Tree Removals and Replacements:
The City Can Improve Processes to Protect and Grow the Community Forest A Report from the City Auditor
Issued November 2022
http://www.sanjoseca.gov/auditor
1 Background
• San José has 1.6 million trees on
private property and public
spaces.
• In February 2022, the City
approved the Community Forest
Management Plan and a request
for this audit.
• DOT, PBCE, and Public Works are
all involved overseeing or
managing trees, along with PRNS.
The purpose of the audit was to
review:
a. how and whether the City is collecting
tree-related mitigation fees from developers,
b. how and whether the City is enforcing
tree-planting conditions on development,
c. how the City is spending tree mitigation
funds, and
d. how the City can most cost-effectively
plant more trees.
2 Background
3 Exhibit: Private Property Tree Replacement Process
Source:Auditor analysis of tree removal and replacement process Single family or
duplex residence:
1:1 replacement
Other properties:
City’s Standard
Replacement Ratio
When possible, trees
are replanted
onsite
Otherwise, applicants
Pay a fee
DOT uses the fee to
plant a new tree
A tree is requested to be
removed
If no space
If space
Finding I: Private Property Tree Removal Permitting
Requires Better Resources and Improved Processes
4 • Nearly 1/3 of permits we reviewed
had errors, resulting in 142 fewer
trees planted or $110,050 in in-lieu
fees.
• Standard training and further guidance
can improve the tree removal process.
• Planners do not have tree-related
expertise. Guidance or arborist
support would aid decision-making.
RECOMMENDATIONS:
PBCE should:
→Develop procedures on tree
removal permit processing
→Provide planners with technical
guidance about trees or
provide further access to
certified arborists
Finding I: Private Property Tree Removal Permitting
Requires Better Resources and Improved Processes
5 • In our sample, the process to review
live tree removals exceeded the time
recovered in the fee.
• CFMP recommendations may further
impact the process.
• PBCE plans to review the fee and
related process.
RECOMMENDATION:
PBCE should:
→Review live tree removal fee
and associated process.
Finding 2: The City Can Better Ensure Replacement
Trees are Planted and Regrowing the Canopy
• The City does not verify that applicants
planted required replacement trees.
• There are two verification methods,
but neither is performed routinely.
• The City determines the number of
replacement trees without accounting
for the canopy lost and does not
provide guidance for suitable
replacement tree species.
6 RECOMMENDATIONS:
PBCE should:
→Develop procedures to enforce
tree planting requirements
→Revise the tree replacement
policy to incorporate canopy
size and provide guidance for
tree selection.
Finding 3: DOT Has Not Been Spending In-Lieu Fees
Timely
7 RECOMMENDATIONS:
DOT should:
→Identify planting locations or
uses for accumulated fees
→Create guidelines for how fees
should be spent
→Regularly review information
on fee collection
Exhibit: Tree In-Lieu Fee Balances Have Grown
$-
$300,000
$600,000
$900,000
$1,200,000
$1,500,000
18-19 19-20 20-21 21-22
Source: Auditor analysis of FMS and AMANDA fee records. Data indicates cumulative in-lieu fees collected less in-lieu fee spending by the end of each fiscal year.
Finding 4: DOT Should Evaluate Costs and Establish
Metrics for the Community Forest Program’s Objectives
• The CFMP has multiple objectives for
the community forest.
• DOT has several potential planting
approaches, including City-funded and
directed plantings or engaging private
property owners in planting efforts.
• Each approach has varying costs and
may be more or less effective in
meeting a particular goal of the tree
planting program. 8
Costs include:
• Procuring and planting the tree
• Site preparation
• Traffic safety measures
• Watering during establishment
• Future maintenance
Finding 4: DOT Should Evaluate Costs and Establish
Metrics for the Community Forest Program’s Objectives
• Data on tree removals, replacements,
and tree planting is limited.
• To measure how the City is meeting
objectives, the City should track more
data relating to tree planting, tree
removals, and outreach efforts.
• Metrics would help the City evaluate
cost effectiveness of planting
approaches in meeting objectives.
9 RECOMMENDATIONS:
DOT should:
→Develop metrics and work with
PBCE on necessary data
collection to measure progress
toward the City’s tree planting
objectives
→Work with the Community
Forest Advisory Committee to
develop an outreach plan
Conclusion
This report has ten recommendations to improve the City’s processes to protect and grow the community forest.
We would like to thank the Departments of Transportation; Planning, Building and Code Enforcement, and Public Works. We also thank the City Attorney’s Office and the City Manager’s Budget Office.
The audit report is available at www.sanjoseca.gov/auditor Audit staff: Alison Pauly, Michael O’Connell Jr., William McClain (Stanford in Government fellow)
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