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HomeMy WebLinkAboutRoberts_SP_Renton_Arborist_Report LAYTON TREE CONSULTING, LLC It’s all about trees…… PO BOX 572, SNOHOMISH, WA 98291-0572 * 425-220-5711 * bob@laytontreeconsulting.com ARBORIST REPORT/TREE PLAN Roberts Short Plat 137XX 154th Avenue SE – Short Plat King County Parcel 146340-0052 Renton, WA Report Prepared by: Bob Layton Registered Consulting Arborist #670 Certified Arborist #PN-2714A April 15, 2025 Updated February 20, 2026 Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 2 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026 Table of Contents Assignment.................................................................................................................................................... 3 Description .................................................................................................................................................... 3 Methodology ................................................................................................................................................. 3 Judging Condition...................................................................................................................................... 4 Judging Retention Suitability .................................................................................................................... 4 Observations ................................................................................................................................................. 4 Discussion/Recommendations ...................................................................................................................... 5 Tree Protection Guidelines ............................................................................................................................ 5 Tree Density-Tree Replacement ................................................................................................................... 6 Arborist Disclosure Statement ...................................................................................................................... 7 Attachments Photos, pages 8 - 15 Tree Summary Table Tree Locator/Conditions Map – Existing Conditions Tree Plan Map City of Renton - Tree Retention and Credit Worksheet City of Renton Tree List Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 3 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026 Assignment Layton Tree Consulting, LLC was asked to compile an Arborist Report for a parcel in Renton. The subject property is located at 137XX 154th Avenue SE, King County Parcel 146340-0052. The purpose of the report is to satisfy City requirements associated with tree retention regulations for the proposed 4-Lot short plat. My assignment is to prepare a written report on present tree conditions, which is to be submitted to the City with the development application materials. This report covers all of the criteria set forth under the City of Renton’s tree regulations, Municipal Code Section 4-4-130 - Tree Retention and Land Clearing Regulations. Date of Field Examination: April 9, 2025 Description 63 trees of ‘significant’ size were identified and assessed on the subject parcel. A ‘significant’ tree as defined by the City is ‘A tree with a caliper of at least six inches (6"), or an alder or cottonwood tree with a caliper of at least eight inches (8"). Trees qualified as dangerous shall not be considered significant. Trees planted within the most recent ten (10) years shall qualify as significant trees, regardless of the actual caliper’. The subject property is vacant. There is a large elevated pad in the middle of the property where the grade was significantly raised in the past. Trees are primarily located on the east and west portions of the property. These are native species of Douglas fir, and one native bigleaf maple. Trees were identified in the field with a numbered aluminum tag, attached to the lower trunk. These tag numbers correspond with the numbers on the attached Tree Summary Table and attached Tree Plan Map. There are six significant neighboring or off-site trees whose crowns or canopies extend onto the subject property. These trees were assessed and are included in this report. These are all Douglas fir. Methodology Each tree in this report was visited. Tree diameters were measured by tape. The tree heights were measured using a Spiegel Relaskop. Each tree was visually examined for defects and vigor. The tree assessment procedure involves the examination of many factors:  The crown or canopy of the tree is examined for current vigor/health by examining the foliage for appropriate color and density, the vegetative buds for color and size, and the branches for structural form and annual shoot growth; and the overall presence of limb dieback and/or any disease issues.  The trunk or main stem of the tree is inspected for decay, which includes cavities, wounds, fruiting bodies of decay (conks or mushrooms), seams, insect pests, bleeding or exudation of sap, callus development, broken or dead tops, structural defects and unnatural leans. Structural defects can include but are not limited to excessive or unnatural leans, crooks, forks with V-shaped crotches, multiple attachments. Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 4 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026  The root collar and exposed surface roots are inspected for the presence of decay, insect damage, as well as if they have been injured or wounded, undermined or exposed, or the original grade has been altered. Judging Condition The three condition categories are described as follows: Good – free of significant structural defects, no disease concerns, minor pest issues, no significant root issues, good structure/form with uniform crown or canopy, foliage of normal color and density, average or normal vigor, will be wind firm if isolated or left as part of a grouping or grove of trees, suitable for its location Fair – minor to moderate structural defects not expected to contribute to a failure in near future, no disease concerns, moderate pest issues, no significant root issues, asymmetric or unbalanced crown or canopy, average or normal vigor, foliage of normal color, moderate foliage density, will be wind firm if left as part of a grouping or grove of trees, cannot be isolated, suitable for its location Poor – major structural defects expected to cause fail in near future, disease or significant pest concerns, obvious irreversible decline due to old age, disease or pests, not suitable for its location The attached tree plan maps indicate the ‘condition rating’ of the subject trees found at the site. The attached Tree Summary Table provides specific information on tree sizes and condition; and drip-line measurements for trees with a potential for retention. Judging Retention Suitability Not all trees necessarily warrant retention. The three retention suitability categories as described in ANSI A300 Part 5 (Standard Practices for the Management of Trees During Site Planning, Site Development and Construction) are as follows: Good – trees are in good health condition and structural stability and have the potential for longevity at the site Fair – trees are in fair health condition and/or have structural defects that can be mitigated with treatment. These trees may require more intense management and monitoring, and may have shorter life-spans than those in the “good” category. Poor – trees are in poor health condition and have significant defects in structure that cannot be mitigated with treatment. These trees can be expected to decline regardless of management. The species or individual tree may possess characteristics that are incompatible or undesirable in landscape settings or be unsuited for the intended use of the site. Observations Subject trees are found on the east and west side of the property. The middle is open with no tree cover. Species composition is Douglas fir, and one bigleaf maple. Trees are even-aged (all about the same age). These are semi-mature specimens, estimated at around 80 years of age. Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 5 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026 The majority of trees are of good vigor with foliage of normal color and density. The majority have sound trunks with no outward indicators of any internal decay issues. Several have old wounds on the lower trunks where they have been hit by equipment in the past. Some of the trees around the perimeter of the raised pad had fills soils placed over their roots many years ago. This does not appear to have had adverse effects on tree health. Tree #62 has an incipient infection of Schweinitizii root and butt rot. This is evident by the presence of fruiting body of the fungus near the base of the tree. Condition is rated as ‘fair-to-poor’. Only three trees were found to be in ‘poor’ condition. These include Trees #12, #15 and #39. Trees #12 and #15 are smaller, suppressed specimens. These have developed poor structural form and are susceptible to failure. Tree #39 has an advanced infection of Porodaedalea pini, red ring rot. This is evident by the presence of multiple fruiting bodies(conks) of the white rot fungus on the lower and mid- trunk. It is susceptible to failure. One tree has recently died, Tree #20. The cause of mortality is unknown. Neighboring/Off-site Trees Trees #101 > #106 are also all Douglas fir. These are similar in size and condition as compared to subject property trees. No concerning issues were observed from the subject property side. Tree conditions range from ‘fair’ to ‘good’. Discussion/Recommendations The proposal is to retain trees on the site perimeter that will not be significantly impacted by the construction of future homes. These are well-positioned for successful retention. See the attached Tree Plan Map. The attached Tree Plan Map indicates the driplines of retained and protected off-site trees, and the recommended location of a tree protection barrier. Position the tree protection barrier a few feet beyond the driplines for optimal protection as shown on the attached map. The cut stumps of removed trees in proximity to tree protection areas shall be grinded down to grade and not pulled to protect the roots of nearby trees. This applies to Trees #58 and #41. Neighboring or off-site trees are not expected to be impacted by the proposal. No work is proposed within a proximity of them. Position a tree protection barrier at +/- 6- feet off the north property line to appropriately protect off-site Trees #101 and #102. The removal of trees from the property is not expected to have adverse effects on trees to remain at the site. Tree Protection Guidelines Tree protection fencing shall be positioned around any retained trees or off-site protected trees prior to site demolition or bringing any heavy equipment onto the site. This will help to define clearing limits and protect soils and surface roots. Existing grades within the fenced areas shall not be altered. Position fencing as shown on the attached tree plan map. Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 6 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026 Any excavation within the driplines of retained trees and/or the neighboring trees shall be monitored by the project arborist so necessary precautions can be taken to minimize overall impacts. Any roots that are damaged outside of the fenced protection area shall be pruned clean at sound tissue prior to backfilling or finishing areas. Sound tissue is where the root is undamaged and the bark is completely intact with the root. This will help roots to seal off potential decay and allow them to sprout new growth. Any disturbed areas at the outer edge of the protection area shall be watered weekly during the dry season of June through September. This will help to create a favorable environment for new root growth and reduce the overall stress associated with root loss and disturbance. Simply finish the landscape within the driplines of retained trees by cutting/hand-pulling any unwanted vegetation and applying a 2 to 4-inch covering of organic mulch/beauty bark. Retain any existing native shrubs. Keep large plantings, irrigation trenches and the construction of hardscapes outside of the driplines of retained trees. Tree Density-Tree Replacement RMC 4-4-130 H. 1. Protected Trees – Retention Required: a. Minimum Tree Retention Requirements: Properties subject to an active land development permit shall retain a minimum of thirty percent (30%) of all significant trees on site. The subject site requires the retention of 30% of significant trees. There are 59 viable significant trees on the property, requiring the retention of 18 trees. Based on the proposed site layout, there are 17 trees that can be feasibly retained. These are well- position for successful retention on the site perimeters. All of these are classified as Priority One trees under Renton’s tree code section. Tree credits to be retained (160) far exceed the required minimum for the property (38). See the attached Tree Retention and Credit Worksheet. No supplemental trees are required to meet the required minimum of 30 tree credits per acre of net buildable area, however; since only 17 trees can be retained, the 18th tree will require replacement. The planting of 12 tree credits is required, see page 3 of the worksheet. This can be achieved by the planting of 12 medium sized trees, or a combination of small, medium and large trees to attain the required credits. Species can be selected from the City’s tree list, also attached. Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 7 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026 Arborist Disclosure Statement Arborists are tree specialists who use their education, knowledge, training and experience to examine and assess trees, recommend measures to enhance the beauty and health of trees, and attempt to reduce the risks associated with living near trees. Clients may choose to accept or disregard the recommendations of the arborist, or to seek additional advice. Arborists cannot detect every condition that could possibly lead to the structural failure of a tree. Trees are living organisms that grow, respond to their environment, mature, decline and sometimes fail in ways we do not fully understand. Conditions are often hidden within trees and below ground. Arborists cannot guarantee that a tree will be healthy and/or safe under all circumstances, or for a specified period of time. Likewise, remedial treatments, like any medicine, cannot be guaranteed. Treatment, pruning and removal of trees may involve considerations beyond the scope of the arborist’s services such as property boundaries, property ownership, site lines, disputes between neighbors, and other issues. Arborists cannot take such considerations into account unless complete and accurate information is disclosed to the arborist. An arborist should then be expected to reasonably rely upon the completeness and accuracy of the information provided. Trees can be managed, but they cannot be controlled. To live near trees is to accept some degree of risk. The only way to eliminate all risk associated with trees is to eliminate all trees. Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 8 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026 Photo Documentation Looking east down north perimeter of property Trees #1 > #5 on west perimeter Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 9 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026 Trees #6 > #10 on west perimeter Trees #6 > #10 on west perimeter Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 10 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026 Upper crowns of trees pictured above Looking west down south perimeter, Tree #28 in foreground Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 11 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026 Trees on west side of property Upper crowns of trees pictured above Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 12 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026 Looking west down south property line, Tree #26 closest to fence Trees on east side of property Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 13 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026 Trees #35 and #36 on south perimeter The lower to mid-trunk of #39 covered with pini conks Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 14 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026 Trees #52, #53 and #54 on north perimeter, fire pit near trees Base of Tree #62, has incipient Schweinitizii infection Arborist Report – 137XX 154th Ave SE Short Plat - Renton Page 15 Layton Tree Consulting LLC April 15, 2025 Updated February 20, 2026 Looking south down east property line, Trees #63 and #105 in foreground Looking north down east property line, Tree #106 in foreground-right Layton Tree Consulting LLC For:Roberts Short Plat Site:137XX 154th AVE SE - Renton Tree Summary Table Date: Average Tree/DBH Height Dripline Retention Tag #Species (inches)(feet)Radius Condition Suitability Comments Proposal 1 Douglas fir 16 72 10 Fair CBC old broken top,foliage somewhat sparse Remove 2 Douglas fir 23 120 14 Good CBC natural, self corrected lean north Remove 3 Douglas fir 24 125 12 Fair-Good CBC foliage somewhat sparse Remove 4 Douglas fir 26 125 12 Good CBC good form and vigor Remove 5 Douglas fir 36 112 16 Good CBC old broken top,good vigor Remove 6 bigleaf maple 23 56 16 Fair-Good CBC somewhat suppressed by firs Remove 7 Douglas fir 40 115 16 Good CBC good form and vigor Remove 8 Douglas fir 31 105 12 Good CBC good form and vigor Remove 9 Douglas fir 11 50 8 Fair CBC somewhat suppressed, decent vigor Remove 10 Douglas fir 31 120 16 Good CBC good form and vigor Remove 11 Douglas fir 18 85 10 Good CBC natural, self corrected lean north Remove 12 Douglas fir 13 30 x Poor Poor suppressed, dead top,decay column Remove 13 Douglas fir 27 115 12 Good CBC good form and vigor Remove 14 Douglas fir 17 65 12 Fair CBC old broken top,foliage somewhat sparse Remove 15 Douglas fir 9 50 x Poor Poor bent top,poor stem taper Remove 16 Douglas fir 32 125 14 Good CBC good form and vigor Remove 17 Douglas fir 25 125 14 Fair CBC sparse top foliage Remove 18 Douglas fir 16 85 10 Fair-Good CBC old broken top,good vigor Remove 19 Douglas fir 30 135 14 Fair CBC foliage somewhat sparse Remove 20 Douglas fir 26 125 x Dead Poor recent dead Remove 21 Douglas fir 22 60 14 Fair CBC old broken top,foliage somewhat sparse, ivy on trunk Remove 22 Douglas fir 18 65 14 Good CBC good form and vigor Remove 23 Douglas fir 33 115 16 Good CBC old broken top,good vigor Remove 24 Douglas fir 26 110 14 Fair-Good CBC top foliage somewhat sparse Remove 25 Douglas fir 33 120 16 Fair-Good CBC asymmetric crown SW,crook in top Remove 26 Douglas fir 23 70 14 Good Good asymmetric crown south, overtopped,good vigor Retain 27 Douglas fir 37 125 14 Good Good asymmetric crown south, good form and vigor Retain 28 Douglas fir 29 118 12 Fair-Good Good top foliage somewhat sparse Retain 29 Douglas fir 28 90 14 Good CBC good form and vigor Remove 30 Douglas fir 27 110 12 Good CBC good form and vigor Remove 31 Douglas fir 32 120 14 Fair-Good Fair top foliage somewhat sparse, asymmetric crown south Retain 32 Douglas fir 22 90 12 Fair-Good Fair old buttress root damage Retain 33 Douglas fir 32 130 16 Fair Fair sparse foliage Retain 34 Douglas fir 26 105 14 Good Good old broken top,good vigor Retain 35 Douglas fir 33 130 16 Fair-Good Fair asymmetric crown south, old root damage Retain 36 Douglas fir 21 100 12 Fair-Good Good old broken top,good vigor Retain 37 Douglas fir 19 80 12 Fair Fair old broken top,decent vigor Retain 38 Douglas fir 27 125 14 Good Good good form and vigor Retain 39 Douglas fir 17 95 x Poor CBC advanced pini infection, sparse foliage Remove 40 Douglas fir 17 75 12 Fair Fair somewhat suppressed, decent vigor Retain 41 Douglas fir 28 120 14 Good CBC good form and vigor Remove 42 Douglas fir 28 115 14 Good CBC good form and vigor Remove 43 Douglas fir 21 85 14 Good CBC good form and vigor Remove 44 Douglas fir 21 80 12 Fair CBC unusual lean south, crooked top Remove 45 Douglas fir 22 100 12 Good CBC old broken top,good vigor Remove 46 Douglas fir 25 120 14 Good CBC good form and vigor Remove 47 Douglas fir 20 95 12 Fair-Good CBC old trunk wound Remove 48 Douglas fir 19 80 10 Fair-Good CBC somewhat suppressed, good vigor Remove 49 Douglas fir 23 90 12 Fair CBC large old trunk wound ,old broken top Remove 50 Douglas fir 30 125 16 Good CBC good form and vigor Remove 51 Douglas fir 22 95 12 Good CBC old broken top,good vigor Remove 52 Douglas fir 28 125 14 Good CBC good form and vigor Remove 53 Douglas fir 34 125 16 Good CBC good form and vigor Remove 54 Douglas fir 28 120 14 Good CBC good form and vigor Remove 55 Douglas fir 17 100 10 Fair-Good CBC decent form,good vigor Remove 56 Douglas fir 23 110 14 Good CBC good form and vigor Remove 57 Douglas fir 24 120 14 Fair-Good CBC old trunk wound Remove 58 Douglas fir 17 60 12 Fair-Good CBC somewhat suppressed, good vigor Remove 4/9/2025 Layton Tree Consulting LLC For:Roberts Short Plat Site:137XX 154th AVE SE - Renton Tree Summary Table Date: Average Tree/DBH Height Dripline Retention Tag #Species (inches)(feet)Radius Condition Suitability Comments Proposal 4/9/2025 59 Douglas fir 28 115 14 Fair-Good Good recent trunk wound, good vigor Retain 60 Douglas fir 14 70 10 Fair Fair crooked top,foliage somewhat sparse, old trunk wound Retain 61 Douglas fir 16 75 12 Fair Fair crooked top,foliage somewhat sparse Retain 62 Douglas fir 22 110 10 Fair-Poor Fair schw infection, slight lean west Retain 63 Douglas fir 24 100 14 Good Good good form and vigor Retain Neighboring/Off-site Trees 101 Douglas fir 26 110 12 Good Good no concerns Protect 102 Douglas fir 18 100 10 Fair Fair sparse foliage Protect 103 Douglas fir 28 115 14 Good Good good form and vigor Protect 104 Douglas fir 12 60 8 Fair Fair suppressed, small live crown Protect 105 Douglas fir 14 65 8 Fair Fair somewhat suppressed, decent vigor Protect 106 Douglas fir 18 75 12 Good Good asymmetric crown south, good vigor Protect Dripline measurements from face of trunk CBC - Compromised by Construction rentonwa.gov/permitcenter | planningcustomerservice@rentonwa.gov | 425-430-7294 10/6/2022 Page 1 of 3 CITY OF RENTON Ι PERMIT CENTER 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 rentonwa.gov/permitcenter | planningcustomerservice@rentonwa.gov | 425-430-7294 10/6/2022 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: rentonwa.gov/permitcenter | planningcustomerservice@rentonwa.gov | 425-430-7294 10/6/2022 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: