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HomeMy WebLinkAboutD_Fred Meyer Tree Removal_20250630_FinalDEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT Routine Vegetation Management Permit and Critical Areas Exemption PLANNING DIVISON ROUTINE VEGETATION MANAGEMENT PREMIT EVALUATION FORM & DECISION DATE OF DECISION: June 30, 2025 PROJECT NUMBER: LUA25-000194, RVMP PROJECT NAME: Fred Meyer Tree Removal PROJECT MANAGER: Ashley Wragge, Assistant Planner OWNER: Sara Abdelrahman, Property Manager on behalf of Kite Realty 30 S Meridian Street, Suite 1100, Indianapolis, IN 46204 APPLICANT/ CONTACT: John Cvikota, The Davey Tree Expert Company 8622 S 222nd St, Kent, WA 98032 PROJECT LOCATION: 17801 108th Ave SE, Renton, WA 98055 (APN 3223059016) PROJECT DESCRIPTION: The applicant, John Cvikota from The Davey Tree Expert Company, is requesting a Routine Vegetation Management Permit (RVMP) to remove five (5) trees from the Fred Meyer parking lot located at 17801 108th Ave SE (APN 3223059016). The subject property is approximately 544,650 square feet (12.5 acres) and is situated within the Commercial Arterial (CA) zone and the Benson Community Planning Area. According to City of Renton (COR) Maps, the property is encumbered with sensitive and protected slopes (>15% & <=90%). An Arborist Report, prepared by The Davey Tree Expert Company, dated April 15, 2025 (Attachment A), was submitted with the application. In the report, the ISA Certified Arborist, John Cvikota, proposes the removal of five (5) pine trees (Pinus sp.) ranging from eleven inches (11”) to sixteen inches (16”) in diameter at breast height (dbh) and approximately twenty feet (20’) to thirty feet (30’) tall. In the report, the arborist notes that the history of property damage to the tree planter islands and the surrounding asphalt in the parking lot are due to these trees and that the planter islands are too restrictive for large pine trees. The arborist states that these trees are likely to continue damaging the tree planter islands and parking lot, and therefore, a more suitably sized tree should be considered. CRITITCAL AREA: Sensitive and protected slopes ROUTINE VEGETATION MANAGEMENT REVIEW CRITERIA 4-9-195D.4: Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 City of Renton Department of Community & Economic Development Fred Meyer Tree Removal Routine Vegetation Management Permit LUA25-000194, RVMP Permit Date: June 30, 2025 Page 2 of 4 YES, IF CONDITIONS ARE MET 1. The lot shall comply with minimum tree credit requirements pursuant to RMC 4-4-130, Tree Retention and Land Clearing Regulations. Staff Comments: In accordance with RMC 4-4-130H, compliance with tree credit requirements necessitates a minimum of 30 tree credits per net acre. The subject property, located at 17801 108th Ave SE (APN 3223059016), is approximately 544,650 square feet (12.5 acres). Based on the property size, 375 tree credits are required to meet the minimum tree density requirement (30 tree credits per acre × 12.5 acres = 375 credits). According to the Tree Retention and Tree Credit Worksheet (Attachment B), the property has 35 trees, which are six-inch (6”) caliper or greater in size after deducting the five (5) trees proposed for removal. Page 2 of the Tree Retention and Credit Worksheet (Attachment B) shows that the 35 trees included in the calculations total 164 tree credits. Per code standards, this is not a sufficient amount of tree credits for a parcel of this size. The code does not distinguish residential standards from commercial standards for tree density when applying the code but the approximate tree quantity for this parcel does follow similar guidelines found in current code regarding parking lot landscaping. For example, when a site visit was conducted, there seemed to be a tree within fifty feet (50’) of every parking stall. This indicates that the approximate tree density currently sustained at the site is within similar parameters of current parking lot tree density requirements. The applicant proposes the five (5) pine trees proposed for removal to be replaced at a one-to-one (1:1) ratio with five (5) red sunset maple trees that are two-inch (2”) caliper in size. This replacement would meet the approximate density appropriate for a commercial parking lot. As a result, staff recommends as a condition of approval that the applicant plant five (5) red sunset maple trees that are two-inch (2”) caliper in size. One (1) tree shall be planted in each location where the five (5) pine trees are proposed for removal. YES 2. The land clearing and tree removal shall be consistent with restrictions for critical areas, pursuant to RMC 4-4-130, Tree Retention and Land Clearing Regulations, and RMC 4-3- 050, Critical Areas Regulations. Staff Comments: As seen on the City of Renton (COR) Maps, this property has sensitive and protected slopes (>15% & <=90%). The protected slope area is on the very northwestern corner of the property and appears to be due to grading between the shopping center and the roadway, namely 105th Pl SE. The pine trees proposed for removal are located outside the protected slope area, which means the proposed removal does not require additional critical areas review, and therefore the proposed action is consistent with restrictions for critical areas. N/A 3. Removal of a landmark tree shall meet the review criteria for removal of a landmark tree, pursuant to RMC 4-4-130, Tree Retention and Land Clearing Regulations. Staff Comments: Per RMC 4-11-200, Definitions T, a landmark tree is classified as such if it measures with a caliper of twenty-four inches (24") or greater, except for big leaf maples, black cottonwoods, and red alder trees, which qualify as landmark trees with a caliper of thirty inches (30") or greater. The trees proposed for mitigation are between eleven inches (11”) to sixteen inches (16”) in diameter at breast height (dbh). Per the City’s classification these are significant trees; therefore, the review criteria for removal of landmark trees do not apply. Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 City of Renton Department of Community & Economic Development Fred Meyer Tree Removal Routine Vegetation Management Permit LUA25-000194, RVMP Permit Date: June 30, 2025 Page 3 of 4 YES 4. Street frontage and parking lot trees and landscaping shall be preserved, unless otherwise approved by the Administrator. Staff Comments: The trees proposed for removal are located within parking lot landscaping. This permit would act as obtaining administrator approval to remove the trees located within ten feet (10') of a surface parking lot with ten (10) or more parking spaces. It is not reasonably feasible to preserve the five (5) pine trees marked for removal due to the reasoning proposed and additional factors observed during a site visit. The applicant contends that the large pine trees are constrained in the landscaping islands and the trees are causing damage to the surrounding parking area. Historic repairs and current damage can be seen in photographs provided in the Arborist Report (Attachment A). In addition to the reason stated in the removal request, staff noticed on site that Tree1, Tree 2, and Tree 3 are located in close proximity to parking lot lighting. While these trees have a reduced vigor due to the site constraints, they are still large pine trees with wide canopies that impact the lighting illumination levels of the parking lot light poles. Light poles are intended to provide clear visibility that promote the general public health, welfare, and safety, to accent key architectural elements and landscape features. These oversized trees negatively impact both visibility and safety. The alternative trees proposed by the arborist for replacement are a more size-appropriate alternative that addresses the concerns stated by the applicant and also interfere less with the parking lot illumination. For these reasons, staff supports replacing the parking lot trees instead of preserving the existing landscaping. YES 5. The land clearing and tree removal shall not remove any landscaping or protected trees required as part of a land development permit. Staff Comments: The proposed tree removals are a part of parking lot landscaping and removal of landscaping is not permissible per code. The existing oversized pine trees are incompatible with the island size and would pose continued challenges if the trees were preserved. No landscaping would be eliminated, rather the existing trees would be replaced with an alternative tree species that are more size-appropriate for the site conditions. This would mitigate the damage the existing trees are causing and would maintain landscaping requirements with more appropriate trees that are more likely to thrive in the restricted conditions. YES 6. The land clearing and tree removal shall maintain visual screening and buffering between land uses of differing intensity, consistent with applicable landscaping and setback provisions. Staff Comments: The trees proposed for removal are located in the interior of the parcel and are not intended to serve the function as visual screening and buffering between land uses. Therefore, the proposed removal and replacement would not negatively impact buffering or screening efforts. YES 7. The land clearing and tree removal shall not create or contribute to a hazardous condition, such as increased potential for blowdown, pest infestation, disease, or other problems that may result from selectively removing trees and other vegetation from a lot. Staff Comments: The provided documentation did not indicate that the removal and replacement of the pine trees with a more appropriate tree species would create or contribute to a hazardous condition. Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 City of Renton Department of Community & Economic Development Fred Meyer Tree Removal Routine Vegetation Management Permit LUA25-000194, RVMP Permit Date: June 30, 2025 Page 4 of 4 N/A 8. The land clearing and tree removal shall be consistent with the requirements of the Shoreline Master Program, pursuant to RMC 4-3-090F.1, Vegetation Conservation, and RMC 4-4-130, Tree Retention and Land Clearing Regulations. Staff Comments: Not applicable. The property is not located within shoreline jurisdiction. DECISION: The Fred Meyer Tree Removal Routine Vegetation Management Permit, LUA25-000194, RVMP is Approved* and subject to the following conditions: . *CONDITIONS OF APPROVAL: 1. The applicant shall plant flve (5) red sunset maple trees that are two-inch (2”) caliper in size. One (1) tree shall be planted in each location where the flve (5) pine trees are proposed for removal. SIGNATURE & DATE OF DECISION: Matthew Herrera, Planning Director Date RECONSIDERATION: Within 14 days of the decision date, any party may request that the decision be reopened by the approval body. The approval body may modify his decision if material evidence not readily discoverable prior to the original decision is found or if he flnds there was misrepresentation of fact. After review of the reconsideration request, if the approval body flnds sufficient evidence to amend the original decision, there will be no further extension of the appeal period. Any person wishing to take further action must flle a formal appeal within the 14-day appeal time frame. APPEALS: This administrative land use decision will become final if not appealed in writing to the Hearing Examiner on or before 5:00 PM on July 14, 2025. An appeal of the decision must be filed within the 14-day appeal period (RCW 43.21.C.075(3); WAC 197-11-680). Appeals must be submitted electronically to the City Clerk at cityclerk@rentonwa.gov or delivered to City Hall 1st fioor Lobby Hub Monday through Friday. The appeal fee, normally due at the time an appeal is submitted, will be collected at a future date if your appeal is submitted electronically. The appeal submitted in person may be paid on the flrst fioor in our Finance Department. Appeals to the Hearing Examiner are governed by RMC 4-8-110 and additional information regarding the appeal process may be obtained from the City Clerk’s Office, cityclerk@rentonwa.gov. EXPIRATION: The Routine Vegetation Management Permit shall be valid for one year from the date of issuance. An extension may be granted by the Planning Division for a period of one year upon application by the property owner or manager. Application for such an extension must be made at least thirty (30) days in advance of the expiration of the original permit and shall include a statement of justiflcation for the extension. ATTACHMENTS: Attachment A: Arborist Report, prepared by The Davey Tree Company, dated April 15, 2025 Attachment B: Tree Credit and Retention Worksheet Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 6/30/2025 | 12:19 PM PDT 1 Arborist Report April 15, 2025 Prepared For: Paciflc Landscape Management 17801 108th Ave NE Renton, WA 98055 Prepared By: John Cvikota The Davey Tree Expert Company 8622 S 222nd St Kent, WA 9032 ISA Certifled Arborist PN-9483A Tree Risk Assessment Qualifled Arborist Attachment A RECEIVED 06/18/2025 AWragge PLANNING DIVISION Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 2 Introduction The Davey Tree Expert Company was contracted by Paciflc Landscape Management to perform a Level 2 Tree Risk Assessment on flve (5) pine trees on their clients’ property that have caused signiflcant damage to concrete and parking lot. The trees were assessed by their location, size, current condition, and overall health. The data was then used to guide the potential strategies for care. The purpose of this report is to provide details of the current condition, health, and recommendations for maintenance. The flndings in this report can be used to make decisions on whether the tree may need to be removed or can be retained with restorative pruning and plant health care. Methods Data was collected by an ISA Certifled & TRAQ Arborist (John Cvikota: PN-9483A) on 04/10/2025. A Level 2 Assessment was performed which involved the following: A 360- degree walk around, visual evaluation of the tree where the crown, trunk, root fiare, above ground roots, and site conditions are evaluated with regard to speciflc targets. This is performed with simple tools such as a sounding mallet, soil probe, clinometer, etc. No physical inspection of the upper canopy, root crown excavation, resistograph or other technologies were used in the evaluation of the trees. The following attributes were collected for each site: Species: Trees were identifled by genus and species, cultivar if evident, and by common name. Diameter at Standard Height (DSH): Trunk diameter was recorded to the nearest inch at 4.5 feet above grade except where noted for each stem. When limbs or deformities occur at standard height, measurement was taken below 4.5 ft. Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 3 Height: Tree Height is estimated to the nearest <5ft. Avg. Canopy Radius: Average dripline distance was measured. Condition: Condition ratings were based on but not limited to:(1) the condition and environment of the tree’s root crown; (2) the condition of the trunk, including decay, injury, callusing or presence of fungus sporophore; (3) the condition of the limbs, including strength of crotches, amount of dead wood, hollow areas, and whether there was excessive weight borne by them; (4) the condition and growth rate history of the twigs, including pest damage and diseases; (5) the leaf appearance, including abnormal size and density as well as pest and disease damage. Using an average of the above factors together with the arborist’s best judgment, the general condition of the tree was recorded in one of the following categories adapted from the rating system established by the International Society of Arboriculture and 10th Edition of the Council of Tree & Landscape Appraisers (CTLA) Guide for Plant Appraisal: ● Excellent (81%-100%): High vigor and near-perfect health with little or no twig dieback, discoloration, or defoliation. Nearly ideal and free of structural defects. A nearly ideal form for the species and is generally symmetrical. ● Good (61%-80%): Vigor is normal for the species and has no signiflcant damage due to disease or pests. Twig dieback, discoloration, or defoliation is minor. Well-developed structure with minor defects that can be corrected easily. Minor asymmetries/deviations from species norm. Function and aesthetics are not compromised. ● Fair (41%-60%): Reduced vigor. Damage due to insects or diseases may be signiflcant and associated with defoliation but is not likely to be fatal. Twig dieback, defoliation, discoloration, and/or dead branches may comprise up to 50% of the canopy. A single structural defect of a signiflcant nature or multiple moderate defects. Structural defects are not practical to correct or would require multiple treatments over several years. Major asymmetries/deviations from species norm. Function and aesthetics are compromised. Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 4 ● Poor (21%-40%): Unhealthy and declining in appearance. Poor vigor and low foliage density and poor foliage color are present. Potentially fatal pest infestation. Extensive twig or branch dieback. A single serious structural defect or multiple signiflcant defects. Observed structural problems cannot be corrected. Failure may occur at any time. Largely asymmetrical or abnormal form. Form detracts from aesthetics or intended use to a signiflcant degree. ● Very Poor (6%-20%): Poor vigor and appears to be dying. Little live foliage. Single or multiple severe structural defects. Visually unappealing and provides little or no function in the landscape. ● Critical (1-5%) The tree is dying and/or presents an unacceptable risk which necessitates immediate removal. ● Dead (0%) Limits of the Assignment There are many factors that can limit speciflc and accurate data when performing evaluations of trees, their conditions, and values. The determinations and recommendations presented here are based on current data and conditions that existed at the time of the evaluation and cannot be a predictor of the ultimate outcomes for the trees. A visual inspection was used to develop the flndings, conclusions, and recommendations found in this report. Values were assigned to grade the attributes of the trees, including structure and canopy health, and to obtain an overall condition rating. No physical inspection of the upper canopy, root crown excavation, and resistograph or other technologies were used in the evaluation of the trees. Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 5 Tree Risk Assessment Tree #1: Pine Pinus sp. DSH Height Avg. Canopy Radius Condition 15” 25’ 20’ Fair Root and Root Collar: History of property damage to tree islands and asphalt. Most islands comprised of smaller maples with little to no damage. These pines are too big for these restrictive locations and will only cause more damage as time wears on. Risk Categorization: The likelihood root failure is Possible with a Medium risk of property damage parked vehicles and the occasional pedestrian. This event is Unlikely, and the consequences of impact are Signiflcant. Overall Tree Risk Rating: LOW Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 6 Tree Risk Assessment Tree #2: Pine Pinus sp. DSH Height Avg. Canopy Radius Condition 16” 30’ 25’ Fair Root and Root Collar: History of property damage to tree islands and asphalt. Most islands comprised of smaller maples with little to no damage. These pines are too big for these restrictive locations and will only cause more damage as time wears on. Risk Categorization: The likelihood root failure is Possible with a Medium risk of property damage parked vehicles and the occasional pedestrian. This event is Unlikely, and the consequences of impact are Signiflcant. Overall Tree Risk Rating: LOW Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 7 Tree Risk Assessment Tree #3: Pine Pinus sp. DSH Height Avg. Canopy Radius Condition 15” 25’ 15’ Fair Root and Root Collar: History of property damage to tree islands and asphalt. Most islands comprised of smaller maples with little to no damage. These pines are too big for these restrictive locations and will only cause more damage as time wears on. Risk Categorization: The likelihood root failure is Possible with a Medium risk of property damage parked vehicles and the occasional pedestrian. This event is Unlikely, and the consequences of impact are Signiflcant. Overall Tree Risk Rating: LOW Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 8 Tree Risk Assessment Tree #4: Pine Pinus sp. DSH Height Avg. Canopy Radius Condition 13” 20’ 20’ Fair Root and Root Collar: History of property damage to tree islands and asphalt. Most islands comprised of smaller maples with little to no damage. These pines are too big for these restrictive locations and will only cause more damage as time wears on. Risk Categorization: The likelihood root failure is Possible with a Medium risk of property damage parked vehicles and the occasional pedestrian. This event is Unlikely, and the consequences of impact are Signiflcant. Overall Tree Risk Rating: LOW Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 9 Tree Risk Assessment Tree #5: Pine Pinus sp. DSH Height Avg. Canopy Radius Condition 11” 20’ 15’ Fair Root and Root Collar: History of property damage to tree islands and asphalt. Most islands comprised of smaller maples with little to no damage. These pines are too big for these restrictive locations and will only cause more damage as time wears on. Risk Categorization: The likelihood root failure is Possible with a Medium risk of property damage parked vehicles and the occasional pedestrian. This event is Unlikely, and the consequences of impact are Signiflcant. Overall Tree Risk Rating: LOW Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 10 Analysis and Recommendations • Remove Tree #1, #2, #3, #4, and #5 – Trees are not of mature size yet and have caused immense damage to parking lot, asphalt, islands, etc. • Install New Trees for Replacement – There is limited space in these little parking lot islands. Recommendation is to plant a 2” caliper Red Sunset Maple in place of each removal (Acer rubrum 'Franks red’) as there is no room to do more than that. Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 rentonwa.gov/permitservices | planningcustomerservice@rentonwa.gov | 425-430-7294 10/24/2023 Page 1 of 3 CITY OF RENTON Ι PERMIT SERVICES TREE RETENTION AND CREDIT WORKSHEET TREE RETENTION REQUIREMENTS A minimum retention of thirty percent (30%) of all significant trees (as defined in RMC 4-11-200) is required on site. Please complete the form below to verify compliance with minimum tree retention requirements. • Identify total number of trees 6-inch caliper or greater (or alder or cottonwood trees 8-inch caliper or greater) on site: Trees Trees Trees Trees Trees Trees Required Trees Proposed •Deductions – Certain trees are excluded from the retention calculation: o Trees that are high-risk, as defined in RMC 4-11-200: o Trees within existing and proposed public right-of-way: o Trees within wetlands, streams, very high landslide hazards, protected slopes, and associated buffers: •Total remaining trees after deductions: •Required tree retention (30%): •Identify number of trees proposed for retention: •Identify number of trees requested for replacement in lieu of retention (skip page 3 if no tree replacement is requested):Trees TREE CREDIT REQUIREMENTS Tree credit requirements apply at a minimum rate of thirty (30) credits per net acre. Complete the form below to determine minimum tree credit requirements. •Gross area of property in square feet: Square Feet •Deductions: Certain areas are excluded from tree credit calculation: o Existing and proposed public right-of-way: Square Feet o Wetlands, streams, very high landslide hazards, protected slopes, and associated buffers: Square Feet •Total excluded area:Square Feet •Net land area (after deductions) in square feet:Square Feet •Net land area (after deductions) in acres:Acres •Required tree credits:Tree Credits Required Attachment B RECEIVED 06/18/2025 AWragge PLANNING DIVISION 41 41 12.299999999999999 35 0 544650 0 544650 12.50 375 Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 rentonwa.gov/permitservices | planningcustomerservice@rentonwa.gov | 425-430-7294 10/24/2023 Page 2 of 3 TREE RETENTION AND CREDIT WORKSHEET PROPOSED TREE CREDITS Please complete the table below to calculate the total tree credits proposed for your project. Identify the quantity of trees for each tree category, after deducting trees within excluded areas, as shown in the previous section. TREE SIZE TREE CREDITS TREE QUANTITY TOTAL TREE CREDITS RETAINED TREES Preserved tree 6 – 9” caliper 4 Preserved tree 10 – 12” caliper 5 Preserved tree 12 – 15” caliper 6 Preserved tree 16 – 18” caliper 7 Preserved tree 19 – 21” caliper 8 Preserved tree 22 – 24” caliper 9 Preserved tree 25 – 28” caliper 10 Preserved tree 29 – 32” caliper 11 Preserved tree 33 – 36” caliper 12 Preserved tree 37” caliper and greater 13 NEW TREES New small species tree (30' or less at maturity) 0.25 New medium species tree (30' to 50' at maturity) 1 New large species tree (50' or more at maturity) 2 TREE CREDITS PROPOSED: 25 3 3 2 1 1 164 100 15 18 14 8 9 0 0 0 0 0 0 0 Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4 rentonwa.gov/permitservices | planningcustomerservice@rentonwa.gov | 425-430-7294 10/24/2024 Page 3 of 3 TREE RETENTION AND CREDIT WORKSHEET TREE REPLACEMENT JUSTIFICATION Replacement may be authorized as an alternative to 30% retention provided the removal is the minimum necessary to accomplish the desired purpose and provided the proposal meets one of the following options: a.There are special circumstances related to the size, shape, topography, location, or surroundings of the subject property; or b.The strict application of the code would prevent reasonable use of property; or c.The strict application of the code would prevent compliance with minimum density requirements of the zone; or d.The project is a short plat with four (4) or fewer lots. Please attach a written justification demonstrating compliance with the requirements and criteria as descripted above. TREE REPLACEMENT QUANTITY Tree replacement quantity is determined based on the credit value of the trees proposed for removal. Larger, higher priority trees shall be used for calculation of tree replacement. Identify the quantity of each tree requested to be removed in lieu of 30% retention, based on tree size. List the identification number of each tree, as indicated in the arborist report. TREE SIZE TREE CREDITS TREE QUANTITY TREE INDENTIFICATION # TOTAL TREE CREDITS Tree 37” caliper + 13 Tree 33 – 36” caliper 12 Tree 29 – 32” caliper 11 Tree 25 – 28” caliper 10 Tree 22 – 24” caliper 9 Tree 19 – 21” caliper 8 Tree 16 – 18” caliper 7 Tree 12 – 15” caliper 6 Tree 10 – 12” caliper 5 Tree 6 – 9” caliper 4 REPLACEMENT CREDITS REQUIRED: TREE REPLACEMENT PLANTING Identify the quantity of proposed new replacement trees (minimum size of 2-inch caliper). The total replacement credits proposed should be equal to or greater than the replacement credits required, as shown in the previous section. TREE SIZE TREE CREDITS TREE QUANTITY TOTAL TREE CREDITS New small species tree (30' or less at maturity) 0.25 New medium species tree (30' to 50' at maturity) 1 New large species tree (50' or more at maturity) 2 REPLACEMENT CREDITS PROPOSED: 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Docusign Envelope ID: 3CDFC625-0C90-45AC-9539-AE7793C716C4