{"id":1880,"date":"2026-06-27T17:44:20","date_gmt":"2026-06-27T17:44:20","guid":{"rendered":"https:\/\/newbellevue.com\/?p=1880"},"modified":"2026-06-27T18:01:15","modified_gmt":"2026-06-27T18:01:15","slug":"letter-about-tree-credit-change-for-sr-1-areas","status":"publish","type":"post","link":"https:\/\/newbellevue.com\/?p=1880","title":{"rendered":"Letter about tree credit change for SR-1 areas"},"content":{"rendered":"\n

This letter from a community which would be affected by the “non-controversial” changes proposed as part of the Omnibus code change<\/a> was compelling to me. It is disappointing that something with obvious drawbacks like this was included in the Omnibus, since the Omnibus includes other major changes to the large development approval process that I think the Planning Commission should have had more time to focus on. The SR-1 zoning classification is new since 2024, and is equivalent to R-2.5.<\/p>\n\n\n\n

Since the tree credits cost $1300 per credit <\/a>and the difference between the current and proposed requirement is 2.5 tree credits<\/a> per 1000 SF of lot area when there are more than two homes on a lot, a 13,500 SF lot would save $45,500 by reducing their contribution to city-wide replacement tree planting if this change passes, and if they are able to keep or plant trees that meet the requirement, they are not charged anything. <\/p>\n\n\n\n

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Dear Mayor Malakoutian, Deputy Mayor Hamilton, Councilmembers Bhargava, Briar, Nieuwenhuis, Robinson, and Sumadiwirya, <\/p>\n\n\n\n

Thank you for considering this request. We also appreciate Nick Whipple\u2019s detailed response explaining the implementation concerns staff has identified on certain SR-1 projects. We understand that the City should examine requirements that may have produced disproportionate outcomes, including unusually high replacement-tree obligations or fees. We are not asking the City to disregard those implementation concerns. <\/p>\n\n\n\n

However, our concern is whether a uniform citywide reduction in SR-1 tree-credit requirements appropriately accounts for the substantially different conditions present in East Kelsey Creek.  Staff\u2019s explanation refers specifically to SR-1 lots that are 13,500 square feet in size. In contrast, Wilburton properties North of NE 8th Street include parcels exceeding one acre. These properties include mature canopy, connected private yards, and environmental conditions associated with the Kelsey Creek watershed. Those parcels are substantially larger than the 13,500-square-foot SR-1 minimum lot area described in staff’s explanation and also larger than the 35,000-square-foot LL-1 minimum lot area shown in the City’s dimensional chart<\/strong>.<\/p>\n\n\n\n\n\n\n\n

 We recognize that gross parcel size alone does not determine a site\u2019s tree-credit obligation because Tree Canopy Site Area excludes critical areas, buffers, and certain setbacks. That is precisely why we ask whether staff\u2019s analysis distinguished among the actual Tree Canopy Site Area, buildable area, existing mature canopy, development type, and environmental constraints of the permits relied upon before recommending one uniform reduction for all SR-1 parcels.<\/p>\n\n\n\n

\"\"<\/figure>\n\n\n\n

The aerial context shows that this remaining canopy area is surrounded by more intensive housing, commercial development, transportation corridors, and hard surfaces in BelRed and Wilburton. We respectfully ask whether staff\u2019s implementation analysis distinguished between typical minimum-size SR-1 lots and substantially larger, mature-canopy parcels with connected mature canopy that may support wildlife movement tribuand watershed constraints before recommending a uniform reduction in SR-1 tree-credit requirements.<\/strong><\/p>\n\n\n\n

This distinction matters. A citywide amendment designed to address outcomes on relatively small SR-1 lots may not be appropriately tailored to unusually large, environmentally constrained SR-1 parcels in the East Kelsey Creek watershed. The relevant question is not simply whether all SR-1 lots should receive the same reduced credit requirement. It is whether staff has distinguished among actual parcel size, buildable area, mature canopy condition, critical-area constraints, and watershed function before applying a uniform reduction.<\/p>\n\n\n\n

We also understand that staff’s immediate concern may be the scale of replacement-tree credits or fees triggered by certain SR-1 projects. But that concern does not fully answer the separate question of what happens to existing mature canopy. Lowering the tree-credit obligation may make the code more workable for some applicants, but it may also reduce the practical incentive to retain mature trees or provide replacement that meaningfully offsets their loss. Mature, full-canopy trees provide shade, rainfall interception, habitat structure, wildlife cover, cooling, and stormwater benefits that newly planted replacement trees cannot provide for many years.<\/p>\n\n\n\n

For the same reason, reliance on the Critical Areas Ordinance alone does not fully resolve the connected-corridor concern. The CAO protects streams, wetlands, buffers, and certain specifically identified habitat areas. But connected mature canopy between streams, parks, ravines, and open spaces may fall outside mapped critical-area buffers or specifically designated corridors. Those upland trees can still provide cover, stepping-stone habitat, stormwater infiltration, and safer wildlife movement between habitat blocks. Critical-area buffers protect important pieces of the system, but they do not necessarily protect the connective tissue between them.<\/p>\n\n\n\n

This is why the Planning Commission discussion is important. Commissioners Kennedy and Ferris encouraged staff to speak with the Kelsey Creek neighborhood about whether local conditions near critical areas, parks, preserves, and wildlife corridors warrant a more tailored approach. Commissioner Khanloo likewise urged the City to \u201cfigure out something\u201d for distinctive SR-1 areas, identifying Kelsey Creek, Enatai, and Bridle Trails as examples, and emphasized the importance of structuring tree credits in a way that incentivizes retention of existing trees. The mature tree canopy provides essential shade and cooling that help sustain habitat function. Those comments support a more site-sensitive approach rather than assuming that all SR-1 parcels present the same conditions. If staff\u2019s implementation concern is primarily driven by smaller or more typical 13,500-square-foot SR-1 lots, that does not by itself establish that the same reduction is appropriate for substantially larger East Kelsey Creek parcels whose size, canopy, and practical development potential may be closely tied to critical-area and watershed constraints.<\/p>\n\n\n\n

Our earlier request also asked why this amendment is being characterized as a minor or low-controversy refinement. Staff’s response explains why a recalibration may be warranted, but it does not explain why reducing SR-1 tree-credit requirements by approximately 60 percent for one-dwelling development and 62.5 percent for two-or-more-dwelling development is considered minor. The amendment may be narrow in scope because it applies to SR-1, but narrow in scope is not necessarily minor in effect.<\/p>\n\n\n\n

Before final Council action, we respectfully request a written staff response addressing the following:<\/p>\n\n\n\n

    \n
  • Why a roughly 60 percent to 62.5 percent reduction in SR-1 tree-credit requirements is considered minor or low controversy;<\/li>\n\n\n\n
  • The number and characteristics of the SR-1 permits staff relied upon, including lot size, development type, tree-credit calculation, whether mature-tree removal occurred, and whether parcels were constrained by critical areas, buffers, slopes, wetlands, or other environmental limitations;<\/li>\n\n\n\n
  • Whether staff evaluated East Kelsey Creek’s SR-1 canopy, stream and riparian connections., wildlife-movement function, and watershed conditions before recommending a uniform SR-1 reduction;<\/li>\n\n\n\n
  • Whether alternatives more narrowly tailored to demonstrated implementation problems were evaluated, such as additional retention credit, a site-specific adjustment process, or a limited hardship pathway;<\/li>\n\n\n\n
  • How staff will measure whether the amendment reduces retention of existing mature trees or lowers expected long-term canopy outcomes, rather than only reducing replacement-tree credits or fees; and<\/li>\n\n\n\n
  • Whether planning staff will meet with the East Kelsey Creek Neighborhood Association to identify whether distinctive SR-1 areas near streams, parks, preserves, or wildlife corridors warrant a more tailored approach that both addresses demonstrated implementation problems and better incentivizes retention of existing mature trees.<\/li>\n<\/ul>\n\n\n\n

    Our concern is not that every SR-1 parcel should be treated identically. It is that a citywide reduction should not proceed without showing why it is minor, whether the cited implementation problems are representative of environmentally constrained large-parcel SR-1 areas, and how the City will protect the mature-canopy and connected-watershed functions in the places where they are most important.<\/p>\n\n\n\n

    Before final action, we respectfully ask Council to direct staff to evaluate East Kelsey Creek\u2019s SR-1 mature canopy, connected private-property canopy, stream and riparian connections, watershed conditions, and environmentally constrained parcels. That evaluation should determine whether a uniform reduction in SR-1 tree-credit requirements is appropriate for areas with these conditions and report how the proposed reduction aligns with Bellevue\u2019s goals for tree canopy, wildlife habitat, stream function, stormwater management, and climate resilience.<\/p>\n\n\n\n

    We respectfully request that Council consider that evaluation and staff\u2019s findings before taking final action on the amendment.<\/p>\n\n\n\n

    Thank you again for your response and for considering these questions.<\/p>\n\n\n\n

    Respectfully,<\/p>\n\n\n\n

    Phyllis White
    Board President
    East Kelsey Creek Neighborhood Association<\/p>\n","protected":false},"excerpt":{"rendered":"

    This letter from a community which would be affected by the “non-controversial” changes proposed as part of the Omnibus code change was compelling to me. It is disappointing that something with obvious drawbacks like this was included in the Omnibus, since the Omnibus includes other major changes to the large development approval process that I […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-1880","post","type-post","status-publish","format-standard","hentry","category-uncategorized"],"_links":{"self":[{"href":"https:\/\/newbellevue.com\/index.php?rest_route=\/wp\/v2\/posts\/1880","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/newbellevue.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/newbellevue.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/newbellevue.com\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/newbellevue.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=1880"}],"version-history":[{"count":4,"href":"https:\/\/newbellevue.com\/index.php?rest_route=\/wp\/v2\/posts\/1880\/revisions"}],"predecessor-version":[{"id":1885,"href":"https:\/\/newbellevue.com\/index.php?rest_route=\/wp\/v2\/posts\/1880\/revisions\/1885"}],"wp:attachment":[{"href":"https:\/\/newbellevue.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=1880"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/newbellevue.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=1880"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/newbellevue.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=1880"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}