October 28, 2016

Eric Feldman
Rhodeside-Harwell
510 King Street
Suite 300
Alexandria, VA 22314

RE: Casey Trees’ Comments on the National China Garden Draft Environmental Assessment

Dear Mr. Feldman:

Casey Trees was founded with a mission “to restore, enhance, and protect the tree canopy of the nation’s capital.” Charged with this duty, we actively plant trees; monitor the city’s tree canopy; and work with developers and decision makers to prioritize D.C.’s trees. We are dedicated to reaching the city’s 40% tree canopy goal by 2032. We appreciate the opportunity to provide comments on the draft environmental assessment of the U.S. National Arboretum’s National China Garden project.

The two alternative designs outlined in the draft environmental assessment for the National China Garden detail the potential impacts and benefits to trees on the proposed site. Impressively, these designs offer an overall net gain of approximately 698 trees in Build Alternative 1 and 629 trees in Build Alternative 2, including the creation of a new urban forest exhibit. However, Build Alternative 1 would result in a net gain of 698 trees, 67 more trees than Alternative 2. In addition, Build Alternative 1 would not impact two stands of mature white pines on Hickey Hill. To account for the removal and potential loss due to transplanting of 52 accessioned trees (part of the Arboretum’s collection), and 2 non-accessioned trees, opt for Build Alternative 1. This design will have the least impact on existing trees and the greatest number of trees post-construction. For these reasons, Casey Trees Supports Build Alternative 1.

To ensure the best outcome for tree canopy post-construction, we also suggest incorporating the following recommendations into the final plans for the National China Garden. Adopting these suggestions will ensure that the Arboretum continues to achieve its mission to “enhance the economic, environmental, and aesthetic value of ornamental and landscape plants.”

1. Retain the 26 accessioned trees that can be preserved in place. According to the draft environmental assessment, Seventy-nine accessioned trees currently exist at the site of the planned National China Garden. These trees would be either propagated, removed, transplanted, or preserved in place.

2. Avoid propagating invasive species, which weaken the resilience of ecosystems. The Mid-Atlantic Invasive Plant Council, National Park Service, and City of Alexandria, VA have provided reference lists of invasive tree species.

3. Ensure that Species of Greatest Conservation Need (SGCN) have sufficient tree habitat after construction of the National China Garden. Currently, the location of the planned National China Garden is important habitat for many wildlife species. Of the 26 recently observed SGCN at the site, the 10 SGCN in Table 1, below, rely on wooded or forested habitat.

Thank you for the opportunity to comment. Casey Trees would be happy to work with you to provide clarity on any of the above recommendations or determine tree species selections for this site. If you have any questions, please feel free to contact me at ktaddei@caseytrees.org or 202-349-1892.

Sincerely,
Kristin Taddei
Planning Advocate

cc: Jordan Ramon, Agricultural Research Service, United States Department of Agriculture
Sandra Gibson, Executive Director, National China Garden Foundation

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