May 7, 2018

Surina Singh
National Capital Planning Commission
401 9th Street NW
Washington, D.C. 20004

Re: Comments on the Draft Parks & Open Space Element of the Federal Comprehensive Plan

Dear Surina Singh,

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 Washington, D.C.’s tree canopy;
and work with elected officials, planners, and residents to prioritize trees. 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 agencies like the National Capital Planning Commission (the commission) adopt policies that grow the city’s
urban forest.

We recognize the importance of parks and green spaces as the national capital region prepares for denser
development, heavy rainfall and flooding, and extreme temperatures in the coming decades. Our city’s parks
and natural features, including the trees that cover about 72% of these spaces, provide a wide array of benefits
to people and wildlife. Green spaces offer a sense of place and essential life-enhancing qualities that aid
community and individual well-being (Figure 1).

With the update to the Parks & Open Space Element of the Federal Comprehensive Plan, the commission has an
opportunity to create robust policies that lead to greener and more inviting tree-filled parks that benefit our
regional community. Integrating the below recommendations into the Parks & Open Space Element will ensure
“a cohesive vision for parks and open space in the region through improved stewardship, utilization,
maintenance, planning, and design.” In particular, our comments focus on restoring and maintaining the urban
forest, creating natural shoreline buffers, and protecting trees and soil from development.

Section B: Provide Stewardship of Natural and Cultural Resources

• POS.B.3 Protect and maintain greenways, potentially including Frederick Law Olmsted Sr.’s historic
  greenways in the District, for their environmental benefits and as natural and cultural resources
• POS.B.4 Protect and preserve small forests all forested and stream valley parks as natural resource
  areas, so they continue to serve as valuable scenic, ecological, educational, cultural, and recreational
  resources.
• POS.B.5 Encourage the use of parks, trees, and natural areas as gradual transitions from the natural
  areas surrounding the terrain features to densely developed urban environments.
• POS.B.9 Encourage land use and actions that protect and improve the Potomac and Anacostia Rivers,
  and require natural shorelines to enhance their ecological quality and scenic character.
• POS.B.10 Retain and restore natural shoreline areas to a more natural state, including daylighting
  streams and planting trees/vegetation to provide more sustainable and resilient conditions.
• POS.B.12 Treat urban shoreline areas to be resilient and adaptable to variations in water level. Opt for
  natural shoreline buffers and avoid hardscape to reduce flooding.
• POS.B.14 Preserve and maintain trees, vegetation, and natural areas and open space on federal
  campuses that support wildlife habitat, improve scenic quality, and enhance aesthetic character.
  Preservation of these spaces should be compatible with the campus mission and programmatic needs.
  • This policy consolidates two previous policies from the 2004 Element which were intended to
    maintain and conserve trees. We urge the commission to specify in policy POS.B.14 that trees
    and wooded areas, in particular, should be preserved and maintained.
• POS.B.15 Increase and conserve urban tree canopy, understory plantings, and landscape cover through
  best design and installation practices, potentially including Low Impact Development (LID) techniques,
  maintenance plans, and soil remediation efforts, to provide long-term aesthetics and environmental
  benefits.
• POS.B.16 Protect and maintain large tree preserves, forests, and mature urban trees when planning and
  designing development projects in the region. Incorporate new trees as part of all public development,
  especially in the District, to help restore the historic green city setting of the National Capital Region.
  • We recommend the commission re-incorporate Policy 9 of the Greenways and Greenbelts
    section in the 2004 Element, with some minor edits, to make it clear that trees should be planted
    as well as protected.
• POS.B.20 Preserve and protect the park-like character and setting of the region by planting native and
  urban hearty trees and vegetation to promote sustainable practices and minimize maintenance
  requirements.
• POS.B.21 Consider Implement partnership opportunities with local non-profits to educate and engage
  communities in the cleanup, planting, removal of invasive species, and maintenance of the region’s
  rivers, trails, parks, and open space.

Section C: Provide Access to and Connections between Parks and Open Space

• POS.C.1 Plan and maintain connections between parks and open space through streets, sidewalks,
  plazas, and trails to create a unified and accessible landscaped park system for the national capital
  region.
• POS.C.4 Link open space along the Potomac and Anacostia shorelines to provide a continuous public
  open space system that creates natural shoreline buffers and recreation opportunities, avoids
  hardscape, and reduces flooding.

Section D: Balance Multiple Uses Within Parks

• POS.D.5 Minimize impacts from development adjacent to parks, open space, and viable soil, including
  trails and parkways, to protect their natural and historic features.
• POS.D.6 Maintain and improve vegetation along the Anacostia Riverwalk Trail in coordination with the
  local government as a regional resource that provides multiple recreational opportunities. Protect the
  Anacostia Riverwalk Trail from the impacts of adjacent development.

Section F: Build Partnerships and Coordination among Multiple Landowners and Jurisdictions

• POS.F.1 Use conservation easements, donations, purchases, exchanges, or other means to create,
  expand, and enhance a cohesive park and open space system.
• POS.F.2 Develop partnerships and build coalitions among local agencies, non-profit organizations,
  educational institutions, foundations, and other stakeholders to create, manage, maintain, preserve,
  and connect a cohesive open space system.
• POS.F.6 Develop federal and local collaborative relationships to maximize the functionality of small
  parks as well-maintained local neighborhood amenities green spaces.
• POS.F.7 Coordinate with responsible agencies and local jurisdictions to minimize prevent physical and
  visual impacts of development projects on the regional park and open space system, including natural
  features and viewsheds.

Thank you for the opportunity to comment. Casey Trees would be happy to work with you to provide treerelated
analyses or information for the Parks & Open Space Element. If you have any questions about these
recommendations, please feel free to contact me at ktaddei@caseytrees.org.

Sincerely,
Kristin D. Taddei
Planning Advocate

Figure 1. Tree canopy covers about 72% of federal parkland in Washington, D.C., Arlington County, Fairfax County, Montgomery County, and Prince George’s County. Data is unavailable for Loudon and Prince Williams Country.