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HomeMy WebLinkAboutAgenda Item - 2024-06-18 - Number 10.1 - Resolution 24-24, Adopting an Updated Urban and Community Forestry Plan (PP 21-0008) 10.1 F °� COUNCIL REPORT � o OREGO\-\ Subject: Resolution 24-24, Adoption of an updated Urban and Community Forestry Plan (PP 21-0008) Meeting Date: June 18, 2024 Staff Member: Jessica Numanoglu, Director Report Date: June 7, 2024 Department: Community Development Action Required Advisory Board/Commission Recommendation ❑ Motion ❑ Planning Commission Recommends Approval ❑X Public Hearing ❑ Denial ❑ Ordinance ❑ None Forwarded ❑X Resolution ❑X Not Applicable ❑ Information Only Comments: The City's current Urban and Community ❑ Council Direction Forestry Plan was adopted in 2008. ❑ Consent Agenda Staff Recommendation: Conduct a public hearing on Resolution 24-24 to adopt an updated Urban and Community Forestry Plan. Recommended Language for Motion: Move to adopt Resolution 24-24. Project/ Issue Relates To: Council goal to "Combat climate change and strengthen the community's resilience to climate impact." Initiative: "Adopt an updated Urban and Community Forest Plan." ❑X Council Goals/Priorities ❑Comprehensive Plan ❑Not Applicable ISSUE BEFORE COUNCIL The Council will hold a public hearing to consider the adoption of an updated Urban and Community Forestry Plan. Respect. Excellence. Trust. Servi e. 503-635-0215 380 A AVENUE PO BOX 369 LAKE OSWEGO, OR 97034 WWW.LAKEOSWEGO.CITY Page 2 EXECUTIVE SUMMARY The proposed 2024 Urban and Community Forestry Plan (UCFP) is a part of the City Council goal to "Combat climate change and strengthen the community's resilience to climate impact" and the Council initiative to "Adopt an updated Urban and Community Forest Plan." The update to the UCFP commenced in Spring 2023 and was informed by the 2022 State of the Urban Forest Report, a review of existing codes and policies, public engagement, and a Technical Advisory Committee. The proposed UCFP is a guidance document for managing the City's urban forest. It addresses Urban Forest Sustainability and Urban Forest Management and includes a Strategic Plan, Implementation Plan, and Monitoring Plan. The final draft of the UCFP being considered for adoption incorporates revisions based on feedback and direction provided by the Council at their May 21, 2024 Study Session. BACKGROUND The City Council first prioritized an update to the City's first UCFP (adopted in 2008) in its 2023 goals and initiatives after an update to the State of the Urban Forest Report (SURF) was completed in 2022. The SURF provided important background and baseline data needed to inform the update to the UCFP. The City contracted with consultant Dudek to assist with the UCFP update in Spring 2023. Community engagement activities were conducted over Summer 2023 and included focus group meetings with stakeholders, outreach at two City events, an online survey that received 582 responses, and outreach through social media and City newsletters. Throughout the project a Technical Advisory Committee (TAC) consisting of City staff with subject matter expertise, a member of the Oswego Lake Watershed Council, and a state representative from the Oregon Department of Forestry has provided input on the process and feedback on work products. A total of four study sessions and a meeting with stakeholder focus groups were held between January and May 2024 to review drafts of the UCFP and feedback that was received from the public in January. This included a joint work session with the Planning and Development Review Commissions and with the Parks, Recreation and Natural Resources and Sustainability Advisory Boards, and two study sessions with the City Council. Feedback from the public, stakeholders, boards and commission, and Council informed revisions that have been incorporated in the updated UCFP. The draft UCFP is included as Attachment A of Resolution 24-24 (Exhibit 1), and consists of the following documents: • Urban and Community Forestry Plan o Appendix A: Community Engagement Memo o Appendix B: Pest Risk Assessment o Appendix C: Municipal Code Redline Respect, Excel'ence. Trust. Service. 503-635-0215 380 A AVENUE PO BOX 369 LAKE OSWEGO,OR 97034 WWW.LAKEOSWEGO.CITY Page 3 o Appendix D: Monitoring Plan Draft Resolution 24-24, to adopt the updated UCFP, is included as Exhibit 1. DISCUSSION The purpose of the UCFP is to bring together policies, practices, and plans related to Lake Oswego's urban forest and serve as a planning and policy tool to guide management of the urban forest as a valuable community asset. The UCFP is not a regulatory document, meaning the plan was not created in order to fulfill a regulatory mandate from a regional, state or federal authority. Rather, it is an aspirational plan for managing a critical community asset that provides countless community benefits to the health and happiness of our residents and visitors as well as essential ecosystem services, and which must be cared for and managed in order to assure its long-term health and resiliency to the effects of climate change. Urban and Community Forestry Plan The UCFP addresses Urban Forest Sustainability and Urban Forest Management and includes a review of current City Codes, Plans, and Policies related to urban forest management, along with recommendations for revisions and updates. The UCFP also includes a Strategic Plan, Implementation Plan, and Monitoring Plan as described below. The Strategic Plan is included on pgs. 82-99 of the UCFP and provides a guide for the actions needed to manage the City's urban forest based on the following five guiding principles: 1. The urban forest is cared for through sufficient financial investment and adequate staffing resources; 2. Trees are managed according to best management practices to improve the health, longevity, safety, and functional capacity of the existing urban forest and to ensure that the future urban forest can reach its potential to provide the full range of environmental benefits and services; 3. The quality of life in the City is enhanced by the benefits and services provided by the urban forest; 4. The thriving urban forest is able to withstand and recover from impacts of climate change, such as storms, drought, pest, and diseases, and contributes to reducing climate impacts, including mitigating urban heat islands, reducing carbon emissions, and sequestering carbon; and 5. An urban forest that integrates with the urban needs of a city to include housing, infrastructure, businesses, schools, and transportation. The Implementation Plan on pgs. 100-113 assigns all the Strategic Plan actions a timeline, responsible party and/or department(s), recommended partners, and the estimated budget to accomplish the work. Respect, Excel'ence. Trust. Service. 503-635-0215 380 A AVENUE PO BOX 369 LAKE OSWEGO,OR 97034 WWW.LAKEOSWEGO.CITY Page 4 The monitoring plan on pg. 115 and Appendix F utilizes the Community Assessment and Goal- Setting tool developed by the Vibrant Cities Lab to measure progress towards a sustainable urban forest. An initial evaluation was completed by City staff and the Consultant team.The UCFP recommends that the City retake the Assessment tool every two years to measure progress towards the sustainability indicators. Revisions made to UCFP since the May 21, 2024 Council Study Session At the May 21 Study Session, Council reviewed Draft 5 of the UCFP and provided feedback and direction to be incorporated into the final draft of the UCFP. These revisions have been included in the UCFP (Exhibit 1 - Resolution 24-24, Attachment A) and are summarized as follows: • Added "and combats" the effects of climate change to the vision statement to be consistent with the language in the City Council Goal (pg. 9); • Deleted the words "preserved" and "protection" from Key Finding#9 (pg. 17) to address concerns that this may wrongly imply that tree removal is not allowed; • To address concerns that the UCFP may be interpreted as imposing new regulations on private property trees, text was added to Key Finding#7 that the plan is directed at managing the urban forest on city-owned and managed properties, but that there are actions included in the Plan to encourage care and maintenance of the urban forest on private property (pg. 16), and added language on pg. 25 noting that the UCFP does not introduce any new regulations for trees on private property; • Added text in the Monitoring Plan introduction to acknowledge that the City has made good progress towards a sustainable urban forest, which is evidenced by its high score compared to other cities using the Vibrant Cities Lab assessment tool (pg. 115); and • Made minor text edits throughout document for clarity or to correct errors. The Council also asked for clarity on which action items in the Implementation Plan would require additional resources or funding. In response, staff created a separate spreadsheet that lists the Implementation Plan actions and identifies which actions are or can be accomplished with existing resources and which actions may require additional funding or staff resources (Exhibit 2). This spreadsheet is not incorporated in the UCFP because it is based on the current budget and staffing resources, and staffing and funding priorities change over time; however, it is a useful reference that can be updated periodically by staff and consulted during the budgeting process. FISCAL IMPACT Some of the actions in the UCFP are or can be accomplished with existing budget and staff and some may require additional resources or staff to accomplish. The UCFP is an aspirational plan and the actions are intended to be implemented over time. The Council will need to consider and balance the funding of the UCFP actions along with the funding of other city needs and priorities during the budgeting process. As discussed, above, Exhibit 2 provides an overview, Respect, Excel'ence. Trust. Service. 503-635-0215 380 A AVENUE PO BOX 369 LAKE OSWEGO,OR 97034 WWW.LAKEOSWEGO.CITY Page 5 based on current budget and staffing, of the actions in the UCFP that may require additional resources and those that are or can be accomplished with existing staff and resources. RECOMMENDATION Staff recommends that the City Council approve Resolution 24-24, adopting the updated UCFP. EXHIBITS 1. Draft Resolution 24-24 Attachment A: Urban and Community Forestry Plan Due to size (943 pages with appendices), please use this link: h ttps://www.ci.oswecgo.or.us/WebLink/Browse.aspx?id=2789056&dbid=0&repo=CityOfLakeOswego Appendix A: Community Engagement Memo Appendix B: Pest Risk Assessment Appendix C: Municipal Code Redline Appendix D: Monitoring Plan 2. Spreadsheet of UCFP Implementation Plan Actions with Budget Notes Staff reports and meeting materials can be found by visiting the project web page for PP 21-0008. Use the link below to visit the City's "Project" page. https://www.ci.oswego.or.us/all-projects (Under "Search" enter PP 21-0008, then press "Enter") Respect. Excel'ence. Trust. Service. 503-635-0215 380 A AVENUE PO BOX 369 LAKE OSWEGO,OR 97034 WWW.LAKEOSWEGO.CITY EXHIBIT 1 RESOLUTION 24-24 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LAKE OSWEGO ADOPTING AN UPDATED URBAN AND COMMUNITY FORESTRY PLAN (PP 21-0008). WHEREAS,the original Urban and Community Forestry Plan was adopted in 2008, and since that time a number of plans, policies and codes relating to urban forest management have been updated or adopted by the City, and issues and emerging threats, such as climate change, invasive pests, and wildfire risks, are not addressed in the original Plan; and WHEREAS, an update to the City's State of the Urban Forest Report was completed in December 2022; and WHEREAS, the City Council established a 2024 goal to "Combat climate change and strengthen the community's resilience to climate impact" that includes an initiative to "adopt an updated Urban and Community Forestry Plan"; and WHEREAS, the update to the Plan was informed by community engagement, including focus group meetings with stakeholders, outreach at City events, an online survey, outreach through social media and City newsletters, and work sessions with the Planning Commission, Development Review Commission, Sustainability Advisory Board, Parks, Recreation and Natural Resources Advisory Board, and City Council; and WHEREAS, the update was guided by a Technical Advisory Committee consisting of City staff, a member of the Oswego Lake Watershed Council, and a state representative from the Oregon Department of Forestry; and WHEREAS, the City Council conducted a public hearing on June 18, 2024 to adopt the updated Urban and Community Forestry Plan; and NOW,THEREFORE, BE IT RESOLVED by the City Council of the City of Lake Oswego that: Section 1. The City adopts the updated Urban and Community Forestry Plan, included as Attachment A, which to brings together policies, practices, and plans related to Lake Oswego's urban forest and serves as a planning and policy tool to guide management of the urban forest as a valuable community asset. Section 2. Effective Date. This Resolution shall take effect upon passage. Considered and enacted at the regular meeting of the City Council of the City of Lake Oswego on the 18th day of June, 2024. AYES: NOES: Resolution 24-24 PP 21-0008 Page 1 of 2 EXCUSED: ABSTAIN: Joseph M. Buck, Mayor ATTEST: Kari Linder, City Recorder APPROVED AS TO FORM: Ellen Osoinach, City Attorney Resolution 24-24 PP 21-0008 Page 2 of 2 EXHIBIT 2 IMPLEMENTATION PLAN ACTION ITEMS ONGOING ACTIONS Wr Action No. Action Responsible Party Recommended Cost Additonal funding Notes Partner(s) needed? Strive to ensure tree planting exceeds tree removal performed by all City We are doing this consistently 5i Parks,PW Planning $$ No departments each year. with current budgets Create a State of the Urban Forest report in conjunction with,or The last update to the SURF was subsequent to,the effective shade analysis,which is generally completed funded through the Planning within a year of when new LiDAR data becomes available to align with the availability of regional lidar data and the City's effective shade/canopy Dept.budget allocation.Funding 3f Planning Parks,PW,GIS $$$$ Maybe of the next SURF update cover analysis,resulting in consistent measurement of the urban canopy. (estimated 2026 or 2027)will Communicate the findings to the community along with the importance of tree canopy and effective shade in lowering or stabilizing stream need to be balanced with other temperatures. Planning Dept.work plan items. Increase tree planting budgets to reflect tree planting goals for existing Involves multiple depts.and le City Parks,PW $$$$ Maybe depends on available budget City plans and documents. and priorities. Pursue tree planting opportunities through community volunteer events or PW,Watershed Possible this could be funded 1c Parks $ Yes using the Tree Fund.See Action collaborating with local organizations to reduce the cost of tree planting. Councils,FOT 1f. Implement a scouting program for invasive beetles,such as emerald ash Planning, Parks has started doing this in borer and Mediterranean oak borer,to better prevent or intercept a pest 4c Parks,PW Watershed $$$$ No collaboration with State that could cause severe damage to the urban forest and to help inform state agency efforts to track the movement of these pests. Councils,GIS Agencies Update the City's tree inventories(2b)according to the recommended time 2c frame in Section 2,to ensure the City has accurate information on which PW Parks,Planning $$$$ Yes to base management decisions. Increase funding for the Habitat Enhancement Program(HEP)to support Parks,Watershed 1g and expand ongoing restoration efforts through partnerships between City I $$$$ I Yes qualified organizations and private landowners. Councils Collaborate with the Oswego Lake Watershed Council to continue training Already collaborating with OLWC, citizen scientists to collect tree inventory data voluntarily on private Watershed but GIS may need additional 2e properties.Explore mechanisms to analyze private property inventory data Planning Councils,PW, $$ Yes funding to analyze data.There is alongside City-managed tree inventory data to understand overall health of Parks not enough data yet,so this is the City's entire urban forest. not a high priority right now. 2m Prioritize planting large-stature trees where possible. PW,Planning,Parks -- $ No Conduct tree maintenance workshops targeted at contractors working in 2r Planning PW,Parks $ No the City.Ensure program follows ISA best management practices. PP 21-0008 EXHIBIT 2/PAGE 1 OF 6 Action No. Action Responsible Party Recommended Cost Additonal funding Notes Partner(s) I needed? Continue to promote an urban forestry stewardship ethic in the community 3a through general education events with watershed councils,HOAs,and Planning Parks $ No other non-profits. 3b Conduct tree protection workshops targeted at builders,arborists,and Planning PW,Parks $ No other contractors working in the City. Maintain status as a Tree City USA and continue to celebrate Arbor Month 3c as a key public outreach period each year for education and encouraging Parks City $ No stewardship of trees in the City. 3d Continue to celebrate Heritage Trees and provide tree care assistance Planning City $ No through the Heritage Tree Preservation Grant Program. Update educational materials every 3 years to ensure information is I 3e aligned with current arboricultural knowledge.Create new stewardship Parks Planning,PW $$ Maybe Requires technical assistance from an arborist. and educational materials as needed to address emerging issues. Encourage tree planting in riparian areas by providing community education and outreach to connect planting native trees to creating PW,Planning, May be accomplished through 3n wildlife corridors,stabilizing stream temperatures for salmonids,and the Parks Watershed $ Maybe existing or new community partnerships with the City.Staff importance to the region.Use the Lake Oswego Effective Shade report as a Councils reference. resources would be needed. — Provide guidelines for private property owners and developers including 3o best management practices for species selection,tree planting,and"right Planning $$ Maybe Could be coordinated with tree,right place"to prioritize large-stature,mature trees to support Action 3e,above. maintaining canopy cover percentage. 4b Ensure that age classes of trees are sufficiently distributed to ensure Parks,PW $$ No environmental benefits continue by consistently planting trees every year. Continue to use canopy cover as a success-measuring metric of urban 4f forest goals,and target areas with low shade cover to increase equitable Planning Parks,PW,GIS $$ No Costs captured by Action 3f shade canopy. Consider establishing a canopy cover goal to maintain over time. _ _ Increase awareness of the Lake Oswego Fire Department's Wildland Urban 4h Interface Home Assessment Program to assist private property owners on Planning Fire Department $ No ways to reduce fuel loads and eliminate the fire's potential relationship with the house. Periodically review the City-recommended tree species list and update it Should 4d be short term or 4d as appropriate with the following attributes:climate resiliency or drought PW,Parks Planning $ Yes ongoing?It's currently listed as tolerance,pest/disease susceptibility,allergen factor,water use,native status,root damage potential,and overstory or understory canopy layer. I short term in the Stragetic Plan PP 21-0008 EXHIBIT 2/PAGE 2 OF 6 Action No. Action Responsible Party Recommended Cost Additonal funding Notes Partner(s) needed? Treatment of infested wood, Treat tree debris collected from storm damage or with known pests with when needed,is going to cost 4g Oregon Department of Agriculture's guidelines prior to using as landscape PW,Parks -- $$ Yes more than typical disposal due mulch throughout the City. to State requirements Notes: PW=Public Works; Parks=Parks&Recreation; City=City council action required; FOT = Friends of Trees Costs: $ Low (0-$25,000); $$ Medium($25,000-$50,000); $$$ High ($50,000-$100,000);$$$$Very High(>$100,000) Short-Term Actions: 1 to 5 Years Action No. Action Responsible Party Recommended Cost Additonal funding Notes Partner(s) needed? 2q Clarify ROW tree management responsibilities of City departments. Planning,PW,Parks City $ No Develop a budget proposal for consideration during the next regular 1a budget cycle,based on the findings from the Urban and Community Planning PW,Parks $ No Forestry Plan(UCFP). Complete a 100%inventory of trees in developed City rights-of-way Possible that this work could be 2b (ROWs),developed City parks,and City-owned and managed properties, PW Parks,Planning, $$$$ I Yes eligible for a state grant per and a 10%sample inventory of trees in City-owned natural areas and GIS unimproved ROWs. Action 1b,below. Standardize establishment care period requirements for City-planted trees. Ensure consistency among all City departments.Create a notification 2d system for adjacent property owners who will adopt maintenance PW Parks,Planning $ Yes responsibilities for City-planted trees after the 3-year establishment period. Require mitigation trees to be planted for more tree removal permit types 20 when there are viable planting areas on site or allow payment into the Tree Planning -- $ No Fund if staff determines there is insufficient space to replant. Create an updated GIS layer that delineates categories of developed ROW, 2a developed parks,undeveloped ROW,and City-owned natural areas to GIS Parks,PW, $ Yes clarify the inventory collection procedures. Planning Pursue Oregon Department of Agriculture(ODA)and Oregon Department of lb Forestry(ODF)grant funding to conduct a tree inventory,create a wood PW Planning,Parks $ Yes reuse program,and prepare a pest action plan. PP 21-0008 EXHIBIT 2/PAGE 3 OF 6 Action No. Action Responsible Party Recommended Cost Additonal funding Notes Partner(s) needed? Align tree practices,such as planting,establishment care,and pruning 2i with ISA best management practices and American National Standards PW Parks,Planning $$ Yes Institute(ANSI)Standards.Ensure that guidelines are followed by City staff and contractors. Establish guidelines for utilizing the City's existing Tree Fund for tree Parks,PW, 1f planting,care,and maintenance,and a program to support tree giveaways Planning Watershed $ Maybe Will require staff resources. to private property owners. Councils _ 3j Consolidate all tree removal information in one location for clarity. Planning -- $ No _ Clearly describe if and when the City may provide tree care assistance to If City decides to provide 3k trees on private property.Ensure that tree care limitations are consistent Planning,PW,Parks -- $ Maybe assistance on private property, across City departments. this would impact budget and staff resources. 5h Clarify tree protection policies in sensitive areas such as riparian zones. Planning Parks,PW $ No This can be done through routine code maintenance. Parks,PW, 2n Quantify acreage goals of invasive species removal in specific open space, Planning Watershed $ No parks,or neighborhoods. Councils Increase transparency of the tree removal permit process by tracking all 3i applications that are submitted(approved,denied,and withdrawn),as Planning -- $ No well as required mitigation. Update Lake Oswego Code(LOC)Chapters 50 and 55 per 5a recommendations in Section 4 of the UCFP to be in compliance with Planning $$$$ Yes Oregon State Regulations to apply clear and objective standards to applications involving housing. Encourage regular meetings between Planning,Parks&Recreation,and 5g Public Works Departments to ensure work activities are effectively Parks,Planning,PW I -- $ No coordinated and operating as intended. Notes: PW=Public Works; Parks=Parks&Recreation; City=City council action required; FOT = Friends of Trees Costs: $ Low (0-$25,000); $$ Medium($25,000-$50,000); $$$ High ($50,000-$100,000);$$$$Very High(>$100,000) Medium-Term Actions:5 to 10 Years Action No. Action Responsible Party Recommended Cost Additonal funding Notes Partner(s) needed? 2f Conduct a hazardous tree survey to identify hazardous,dead,or otherwise PW Parks $$$$ Yes undesirable street trees and along public trails. Limit topping permits to utility companies as much as possible and 2p Planning -- $ No consider replacing trees using"right tree,right place"concept. PP 21-0008 EXHIBIT 2/PAGE 4 OF 6 Action No. Action Responsible Party Recommended Cost Additonal funding Notes Partner(s) needed? Create a tree risk management program that includes risk assessments 2h every 3 to 5 years of City-managed trees and trees in directly managed PW Parks $$$$ Yes parks and City facilities. 2j .Develop a tree replacement program for targeted ROWs. PW Parks $$$$ Maybe Depends on the outcome of action 2q,above. Implement a formative structural pruning program for young and newly 2k planted trees to mitigate potential tree structure and safety issues for Parks -- $$$$ Yes trees in parks. Identify additional incentives for homeowners and builders to preserve 3g trees,to ensure that existing trees are given extensive thought in the Planning -- $ No planning process and integration into the development plan. Develop a strategy to increase tree management funds because as the City's trees age they will require increased maintenance costs,and the 1d looming arrival of invasive pests such as emerald ash borer(Agrilus Parks,Planning,PW City $ Yes planipennis)and Mediterranean oak borer(Xyleborus monographus)will require costly removal or treatment programs. As part of the City's budgeting process,consider funding an urban forester 2s position,either through an on-call consultant or City staff position,to Parks Planning $$$$ Yes implement tasks within the strategic plan Planning,PW, 3h Establish an internship program to enhance the urban forestry workforce. Parks Watershed $$$$ Yes Councils Create a tree debris utilization program that helps retain carbon Parks,Watershed 31 sequestration benefits and provides hyperlocal bioresources to the PW $$$$ Yes Councils community. Target increasing tree canopy in areas identified in the 2021 Effective 3m Shade Report by providing education on the value of trees planted in PW Planning,Parks $$$$ Yes these areas. Establish soil volume standards for street trees and parking lots.In areas 4a where soil volume standards cannot be met,use structural soils and other PW Planning $$ Yes technologies like suspended pavement systems. 4e Require street tree planting for all new development and provide Planning $ No guidelines for mitigation trees planted on site to maintain canopy cover. 5b Update the Comprehensive Plan's Healthy Ecosystems chapter as Planning City $$ No Can be done in conjunction with described in Section 4. HPS Comp Plan updates. 5c Update the TMDL Implementation Plan as described in Section 4. PW City $$ No Can be done in conjunction with the next TMDL Plan update. PP 21-0008 EXHIBIT 2/PAGE 5 OF 6 Action No. Action Responsible Party Recommended Cost Additonal funding Note Partner(s) needed? 5d Update the 2020 Sustainability and Climate Action Plan as described in City Manager's Office City $$ No Can be done in conjunction with Sections 4. the next SCAP update. 5e Consider including analyses and recommendations in future Effective Planning Parks $ Maybe Shade Reports as described in Section 4. 5f Update the 2022 Stormwater Management Plan as described in Section PW City $$ No Can be done in conjunction with 4. the next SWMP update. Notes: PW=Public Works; Parks=Parks &Recreation; City=City council action required; FOT = Friends of Trees Costs: $ Low (0-$25,000); $$ Medium($25,000-$50,000); $$$ High ($50,000-$100,000);$$$$Very High(>$100,000) Long-Term Actions: 10-Plus Years Action No. Action Responsible Party Recommended Cost Additonal funding Note Partner(s) needed 2g Establish a pruning cycle goal of 5-7 years for all City-managed ROW PW Parks $$$$ Maybe Depends on the outcome of trees. Action 2q. PP 21-0008 EXHIBIT 2/PAGE 6 OF 6