HomeMy WebLinkAboutAgenda Item - 2026-04-15 MEMORANDUM
V O
OREGOC�
TO: Parks, Recreation and Natural Resources Advisory Board and Sustainability
Advisory Board
FROM: Jessica Numanoglu, Community Development Director
SUBJECT: Tree Regulation Amendment Project, LU 26-0014, Joint Parks Board/SAB Work
Session
DATE: April 7, 2026 MEETING DATE: April 15, 2026
EXECUTIVE SUMMARY
The purpose of this joint study session is to gather feedback from the Parks, Recreation and
Natural Resources Advisory Board (Parks Board) and the Sustainability Advisory Board (SAB) on
draft code amendments implementing the 2024 Urban and Community Forestry Plan. The
updates aim to improve clarity and efficiency, support sustainable urban forest management,
and ensure compliance with state law, including requirements for clear and objective housing
standards.
The draft reflects technical analysis, peer city review, and extensive outreach with City boards
and commissions, stakeholders, and the public, as well as prior Council and Planning
Commission direction.
The amendments include 33 primary changes (12 substantive and 21 technical), along with
additional minor revisions for clarity and consistency. Key updates include a new clear and
objective Type II tree removal track for housing development to comply with state law,
expanded mitigation requirements, programmatic permits for public agencies and utilities,
provisions addressing Emerald Ash Borer-susceptible species, and new street tree requirements
for residential development.
Feedback from this joint study session will help refine the draft code amendments in advance
of upcoming public hearings before the Planning Commission and City Council.
BACKGROUND
In May 2025, the City initiated the Lake Oswego Tree Regulation Amendments Project to
update provisions in the Tree Code and Community Development Code. The project is guided
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by the goals and recommendations of the City's 2024 Urban and Community Forestry Plan and
is intended to improve regulatory clarity and efficiency, support sustainable urban forest
management, and ensure compliance with state law.
In the first phase of the project, the consultant:
• Reviewed existing City tree regulations and policies and conducted internal staff
interviews;
• Evaluated tree regulations in peer cities to identify best practices and alternative
approaches;
• Conducted stakeholder and public outreach to gather input on key regulatory issues;
and
• Engaged the Tree Task Force, an ongoing advisory body throughout the process.
Extensive outreach and public engagement were conducted in 2025 to better understand how
existing tree regulations function in practice and where key challenges exist. The project team
engaged City Council, City staff, the Tree Task Force, community stakeholders, and the broader
public. A total of seven stakeholder focus groups were convened, representing a range of
perspectives, including arborists and utility providers, developers and businesses, community
and advocacy groups, neighborhood associations, tree removal applicants, boards and
commissions, and large landowners. Participants were asked to identify challenges with the
current regulations and suggest potential improvements, with discussion centered on 12
substantive regulatory issues identified in the Urban and Community Forestry Plan.
In addition to stakeholder interviews, the project team conducted broader public outreach
through tabling at community events and hosting an online open house and survey.These
efforts gathered input on community priorities, values, and concerns related to the urban
forest. Key themes from this engagement were used to inform the development of code
concepts and draft amendments.
Building on this outreach, the project team worked with the Tree Task Force to refine potential
approaches to the identified regulatory issues. Study sessions were held with the City Council
and Planning Commission in November and December 2025 to seek direction on conceptual
approaches for several of the most complex topics. This guidance helped establish a framework
for developing draft amendments.
The project team has prepared draft code amendments addressing both substantive and
technical updates. A preliminary draft was reviewed by staff in February 2026, and a revised
draft was reviewed by the Tree Task Force in March 2026, with focused discussion on key
topics. The current draft reflects this iterative process and is now ready for broader review and
feedback by city Boards and Commissions.
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A link to the Project Page where meeting recordings and materials for prior Task Force
meetings, PC work sessions and City Council study sessions can be accessed is provided at the
end of this report.
DISCUSSION
Overview of Draft Code Amendments
The proposed amendments update tree regulations in the following sections of City Code:
• LOC Chapter 55—Tree Code: This chapter is dedicated to the protection and preservation
of trees citywide. It contains:
o Provisions for tree cutting permits;
o Tree protection plan requirements during development;
o Mitigation standards for tree removal.
• LOC Chapter 50—Community Development Code (CDC): The CDC provides the overall
framework for land use planning and development and implements the Comprehensive
Plan. This chapter prescribes tree planting and preservation requirements, including in:
o Design and Overlay Districts, which include context-specific tree requirements;
o Sensitive Lands Overlay Districts, which regulate trees in environmentally significant
areas, including streams, wetlands, and upland tree groves; and
o Landscaping and street tree requirements applicable to certain types of development
(e.g., land divisions and new commercial buildings).
The proposed amendments also add new tree maintenance requirements in the following
sections of City Code:
• LOC Article 42.08—Sidewalks
• LOC Article 34.10—Types of Nuisances
In total, the draft includes 33 primary amendments, consisting of 12 substantive changes and
21 technical updates. These items were identified through the Urban and Community Forestry
Plan and the project's public outreach process.
In addition, 35 minor "General Technical Revisions" were identified during code drafting. These
are distributed throughout the draft and are intended to improve clarity and consistency.
Attachment 1 provides a summary of the 33 key amendments, including cross-references to
the related code amendment item numbers in the draft code (Attachment 2) and identification
of which project goals each item supports: regulatory clarity and efficiency, sustainable urban
forest management, and compliance with state law.
Notable Changes
Key changes proposed in the draft code include:
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• Two-track Type II tree removal process:
o New Clear and Objective Track—Applies to residential development, as required by
state law, and establishes minimum tree retention standards based on tree count or
total diameter.
o Discretionary Track—Applies to other Type II removals over 15 inches DBH and generally
retains existing criteria, with updates to clarify the definition of"significant tree" and to
allow removal of moderately hazardous trees under specific conditions.
• Programmatic permits and flexible mitigation in Sensitive Lands for public agencies and
utilities to streamline routine maintenance and operations.
• Simplified permit for removal of tree species susceptible to Emerald Ash Borer (EAB),
including ash, white fringetree, and cultivated olive.
• Expanded mitigation requirements for additional tree removal types, including Type I trees
(except fruit trees) and dead, hazard or EAB susceptible trees in the public right-of-way or
part of an approved landscape plan.
• Street tree planting requirements for new single-family, duplex, and middle housing
development, with standards to guide placement and avoid conflicts with infrastructure.
Key Issues for Parks Board and SAB Discussion
Given the volume and complexity of the proposed amendments, the following section focuses
on key policy issues where guidance is most needed from the Parks Board and SAB, aligned with
their respective expertise and advisory roles.
DISCUSSION ITEMS SUMMARY TABLE
Draft Description of Draft Amendment Issues and Policy Alternatives
Code
Reference
See LOC Tree Removal for solar access and Issue:Tree removals for solar features are
55.02.080 defensible space currently uncommon so there is potential for
Pgs. 21-22 a new provision like this to significantly
Not proposed, but could consider: expand the removal of trees for solar
Adding approval criteria to the Type II features. Note that the definition of solar
permit discretionary track to specifically feature in LOC Chapter 50 includes "... a
allow tree removal for solar features window that contains at least 20 sq. ft. of
(defined in Chapter 50), and to maintain glazing oriented within 45° east and west of
fire defensible space consistent with LO true south, a solar greenhouse, or a solar hot
Fire Dept. guidelines. water heater..." so it could be construed very
broadly.
NOTE:The Tree Task Force considered
this amendment and opted not to Tree removal for wildfire risk reduction could
recommend it. likewise significantly expand the removal of
trees.
In public engagement, solar access and
wildfire risks were not in the top 5 priority
issues.
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Policy Options:
• Solar: apply the solar exception to only
photovoltaic panels rather than any solar
feature.
• Defensible Space: do not include this
provision and instead utilize education and
outreach with the LO Fire Dept.to assist the
public with wildfire risk reduction strategies.
See LOC Expands tree removal mitigation Issue: Dead tree permits are now proposed
55.02.084 requirements to include EAB-susceptible species (Ash,
Pg. 29 white fringe tree) in order to ease
Proposed Amendment: Would now permitting.This allows for proactive removal
require mitigation for all Type I tree of EAB-susceptible trees, which become
removals, except fruit trees. more expensive to remove and treat once
Would also require mitigation for the they are infested. Given the abundance of
removal of dead, declining, EAB- ash trees in the city, should mitigation trees
susceptible, hazard, and emergency trees be required for the removal of all EAB-
only when located: (1) in the public right- susceptible species or only required if
of-way, (2) in sensitive lands, or(3) as located in the ROW, in sensitive lands, or as
part of an approved development plan part of an approved development as
(e.g., parking lot trees).This is consistent proposed in the draft amendments?
with existing mitigation requirements for
invasive tree removals. Additionally, during staff interviews we
heard that the replacement requirements
result in City staff not removing EAB-
susceptible and invasive trees due to
logistical challenges involved with replanting
in remote areas.
Policy Alternative 1: Expand replacement
requirements to all EAB-susceptible tree
removals (beyond sensitive lands, ROW, and
approved plans).
• Benefit: Greater canopy retention.
• Drawback: May discourage proactive
removals due to combined cost of
removal plus mitigation and could result
in higher risk trees when they are
eventually infested with EAB.
Policy Alternative 2 (City Parks): Do not
require replacement of EAB-susceptible and
invasive trees removed for restoration or fire
prevention in City parks and natural areas.
• Benefit:The proposed programmatic
permit would allow phased removals
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and system-wide replacement planting
to improve flexibility.
• Drawback: Current replacement
requirements have the effect of
discouraging removals in remote areas
due to replanting logistics.
See LOC Minimum Tree Retention%for Type II Issue:To assist in establishing a minimum
55.02.080 Clear and Objective Track tree retention rate for the new Type II C&O
Pgs. 24-26 Track, staff reviewed 20 Type II tree removal
Proposed Amendment: permits issued in 2024 for new dwelling units
For the NEW Type II Clear and Objective and compared tree retention rates under the
(C&O)Track, would require a minimum existing code and the proposed Clear and
retention rate of at least 45%of trees Objective Track. While retention rates varied
greater than 15-inch DBH within the widely by project,the average and median
development site and abutting street retention rates under both scenarios were
right-of-way fronting the site; or similar, ranging from 45-53%. Peer
a minimum 45% retention rate of total jurisdictions that have established minimum
DBH of trees greater than or equal to 6- tree retention rates range from 20-40%.
inch DBH within the development site
and abutting street right-of-way fronting Policy Alternative: Establish a lower tree
the site retention rate or higher tree retention rate
than 45%.
• Considerations:A retention rate
higher than 45% may result in
significantly fewer housing
developments qualifying for the
Clear and Objective Track, or may be
found to be contrary to state law,
which prohibits cities from adopting
standards that discourage or cause
unnecessary delay in the
development of needed housing.
A rate lower than 45% may result in
a decrease in the City's tree canopy
over time.
See LOC Removal of invasive plants and addition Issue: Supports the UCFP goal of"healthy
55.02.084 of native plantings as mitigation for tree understory and soils," but since mitigation
Pgs. 32-33 removal in Sensitive Lands through invasive plant removal and native
plantings would be staff-intensive and
Proposed Amendment: Would add a difficult to monitor long term compared to
provision in the Tree Code to allow standard tree replacement requirements,
alternative tree mitigation for City this amendment is only proposed to apply to
Projects to occur through the removal of City projects.
invasive plants and planting native plants
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in Sensitive Lands areas.The standards Policy Alternative 1: Do not add any
are similar to the invasive plant removal provision allowing removal of invasive plants
and native plant replacement standards and planting of native species as an
in LOC§ 50.05.010, Sensitive Lands alternative to tree mitigation. Instead,focus
Mitigation. on education and outreach to the public on
creating and maintaining healthy soils and
healthy understory to improve the health of
the urban forest.
Policy Alternative 2:Allow tree mitigation
requirements for any project located in
Sensitive Lands to be met through the
removal of invasive plants and planting
native plants in sensitive lands areas.This
approach would be the most staff intensive,
requiring tracking and monitoring to ensure
plant survival and establishment.
Timeline and Next Steps
April-May 2026: Drafts of the code amendments will be reviewed at a joint study session with
the Planning Commission and Development Review Commission, and a study session with the
Council.
June 8, 2026: Public hearing with the Planning Commission.
July 21, 2026: Public hearing with the Council.
ATTACHMENTS
1. Key Issues Summary Table
2. Draft Code Amendments, dated April 2, 2026
Meeting materials for prior Council and Planning Commission study sessions and Tree Task Force
Meetings can be accessed from the project page at the following link:
www.ci.oswego.or.us/planning/pp-24-0006-tree-regulation-amendments
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