FONTT submitted four principal comments on the changes to the City of Takoma Park Approved Tree Species List, proposed by the Urban Forest Manager in May 2023.

Our comments in full:

On Sun, Jun 11, 2023 at 6:31 AM Friends of Native Trees in Takoma <friendsofnativetreesintakoma@gmail.com> wrote:

Marty,

Thank you for giving us an opportunity to comment on the Takoma Park Approved Tree Species List. 

We worked hard to get such a list when the City Council worked on revising the tree ordinance during 2019-2022.  You probably remember that developing this list was the first thing that our group contacted you about when you took up the city Urban Forest Manager (UFM) position.  We appreciated how many of our native tree species suggestions you put on the first species list.  It is a pleasure to continue to work with you on this.

We have the following four comments:

1.      Non-native species should only be planted in locations where native species are not suitable for well-delineated reasons. 

2.      Non-native species on the approved species list should be near-natives. 

3.      The approved species list should indicate which tree species are native to Maryland.

4.      The Annual UFM Report should give the street locations and species of trees planted in the preceding year to show how the species list has been used in practice.  

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1.      Non-native species should only be planted in locations where native species are not suitable for well-delineated reasons. 

We are not completely clear about why you are adding more non-natives to the approved species list.  It sounds like you intend to plant these non-natives in sites suitable for native species that are climate-resilient.  We don’t think that strategy is in line with the goal of increasing biodiversity in our urban ecosystem.

We understand that the wording of the goal adopted by the City Council in 2020 is ambiguous on this point.  It states:

increased biodiversity (such as species, size) and a focus on planting of native species, and where appropriate, climate-adapted species (2020-15 Resolution, page 2).

During 2019-2020, we urged the City Council to adopt a native tree policy and specifically discussed this goal with one of the councilmembers drafting it.  While the goal as ultimately adopted does not have the precise wording we would have chosen, we think it is meant to incorporate the information, ideas, and arguments that we presented to the council.

Throughout this period, we sought to convey one key point:  Tree species native to our region have critical relationships with hundreds of other native species (thousands if we include soil microorganisms).  We help protect the entire native biological community— biodiversity—by planting native trees.

In the face of climate change, the strategy consistent with the goal of protecting biodiversity focuses first and foremost on increasing the climate resilience in our native species stock. 

That strategy can encompass various tactics.  One tactic would be to plant more climate-resilient native species.  For example, perhaps the city no longer plants sugar maples as street trees, since Takoma Park is located at the southernmost limit of the range for that species.  Also, the city could purchase more southern phenotypes of native species, e.g., Quercus alba (white oaks) grown from Virginia or North Carolina acorns.

A second tactic would be to increase the number of native species on the approved species list, and therefore the number of options available to plant at any given site.  A poor match between species and site can predispose a tree to failure that is then incited by a climate-related factor such as drought or flooding. 

In line with this second tactic, we recommend increasing the number of native species on the approved list by adding:

·       American Chestnut Foundation hybrid

·       Carya tomentosa (mockernut hickory)

·       Rhus copallina (winged sumac)

·       Rhus glabra (smooth sumac).

A third tactic would be adapting management practices in the face of climate change, for example, by watering more during droughts, longer post-installation care, improved tree boxes, and accessing good sites for street trees on private land through agreements with the property owners.

Only as a last resort for specific planting sites would it be appropriate to select a near-native species instead of a native one.

2.      Non-native species on the approved species list should be near-natives. 

Near-natives come from a neighboring state, within our same Piedmont physiographic region.  Virginia and North Carolina are the most likely sources.

Such near-native trees are part of biological communities that we can expect to be gradually migrating north due to climate change.  Near-natives would thus contribute to supporting the evolving biodiversity in our area.

The same cannot be said for non-natives that come from farther afield, say, the Mississippi Valley.  These non-natives may support the biodiversity in our area, especially if they are closely related to native species.  However, it would require more investigation to establish whether that is the case.  These non-natives should not be added to the approved list unless and until this work has been done.

We therefore recommend removing the following from the approved list:

·       Carya illinoinensis (pecan):  Let’s emphasize our native hickories instead.

·       Maclura pomifera (Osage orange)

·       Magnolia grandifolia (Southern magnolia)

·       Magnolia macrophylla (bigleaf magnolia):  There is anecdotal evidence that this is becoming invasive.

·       Quercus texana (nuttall oak): Arlington County uses the similar but native Quercus shumardii and has consciously excluded nuttalls from its species list.

3.      The approved species list should indicate which tree species are native to Maryland.

We recommend adding a column entitled “Maryland Native?” to the approved species list.  We get your point that “native” could mean native east of the Mississippi or to North America.  Still, we think that users of this list are most likely to be interested in whether a species is native to Maryland.  

We suggest using Vascular Plants of Maryland USA: A Comprehensive Analysis of the State’s Botanical Diversity, 2021, to identify which tree species are Maryland natives.  This peer-reviewed publication, based on decades of research and put out by the Smithsonian Institution, is authoritative, comprehensive, and easy to use. 

4.      The Annual UFM Report should give the street locations and species of trees planted in the preceding year to show how the species list has been used in practice.  

Throughout our advocacy on revisions to the tree ordinance, we saw the policy on native trees, a binding tree species list, and a detailed Annual UFM Report as an integrated package:

·       the policy sets a biodiversity goal,

·       the tree species list sets parameters for what can be planted in line with this goal, and

·       the Annual UFM Report allows the public to see how the goal and list have been translated into practice.

We used to get information on tree species planted by street location from a councilmember requesting this list from the UFM.  The following table illustrates what this information looked like. 

Spring 2020 Planting List:  First 10 lines demonstrate the format that was used for reporting Species and Number of Trees by Street Location

Location	Utilities	Tree Type	Quantity	Comments
Anne St.
		Amer Linden	1
Colby Ave.
across from 703, grassy center		Lond. Planetree	1
707				Remove at Res request
713				Remove at Res request
804	wires	Hornbeam		Remove at Res request
807				Remove at Res Request
811		Lond. Planetree	1
812	wires			Remove at Res request
817		Hornbeam	1

Source:  Urban Forest Manager provided to former Ward 1 Councilmember, Peter Kovar.

We advocated for a UFM Report that would provide such information annually to all residents and councilmembers.

Among other things, this style of reporting lays a pathway for getting residents more interested in the urban forest by letting them know how the city is shaping it in their neighborhoods.

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Again, we appreciate your asking FONTT to provide feedback on the Approved Tree Species List.  As the person who is in the difficult nexus of City Council, community groups, and the public, your task is surely a challenging one.  We hope that in providing this feedback, we are sending a clear message of our desire to constructively collaborate with the city as it works towards the goals set by the City Council for urban forest management. 

Please feel free to contact us for additional feedback or clarification on the points in this document.

Regards,
Lizz Kleemeier
Larry Lempert
Bradley Simpson
James Wang
Jeremy Wells

We submitted our comments in response to this email: