our group’s concern with preserving the natural environment but also to the Plan’s own overarching goals of smart growth, sustainability, and inclusion (page 6). The use of high-intensity, dark-sky lighting as envisioned contradicts the Plan’s own professed values. The Plan should forgo the use of such lighting, which is incompatible with the goal of sustainable development because it disrupts and harms the habitats of all living things in and around fields – including humans. Further use of this technology also is incompatible with the goal of inclusion because residents have consistently expressed opposition to expanded lighting. Accordingly, we recommend the following specific improvements referencing the 2005 Plan:
- (page 41: priority 1, recommendation 1.1, sub-recommendations 1 and 2) – Revise the design of Phase I of the North Tract Master Plan to remove dark-sky lighting elements.
- (page 46: objective 1, recommendation 1.7, sub-recommendation 1) – Remove the use of dark-sky lighting as part of a strategy to obtain maximum use and availability of multi-purpose turfs.
Fifth, while we think the draft Plan is on the right track in proposing a Natural Resource Management Plan that integrates plans and strategies across the County (page 44), we suggest there’s a better way to do this:
- (page 45: priority 5, recommendation 5.1, sub-recommendation 3) – Rather than create an Inter-Agency Coordinating Board, designate a Tree Ombudsman to maintain a focus on tree preservation and re-development throughout County activities. To be effective, such a person must have sufficient authority to cross organizational lines within the units of County government.
Again, thank you for the opportunity to comment. We look forward to working with you to put into effect an urgent focus on the need to preserve and protect our trees.
Sincerely, Arlington Tree Action Group: