Councilmember Mary Cheh
Committee on Transportation and Environment
1350 Pennsylvania Ave, NW, Suite 108
Washington, D.C. 20004  

January 26, 2022 

Subject: Comments for the Department of Energy and Environment Performance Oversight Hearing 

Dear Councilmember Cheh, 

Casey Trees is focused on restoring, enhancing and protecting the tree canopy of the nation’s capital. We are dedicated to helping the District meet its 40% tree canopy goal by 2032. Washington DC is a leader in environmental protection and climate resilience, and we commend and support DOEE in its work to provide a green and healthy environment for all DC residents.   

As we are confronted with the challenges of a changing climate, recent land cover data shows that from 2015-2020 our city’s tree canopy decreased by 1% while impervious surface increased.  With impervious surfaces increasing throughout the city, we are experiencing a greater urban heat island effect and increased flooding from stronger storms. Our city’s tree canopy and natural infrastructure is now more critical than ever, and we need to prioritize and incentivize its installation throughout the District. Four key recommendations are as follows: 

The first recommendation is for the city to continue to prioritize programs that work with residents to install green infrastructure and plant trees on private property.  Casey Trees partners with DOEE on the RiverSmart residential programs, and recommends that raingardens receive greater incentivization, as they provide greater environmental benefits.  Under current rebate metrics, raingardens are not adequately incentivized over other landscaping options that provide fewer stormwater management benefits. Additionally, funds for BMP maintenance should be built into DOEE’s budget as a permanent yearly expenditure to ensure the good work that has been started with our pilot maintenance program and the infusion of Federal funding continues for these stormwater maintenance facilities. 

The second recommendation is to further prioritize private lot plantings throughout DC. As recent canopy analysis shows, intensive street tree planting conducted by DDOT, has worked to maximize canopy potential on Right of Way areas – aka street trees – over a relatively short period of time. The City government has tremendous say over what is planted on District property, and are easily and quickly able to plant out open tree pits. On private lots – where canopy potential is the greatest, homeowner buy-in is required and can take considerably more time and energy to get a tree planted. Oftentimes we are working in communities with some degree of tree hesitancy for a variety of reasons. This same amount of energy and dedicated financing that went into street trees, needs to be funneled into private lot plantings if the City is to reach its target tree canopy goal. The largest potential for canopy gain, has been and will continue to be through private lot plantings, particularly in Wards 5, 7, and 8.   We need to ensure these programs have the resources they need to not only respond more efficiently to current demand, but also support their necessary expansion, particularly in areas of the City most vulnerable to climate events. 

Third, we ask DOEE to consider conservation easements as a tool to promote climate resilience, particularly in Special Flood Hazard Areas.  Casey Trees is a certified Land Trust that holds conservation easements.  Urban conservation easements are an innovative conservation approach to ensuring long-term protection of pocket forests, urban farms, and green infrastructure necessary to ensure the health and resilience of our city.  Specifically, lands in the 100-yr flood plain of Watts Branch adjacent to Marvin Gaye Park could be preserved as open space and enhanced through tree plantings to maximize their potential as green infrastructure.  This natural stormwater management would protect vulnerable neighborhoods by minimizing flood risk to adjacent residential and commercial development. 

Finally, our city will continue to see tree canopy loss if our policies do not recognize the entire value of trees. We request DOEE review the GAR and other environmental standards and amend them to look at the whole environmental value of a resource, and more specifically encourage retention of existing trees. Current GAR metrics to not consider the multiple benefits of trees and have allowed developers to remove existing trees and replace them with other landscape elements that provide lesser environmental benefit.  

Our city is one of the most vibrant and diverse communities in the nation and our government continues to be a leader in green and resilient development. We thank DOEE and the DC Council for their dedication to improving the quality of life for District residents and generations to come, and will continue to support DOEE in their mission and vision for the city. 

Thank you,

Andrew Schichtel 

Chief Operating Officer, Casey Trees