Attn.: Climate Ready DC Plan Public Comment
District Department of Energy and Environment
1200 First St NE, Washington, DC 20002
September 1, 2016
Re: Comments on the Draft Climate Ready DC Plan
Dear Alexis Goggans,
Casey Trees is a Washington DC-based nonprofit with a mission “to restore, enhance and protect the
tree canopy of the nation’s capital.” To fulfill this mission, we plant trees; monitor the city’s tree canopy;
and work with elected officials, planners, and residents to prioritize the District’s trees and plant trees
on both public and private property. We are dedicated to helping the District meet its 40 percent tree
canopy goal by 2032 – an achievable goal only if existing trees are protected and the District adopts
policies that grow the city’s urban forest.
We recognize the importance of the Climate Ready DC Plan as the District prepares to face heavy rainfall
and flooding, extreme temperatures, and rising sea levels in the coming decades. With these comments,
we hope to call to attention the many ways trees offer a natural solution to these threats.
The District Department of Energy and Environment has an opportunity to include tree planting and tree
protection as mitigation tools in the Climate Ready DC Plan. In doing so, the District will be better
prepared to face a changing climate and reach the mayor’s 40% tree canopy goal by 2032. Integrating
the below recommendations into the Plan’s adaptation strategies will ensure DC becomes more resilient
and “continues to grow greener, healthier, and more livable.”
Transportation & Utilities
- TU 3.0: Increase resilience of drinking water, wastewater, and stormwater systems.
Rain gardens are mentioned multiple times throughout the plan as a technique for managing
excess stormwater runoff from heavy rainfall. Any bioretention areas should include waterloving
trees to increase uptake and filtration, reduce demand on treatment plants, and lower
the frequency of polluting overflows. We recommend amending action TU 3.0 to include
planting appropriate trees in all rain gardens. Casey Trees’ Urban Tree Selection Guide may be
consulted to select trees that perform best in bioretention areas.
- TU 5.3: Update design standards for roads and transit infrastructure to account for projected
extreme temperatures and extreme precipitation events.
Street trees shade pavement and intercept rainfall, making streets more pedestrian friendly and
reducing the volume of stormwater entering treatment plants and DC’s waterways. Amend sub-
action TU 5.3 to include “Ensure all street tree boxes are filled and that large shade trees are
planted in tree boxes where possible.”
Buildings & Development
- BD 7.0: Improve thermal safety + indoor building temperatures to increase resilience to
extreme heat, especially in the event of a power outage.
Large trees shade buildings, reduce overall energy use, and cut cooling costs. Trees also help to
reduce the urban heat island effect and keep building temperatures low during power outages.
To further improve thermal safety and increase passive cooling, include tree planting and tree
protection as urban heat island mitigation measures under sub-action BD 7.3. In addition, add
action items including “Ensure all street tree boxes are filled and that large shade trees are
planted in tree boxes where possible,” and “Large trees should be planted at all new
development sites, including public housing, to lower indoor building temperatures and reduce
demand on energy systems.”
- BD 9.1: Develop climate resilience guidelines for new development projects.
Amend this sub-action to read “Develop climate resilience guidelines for new development
projects. Include tree canopy goals in these guidelines to manage stormwater and shade new
- BD 11.0: Provide incentives to encourage private property owners and developers to
implement flood resiliency measures.
Include riverbank tree planting and tree-filled rain gardens as incentivized flood resiliency
measures. Tree roots stabilize riverbanks and prevent erosion from storm surges, while trees in
rain gardens intercept and absorb excess rainwater.
Neighborhoods & Communities
- NC 13.2: Reduce the heat-island effect and related increases in outside air temperatures with
cool and living roofs, expanded green space and tree cover, prioritizing hotspots and those
areas with the greatest number of heat vulnerable residents…”
Trees are an essential tool for reducing the heat-island effect. Planting large shade trees in all
green spaces will offer the largest reduction in outside air temperatures. Change this sub-action
to “Reduce the heat-island effect and related increases in outside air temperatures with cool
and living roofs; expanded tree planting and tree protection efforts; prioritizing hotspots and
those areas with the greatest number of heat vulnerable residents…”
- NC 14.4: …Provide green space that supports community activities and serves as a rain garden
to capture slow precipitation runoff…
Amend the third sentence of this sub-action to read “Provide tree covered green space that
supports community activities and serves as a rain garden to capture slow precipitation runoff.”
Governance & Implementation
- GI 17.0: Align Climate Ready DC with related planning efforts including hazard mitigation,
comprehensive land-use, comprehensive energy, and capital budget planning
Add a sub-action that reads “Add resilience as a benefit of achieving the Sustainable DC Plan’s
40% tree canopy goal (Action 2.1).”
- GI 18.0: Establish the necessary structures to ensure successful implementation of Climate
Add a sub-action such as “Ensure public tree planting efforts by the District Department of
Transportation’s Urban Forestry Administration and residential tree planting efforts by the
District Department of Energy and Environment are fully funded to allow the maximum amount
of tree planting.”
Thank you for the opportunity to comment. Casey Trees would be happy to work with you to provide
tree-related analyses or information for the Climate Ready DC Plan. If you have any questions about
these recommendations, please feel free to contact me at firstname.lastname@example.org.