September 14, 2017

Shilpa Gupta
Environmental Supervisor I
Bureau of Engineering, Environmental Management Group
City of Los Angeles, Department of Public Works
Shilpa.Gupta@lacity.org

RE: Comments on Sidewalk Repair Program

Dear Ms. Gupta:

On behalf of Los Angeles urban forestry community we are writing to provide our comment on
the current Initial Study for the Sidewalk Repair Program.
Thank you for the work the Bureau of Engineering has done to provide a transparent process for
the residents of Los Angeles to comment on the Initial Study of the Sidewalk Repair Program.
The 30 year $1.4 billion Willits settlement is an unprecedented opportunity for the City of Los
Angeles to make the necessary changes to our current urban forest management practices to
create an urban forest supporting healthy neighborhoods, mitigating the urban heat island effect,
and resiliency to climate change.
Having safe and accessible sidewalks for all Los Angeles residents is a shared goal for those
working to support our urban forest. To that extent, we know trees will often be removed to
make the necessary repairs to our sidewalks. The Sidewalk Repair Program, coupled with the
on-going drought and invasive pests, make this a critical juncture for the City to preserve and
increase the canopy coverage of our trees.
Because of this, we are making the following recommendations on what the Environmental
Impact Report should address to ensure a healthy urban forest for all Los Angeles residents:
1. No net loss of tree canopy:

a. The tree replacement policy at a minimum needs to be 2:1 when trees have
a canopy under 30 feet and should increase to 4:1 for trees over 30 feet. There

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 should be a no-net-loss in canopy from sidewalk replacements and this ratio helps
get the City there.
2. Updating best management practices:
a. Removal of root barriers from planting detail: The standard planting detail S-
456-2 should be updated to completely remove the installation of root barriers.
Root barriers create a less stable root system for street trees increasing the
potential for tree failure. They are expensive to install, and provide no assurance
that it will prevent tree roots from growing under a sidewalk.
b. 15 gallon size trees for residential plantings: 15 gallon size trees provide a
healthier root system when planted which decreases the time needed for the tree
to establish its roots and lowers the time needed for supplemental watering. They
are also roughly half the cost to plant and install than a 24 box tree, and will be
equal in size two to three years after planting.
c. Increase species diversity: The current list of Los Angeles City approved street
trees should be updated to remove trees that require a moderate amount of water,
and introduce new species that are low water use and will be adapted to the
increasing temperatures Los Angeles will face over the next 50 years.
3. Tree inventory:
a. In order to properly manage our urban forest we should first know the current
state of our urban forest. It has been roughly 20 years since Los Angeles has
completed a tree inventory. It is imperative that this be included into the
Sidewalk Repair Program so the full impact of the program can be understood and
properly mitigated.
4. Transparency to the public:
a. Publicly available map of all removals and replacement locations: As trees
are removed and replaced, residents should be able to track where this work is
being completed. Having a publicly accessible online platform will provide the
transparency needed for residents to be confident the City is meeting the
mitigation requirements established by the EIR.
5. Sustainable sidewalk designs:
a. Our urban forest could significantly increase water supplies for LA if the City
integrated sustainable sidewalk designs such as bioswales to capture stormwater
and other green infrastructure opportunities. Other sustainable designs include
meandering sidewalks, bridging over existing roots, curb bump-outs and larger
tree-wells.
As the leaders of urban forestry in Los Angeles we strongly encourage the City of Los Angeles
to study these issues in the EIR process, and make these changes to our current urban forest

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management. We look forward to continuing to work together on creating a healthy urban forest
for the future of Los Angeles.

Sincerely,

Sharyn Romano Andy Lipkis Wendy Butts

Los Angeles TreePeople Los Angeles
Beautification Team Conservation Corps

Johng Ho Song Mark Kenyon Mario J. Becerra

Koreatown Youth North East Trees A Cleaner Greener East LA
and Community Center

Mike Meador Devorah Brous Lisa Smith

California Greenworks Netiya Consulting Arborist
The Tree Resource

Gabrielle Newmark Cassy Aoyagi Marilee Kuhlmann

Industrial District Green FormLA Landscaping Urban Water Group