HomeMy WebLinkAbout04-01-25 Public Comment - Bozeman Tree Coalition - Approval 24606From:BozemanTreeCoalition
To:Bozeman Public Comment; Terry Cunningham; Douglas Fischer; Emma Bode; Joey Morrison; Alex Nordquest;Jennifer Madgic; Erin George
Subject:[EXTERNAL]Approval 24606
Date:Tuesday, April 1, 2025 10:07:55 AM
Attachments:April 1 BTC North Central Mod Approval Response Submitted.pdf
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Attached please find Bozeman Tree Coalition's public comment response to Approval 24606in pdf. We request that the Urban Parks & Forestry Advisory Board be sent our response as
well.
Thank you.
1
April 1, 2025
Dear City Commission, Community Development Department (CDD), Forestry Division, and
Urban Parks & Forestry Board,
Re: North Central Master Site Plan Modification Decision (Application 24606; approved March
24, 2025).
The Public Notice period for this modification application generated 65 public comments. Most, if
not all, called for the protection of mature, public, boulevard trees remaining along West Lamme
Street. In case you have not already read it, here is Bozeman Tree Coalition’s (BTC) burden of
proof for why those trees and/or boulevard should remain.
The CDD’s decision to approve is dismaying on many levels, including but not limited to:
1.) A robust level of public comment calling for tree protection not removal,
2.) The original Master Site Plan gave the impression that these trees would be protected
within the context of the re-development project,
3.) The re-development project lies within the Neighborhood Conservation Overlay District
(NCOD) with intended additional protections for mature vegetation – yet a search within
the approval letter of the term “NCOD” yields zero results,
4.) These are public – not private – assets,
5.) To date, the City has not ever invoked Bozeman Municipal Code 16.05.330 – Section 4b
opting instead to preserve public trees during and after construction,1
6.) There is the appearance that the developer’s financial interest is ranked above the
general welfare of the existing neighborhood and the Bozeman community as a whole,
and
7.) The approval letter provides no insight into why removing the trees is a better option
than letting them age in place. Planting additional trees of diverse species while
maintaining the existing trees is a viable course of action that would not only maximize
the benefits of the existing trees but also protect the boulevard as public space for future
plantings.
1 Per City Manager email from December 12, 2024: “We have not issued any citations under 16.05.330 – Section
4b. Our forestry staff routinely works with developers to discuss which trees can be saved and protected during
construction and which might be irreversibly harmed. A current example is the Stockman Bank project at 8th &
Mendenhall. The existing boulevard trees are being preserved outside of the construction zone with no concerns about
them being harmed.”
BOZEMANTREECOALITION@GMAIL.COM
2
Figure 1. Google maps screenshot of the West Lamme Street, Bozeman, MT – Tree City, USA. The trees in question are
located on the boulevard pictured at right.
BTC understands the impending threat of the Emerald Ash Borer (EAB) on Fraxinus species and
the City’s desire to diversify species composition of our urban forest. In light of this, we offer for
your collective consideration Burnsville, Minnesota’s approach to the EAB problem:
“…it is strongly recommended not to plant additional ash. However, if you have an ash
[…] and it is healthy, it is not necessary to remove it. Instead, consider planting a tree
adjacent to your existing ash to avoid a drastic loss of shade if and when your ash tree
must be removed.”
We’d also like to bring your attention to Bozeman’s Urban Forestry Management Plan (UFMP)
and Emerald Ash Borer Course of Action Plan. Both documents extol trees as essential
infrastructure, cite the benefits of retaining trees, and even discuss the importance of educating
the public on tree protection strategies.
From p. 19 of the EAB Course of Action Plan, “If the tree is close to the 10-inch caliper, in a
good location and in good condition, the tree will likely be a good candidate for saving to
preserve the benefits of canopy cover and avoid the costs of removing the tree.”
3
As reported in BTC’s burden of proof, diameter at breast height measurements from west to east,
as reported in the City’s Tree Inventory Map, are 27 inches (in), 24 in, 16 in, 39 in, and 15 in.
Indeed, this location has been good enough for these trees to grow to maturity and persist for
decades. There is no indication that the trees in question are currently in anything other than good
condition. Therefore, per EAB Course of Action Plan, these trees within the NCOD are “good
candidate[s] for saving to preserve the benefits of canopy cover and avoid the costs of removing
the tree.”
As a grassroots movement with no funding sources, BTC does not have the means for a formal
appeal, which costs approximately $2,700. Therefore, we request an expedited review of the staff
24606 approval letter – which was not signed by the Community Development Director – for
further review by the Community Development Director, the City Manager, and the City
Commission itself.
We request, if the City decides to stand behind this questionable staff approval without a
reasonable review as requested, that the City:
1.Substantiates in a reply letter how staff came to decide that approving the tree and
boulevard removal modification request adheres to (a) the intent of the UFMP and
EAB Course of Action Plan as well as Bozeman’s Growth Plan, (b) meets UDC
38.230.100, 38.110, and 38.410.010, and (c) is in the community’s best interest.
2.Captures the full range of economic costs beyond the trees’ existing forms, such as
those related to the loss of these trees over time as is illustrated in
www.ecomatcher.com’s carbon sequestration calculator.
3.Delays the removal of trees until after breeding bird season (per state and federal
laws), which runs through at least the month of July.
Signed,
BTC Co-founders Angie Kociolek, Dan Carty, April Craighead, Marcia Kaveney, Lara Schulz,
and Chris McQueary