HomeMy WebLinkAbout15 APPEAL OF DENIAL OF REQUEST FOR TREE REMOVAL COX MARKET PLAZAAgenda
AGENDA REPORT Reviewed m 15
City Manager
05 Finance Director /A
MEETING DATE: AUGUST 16, 2016
TO: JEFFREY C. PARKER, CITY MANAGER
FROM: DOUGLAS S. STACK, DIRECTOR OF PUBLIC WORKS/CITY ENGINEER
SUBJECT: APPEAL OF DENIAL OF REQUEST FOR TREE REMOVAL
COX MARKET PLAZA
APPELLANT: PHILIP K. COX
COX'S MARKET PLAZA
P.O. BOX 6069
BROOKINGS, OR 97415
LOCATION: 120 EAST MAIN STREET
140 EAST MAIN STREET
150 EAST MAIN STREET
TUSTIN, CA 92780
SUMMARY/REQUEST
Mr. Philip Cox ("Appellant") appeals from and requests reconsideration of the Director of Public
Works' February 10, 2016 decision upholding the Field Services Manager's December 10, 2015
denial of a request to remove Ficus trees at 120, 140, and 150 East Main Street. The Field
Services Manager's December 10, 2015 denial letter is included as Attachment "B". The Director
of Public Works' letter upholding the denial of the request to remove the trees is included as
Attachment "D". The Appellant's March 10, 2016 written appeal to that decision, is included as
Attachment "E".
RECOMMENDATION
Pleasure of the Council:
The City Council may uphold the decision of the Field Services Manager and Director of Public
Works, order one or more of the trees to be removed, or remand the matter for further proceedings
in accordance with directions of the City Council. (TCC § 7307)
FISCAL IMPACT
N/A
Appeal of Denial of Request for Tree Removal — Cox Market Plaza
August 16, 2016
Page 2
BACKGROUND/JURISDICTION
Any decision of the Field Services Manager regarding a request for tree removal may be appealed
to the Director of Public Works and ultimately to the City Council in accordance with Tustin City
Code ("TCC") section 7307.
DISCUSSION
Pursuant to Tustin City Code section 7301, the City maintains and exercises full power, authority,
and jurisdiction over all trees, plants, or shrubs in or growing upon or over any public parkway,
street, highway, alley, right-of-way, and City -owned property in the City. The City's Manager of Field
Services is authorized to remove trees which are determined to be blighted, diseased, or unsafe to
the public. (TCC§7306(a)) However, the Tustin City Code makes clear that "a healthy tree
specimen will not be removed unless it caused damage to adjacent property or is determined to be
unsafe." (TCC §7306(b))
On October 26, 2015, the Appellant submitted a request for tree removal to the City for three Ficus
trees located at 120, 140, and 150 East Main Street, Tustin, CA ("Property"). The Appellant's
request stated that the Ficus trees caused damage and/or were unsafe. To support the request, the
Appellant provided photographs of the property and video images from a camera Appellant's
plumber lowered through the main sewer discharge lines at Cox's Market Plaza. The video images
appear to show tree roots in the Appellant's sewer line. A copy of the request and corresponding
photographs and video are included as Attachment "A".
On December 10, 2015, the City's Field Services Manager denied the Appellant's request to
remove the trees. The denial letter is included as Attachment "B." The denial informed the
Appellant that the City of Tustin, as a multi-year recipient of the National Arbor Day Foundation's
"Tree City USA" award is dedicated to preserving trees within the City to enhance the aesthetics of
the community and promote general environmental quality of the City. The denial also stated that
the Appellant had not submitted any evidence to show that the trees identified were unsafe in any
manner. Finally, the denial stated that the video and photographs provided did not adequately
show which, if any, of the trees had caused damage to Appellant's property. In accordance with the
TCC, without clear evidence to show that a tree is causing damage, the City cannot remove the
tree.
On January 9, 2016, the Appellant appealed to the Director of Public Works and reasserted that the
trees in question had caused damage to his sewer line. The Appellant also provided a 1987 article
ranking trees according to their propensity to damage sewer pipes. The Appellant's response is
included as Attachment "C".
On February 10, 2016, the Director of Public Works issued a determination upholding the Field
Services Manager's denial of the request for removal. The determination is included as Attachment
"D." The Director of Public Works reiterated that the Appellant failed to provide sufficient evidence
to demonstrate that any of the Ficus trees were unsafe or had caused damage. While the video
does appear to show plant roots in the sewer lines, there is no way to prove the roots are
connected to any tree in particular, where the images were captured, or that the roots found in the
pipeline grew through and damaged the line. It is the property owner's responsibility to maintain his
own sewer line, and the Appellant has failed to provide any evidence to demonstrate proper
maintenance or even to show that any actual damage was caused only by roots and not by other
Appeal of Denial of Request for Tree Removal — Cox Market Plaza
August 16, 2016
Page 3
substances such as fats, oils, and/or grease. Hence, the mere "potential" harm posed by the
proximate location of a tree and its root system is not justification for removal.
In response, on March 10, 2016, the Appellant filed a written appeal from the Director of Public
Works' determination to the City Council, which Appellant then supplemented with additional
correspondence on June 3, 2016. This correspondence is included as Attachments "E" and "F"
respectively.
Additionally, while the appeal has been pending, the City has kept the Appellant informed as to the
developing Tustin Commercial Core Plan ("TCCP"). While not yet finalized, the TCCP identifies a
Main Street Improvement project that incorporates improvements to this specific area that will likely
include removal of these specific trees for further beautification measures in association with a
bicycle corridor. Despite this information and the likelihood that the City will soon act to make
improvements to this immediate area, Appellant requested the appeal be placed on the City Council
agenda at this time.
Vc
I s . Stack, P. E.
t of Public Works/City Engineer
Attachment(s):
A. Cox Market Plaza request letter, dated October 26, 2015
B. Field Services Manager's December 10, 2015 Letter
C. Cox Market Plaza Appeal Letter, dated January 9, 2016
D. Director of Public Works' February 10, 2016 Letter
E. Cox Market Plaza Appeal Letter, dated March 10, 2016
F. Cox Market Plaza supplemental correspondence, dated June 3, 2016
ATTACHMENT A
Cox Market Plaza Request
Dated October 26, 2015
'�.COX'S MARKET PLAZA
A Place of History for Unique Shops is Since 1936 s Old Town Tustin
PHILIP K. COX — LINDA M. COX • POST OFFICE BOX 6069 • BROOKINGS, OR 97415
Phone • Cell 714 — 227-4610 • Fax 541 — 469-3815 • Home 541 — 469-5729
e-mail philindacox�charter.net RECEIVEDOctober 26, 2015 OCT 2 6 2015
Douglas S. Stack, Director of Public Works ,
City of Tustin
300 Centennial Way
Tustin, CA 92780
Delivery — By Hand
Re: SECOND REQUEST FOR REMOVAL OF FICUS TREES AT 120,140 AND 150 EAST
MAIN STREET, TUSTIN, CALIFORNIA
Dear Mr. Stack;
Per your request, today, I had a plumbing contractor run a sewer camera through the main discharge
lines at Cox's Market Plaza, a small, historical shopping center, at the SouthiEast Corner of El Camino
Real and Main Street (435 El Camino Real) Tustin, California.
Please find enclosed a USB thumb drive of the images inside the 4 and 6 inch sewer pipe which shows
the Ficus root penetrations which correspond to the attached Exhibit A and Exhibit B. A plot plan
drawing which also demonstrates the loca4 ons and the proximity of the offending Ficus trees (exhibit
C). These locations are also marked on the concrete directly above each intrusion. Also attached is a
work sheet printout of the expenses these trees have incurred over the past few weeks. Copies of
invoices are included. This does not include countless hours that our handyman and Phil have spent
attempting to preserve our property.
This second request is necessary to prevent having to spend our entire maintenance fund on this
continuing damage. We would like to continue our past practice of 45 years of helping keep Samuel
Tustin's building in a clean and sanitary condition and to help preserve its historical significance.
We believe that we have clearly dcmonstrated the facts that would allow us to be eligible to City Code
7306 — REMOVAL AND/OR REPLACEMENT. (b) Request from an adjacent property owner for the
removal of a healthy tree specimen in the public right-of-way shall be evaluated by the Manager of Field
Services or his designated representative. A healthy tree will not be removed unless it has caused
damage to adjacent property or is determined to be unsafe (Ord. No. 589, Sec.2; Ord. No 1054, Sec. 1,
3-4-91). Please refer to the original request regarding damage to citrus trees, dated August 16, 2015
We reserve the right to appeal as provided in City Ordinance 7307 —RIGHT OF APPEAL.
With out any legal duty to do so, Cox's Market Plaza is willing to cover the cost of the removal of these
3 Ficus trees by the City's Contractor. Please find enclosed our check #14732, dated October 26, 2015
in the amount of $1,680.00. If this is not the correct amount, please advise us and the correct amount
will be submitted. We have based the cost amount on the following:
The measurement of each tree at a location 3 feet above ground level, Diameter X $30.00 Per
inch of Diameter:
120 East Main Street —
140 East Main Street —
150 East Main Street —
181/2" X $30.00 = $555.00
181/2" X $30.00 = $555.00
19" X $30.00 = $570.00
$1,680.00
In addition to this, we are committing to the funding of planting 3 replacement trees of the City's
selection of property and sewer friendly species and to provided the funds necessary to cover all costs
relating to the trees replacement up to the amount of $500.00 for each tree, p
Thank you for your assisting our goal of keeping Cox's Market Plaza a show place in Old Town Tustin
and attracting quality businesses that provide taxes to the City. But most importantly, for the
preservation of History to the Visitors. Please forward your decision in writing to the addresses
provided above.
Philip K. C'ox, Owner
Cox's Market Plaza
PKC lmc LT31C1CMPIMARiTENANCE\Ficus2ndRequest20151026
Enclosures: Sewer Camera USB Thumb Drive
Exhibits A, B & C
Check # 14732
Work sheet of expenses
Copy to: Jeffrey C. Parker
City Manager, City of Tustin
Delivery, By Hand
Walter M. Crandall, Esq.
2 Parkway Plaza, Suite 730
Irvine, CA 92614
Delivery by e-mail
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ADOPT A FI CUS TREE
If a person likes a ficus tree and wants to preserve it on city property,
then they should be willing to adopt it and take care of any damage it
causes to adjoining property. Adoption may be given to one or more
parties and any liabilities will be shared equally among those
adopters. To determine if the adopted tree has caused damage then
the determining factor as to which tree will be determined by simply
the measurement from the damage to the closest tree. With the
exception of leaves from the adopted tree, cleanup of any residue,
fruit or other deposits, dropped on public or private property shall
be cleaned up at the adopters expense. In the aspect of a change of
mind on the benefits of adoption, then that adopting party will cause
the tree's removal at their expense. The adopted tree will be
identified by measurement from a fixed position and by photograph
of the tree with the fixed position in the background.
e •
Plumbing - drain Cleaning - Sewer Lines
740 Hariton St.
Orange, CA 92868
Phone: 714-457-9407 Fax: 714-771-7481
www.RescueRooter.com
imorgan(cD-ars.com
�
oposas
DATE August 11, 2014
Location lD#
Customer ID
Quotation valid until: September 11, 2014
Prepared by. Joe Morgan
Proposal To: Job Location (if different):
Customer Name: Phil & Linda Cox Name:
Company Name: Cox Market Plaza Company Name:
Address: 405 EI Camino Real Address:
City/State/Zip: Tustin, CA 82780 City/State/Zip:
Phone: 714-227-4610 Phone:
Rescue Rooter0 proposal to furnish all materials, labor, subcontractors and permits necessary to
complete the followina :
Description of Work
Proposal for a spot repair under the building sidewalk/walkway. Visual of root intrusion and a damaged mainline pipe.
Option 1: Saw cut a 3x3 area, 8' deep. Install shoring. Cut ABS failed mainline section. Camera upstream/downstream.
Make repair. City of Tustin will inspect and sign off. Backfill dirt and apply concrete. Concrete will be approx 2 1/2' deep
because of the raised step/walkway.
Proposal includes labor for one Tech and one helper, parts and materials, concrete, shoring, concrete saw, jackhammers,
cones, yellow tape, camera recording, and proper permit.
$ 6896.12
Option 2: Client will provide concrete work from sub -contractor. $4750
*We will notify the client if further repairs or problems are found beyond the scope.
PROPOSAL PRICE TOTAL 1 $6,896.12
Any unforeseen conditions, alterations or deviations from the above specifications involving extra costs will be
executed only upon written change orders signed by both parties and will become an extra charge over and
above the original proposal
Respectfully Submitted by: Joe Morgan Date: 8/11/2014
Acceptance of Proposal
The above prices, specifications and conditions are satisfactory and herby accepted. You are authorized to
do the work as specked. Payment will be made as outlined above.
Accepted by:
Date :
Signature
Signature
THANK YOU FOR YOUR BUSINESSI
O2014 ARS Rescue Rooter All Rights Reserved License # 765155 Branch # 8101
ATTACHMENT B
Field Services Manager's letter
Dated December 10, 2015
Department of Public Works
Douglas S. Stack, P.E.
Director
December 10, 2015
VIA FIRST CLASS MAEL
Mr. Philip K. Cox
Cox's Market Plaza
P.O. Box 6069
Brookings, OR 97415
Re: Reguest for Removal of Ficus Trees at 120,140 and 150 East Main Street. 2)11tin
Dear Mr. Cox:
Please accept this correspondence as the City of Tustin's ("City'l response to your
October 26, 2015 request for removal of three Ficus trees located within the public right-of-way
at 120, 140 and 150 East Main Street in the City of Tustin. In addition to your October 26, 2015
request, the City has considered the photographic and video documentation you provided with
your letter, as well as your August 16, 2015 correspondence. After due consideration, the City is
denying your request at this time.
As a multi-year recipient of the National Arbor Day Foundation's "Tree City USA"
award, the City is dedicated to preserving trees within the City in order to enhance the aesthetic
image of the community and to promote general environmental quality within the City. With
that in mind, it is the City's goal to maintain all currently existing trees within City rights-of-way
absent a clear need to remove a tree. Indeed, Tustin City Code ("TCC") section 7306(b) states
that "a healthy tree specimen will not be removed [from the public right-of-way] unless it has
caused damage to an adjacent property or is determined to be unsafe." First, there is no evidence
that the three Ficus trees you have identified are unsafe in any manner. Further, the evidence
submitted with your request is insufficient to establish which, if any, of the identified Ficus trees
have caused damage to your property. Without clear evidence to support a finding that a
particular tree within the public right-of-way is causing damage to property, the City is not
prepared to authorize removal.
Enclosed you will find the $1,680.00 check submitted with your October 26, 2015
request which we are returning to you. Pursuant to TCC section 7307 you have the right to
appeal this decision to the City's Director of Public Works. Any appeal must be made, in
writing, to the Director of Public Works within 30 days of the date of this correspondence.
Should you wish to discuss this matter further, please do not hesitate to contact the undersigned
at 714.573.3355.
300 Centennial Way, Tustin, CA 92780
1128883.1
P: (714) 573-3150 • F: (714) 734-8991 • www.tustinca,org
Mr. Philip K. Cox
]December 10, 2015
Page 2
Respectfully,
RC1.1IL
Fie d Services Manager
City of Tustin
Enclosure
cc: City Attorney
City Manager
Walter M. Crandall, Esq,
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ATTACH M ENT C
Cox Market Plaza Appeal Letter
Dated January 9, 2016
ROBERTSON & OLSIEN, L11'
A LAW PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
January 9, 2016
r1a Certified U.S. Mail
Douglas S. Stack, P.E.
Director of Public Works
City of Tustin
300 Centennial Way
Tustin, CA 92780
RECEIVED
JAN 1 1 2016
TUSTIN PUBLIC WORKS DEPT.
Re: Appeal of City's Denial of Request for Removal of Ficus Trees at 120,140, and 150 East
Main Street, Tustin
Dear Mr. Stack,
This office has been retained by Cox's Market Plaza to assist with its request for the removal of the
three ficus trees that the City of Tustin denied through a letter sent by your office's Field Services
Manager, Jason Churchill, on December 10, 2015. Please send all further communications
regarding this matter to my office at the address provided below.
Cox's Market Plaza through its owners, the Cox Family Trust, hereby appeals the City's denial of
the request for the removal of the three ficus trees. Replacing these ficus trees with trees that will
cause little or no property damage to the adjacent property owners will not subtract from the City's
dedication to enhance the aesthetic image of the community and to promote general environmental
quality within the City. This is the exact reason why without any legal obligation to do so, Cox's
Market Plaza included with its tree removal request, a check for $1,680.00 designated to be used for
the removal of the three trees; and, indicated a willingness to donate up to an additional $1,500.00
toward the planting of three replacement trees of a species that is more appropriate for urban
planning. This offer remains open should the City grant Cox's Market Plaza's request for removal
of the three trees. Enclosed is a copy of an article from Ornamentals Northwest Archives where
Pavel Svihra, Horticultural Advisor to the University of California summarized an Australian study
which ranked the ficus as the leading tree species whose roots are likely to cause damage to sewage
and drainage pipes.
Tustin City Code Section 7306(b) states that, "A healthy tree specimen will not be removed unless it
had caused damage to adjacent property or is determined to be unsafe." Mr. Churchill's statement
that, "there is no evidence that the three Ficus trees [Mr. Cox had] identified are unsafe in any
manner" is conclusory and fails to consider potentially unsanitary conditions the roots of the City's
ficus trees can potentially cause if they continue to shift, break, and block the underground sewage
and drainage pipes of the adjoining properties. Assuming arguendo, Mr. Churchill is correct in his
statement that these three trees are not unsafe in their current condition, section 7306(b) still
authorizes the removal of these trees if they have caused damage to an adjacent property owner. In
this case, these trees have damaged the adjacent property by shifting, breaking, and blocking Cox's
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ORANGE COUNTY: 2601 MAIN STREET SUITE 500 IRVINE, CA 92614 (714) 361-2111 (714) 361-2110 FAX
LOS ANGELES: 9696 CULVER BOULEVARD SUITE 301 CULVER CITY, CA 90232 (310) 388-4870 (310) 388-4871 FAX
Page 2
Mr. Churchill
January 9, 2016
Market Plaza's sewage and drainage lines. Cox's Market Plaza is currently being forced to spend
its entire maintenance budget to hire contractors to repair and clear these lines to allow for the
proper drainage of sewage from the property.
Mr. Churchill's letter states, "[T]he evidence submitted with [the] request is insufficient to establish
which, if any, of the identified Ficus trees have caused damage to [Cox's Market Plaza's] property."
His letter continues, "Without clear evidence to support a finding that a particular tree within the
public right-of-way is causing damage to property, the City is not prepared to authorize removal."
This logic is flawed and it prescribes an incorrect burden of proof that will not be upheld by the
Court if my client is forced to seek a writ of mandamus.
California Evidence Code Section 140 defines "evidence" as, "testimony, writings, material objects,
or other things presented to the senses that are offered to prove the existence or nonexistence of a
fact." [California Evidence Code Section 140] California Evidence Code Section 115 provides that,
" `Burden of proof means the obligation of a party to establish by evidence a requisite degree of
belief concerning a fact in the mind of the trier of fact or the court. The burden of proof may require
a party to raise a reasonable doubt concerning the existence or nonexistence of a fact or that he
establish the existence or nonexistence of a fact by a preponderance of the evidence, by clear and
convincing proof, or by proof beyond a reasonable doubt. Except as otherwise provided by law, the
burden of proof requires proof by a preponderance of the evidence." [California Evidence Code
Section 115] "Preponderance of the evidence" means that the fact is more likely to be true than not
true and a party may establish their burden of proof through indirect evidence, which proves a fact
indirectly. As far as the law is concerned, indirect evidence receives the same weight as direct
evidence.
Per your request, my client, at its own expense, hired a plumbing contractor to run a sewer camera
through the main discharge lines at Cox's Market Plaza, and the camera captured footage
demonstrating ficus root penetrations blocking the sewage lines below the surface of the property.
When the locations of the pipe blockages are compared with the locations of the three ficus trees at
issue, it is more likely than not that these three trees are the root cause of the property damage. For
this reason, per Tustin City Code Sections 7306(b) and 7307, Cox's Market Plaza respectfully
requests that the City of Tustin reconsider the denial of the request to remove these three ficus trees,
and replace these three ficus trees with a tree species that is more appropriate for urban planning in
order to prevent any further damage to my client's property.
Please do not hesitate to contact me should you have any questions.
Very Truly Yours,
Waiter M. Cra*,cuit
Walter M. Crandall
Enclosure
cc: Philip K. Cox, Cox's Market Plaza
Jeffrey C. Parker, Tustin City Manager
Toni L. Burnside, Administrator at Woodruff, Spradlin Smart
Pavel Svih ra
ORNAMENTALS July -August 1987 Horticultural Advisor
NORTHWEST Voi.I1, Issue I Univ. of Calif. Alameda County
ARCHIVES Page 7 224 W.Winton Ave.
Rm. 174
Hayward, CA 94544
RANKING OF TREES ACCORDING TO DAMAGE OF SEWAGE PIPES
In landscape design, it is important to select tree species whose roots are less likely to enter
sewage and drainage pipes. Few quantitative data have been available for California landscape
architects and contractors which would help
them to recognize the species that notoriously
Table: Ranking of Woody Ornamentals Based
block sewage pipes. Recently two Australian
on Their
Frequency of Sewage and Drainage
scientists, B.P. Wilkins and R. J. Turner,
PIPE
published results of their five-year study
DAMAGE
investigating 460 cases of drainage pipe
BYROOTS
blockage by the roots of more than 60 woody
Rank
BOTAMCALNAME
ornamentals planted in Sydney. Such a large
sample allowed them to rank the different tree
I
Ficus spp.
15.9
species according to frequency of damage and
2
Eucalyptus spp.
12.2
probability of occurrence. These results are
3
Salix spp.
11.3
very precious for California landscape
4
Liquidambar spp.
6.3
architects and contractors because most of the
5
Jacaranda spp.
6.1
species investigated in Sydney are planted here.
6
Populus
4.6
7
Nerium oleander
43
From this table it is apparent that of the 460
9
Acer spp.
2.4
cases, figs, eucalypti, willows, liquidambars
10
Cinnamomum camphora
2.2
and jacarandas were most frequently found to
11
Wisteria spp.
2.0
cause damage. Members of the family
12
Cupressus spp.
1.7
Moraceae most frequently plug pipes, and in
13
Fraxinus spp.
1.5
some cases (i.e. figs) their roots were capable
13
Morus spp.
1.5
of blocking a drain 90 feet from the tree stem.
14
Primus
1.3
Also trees that enjoy swampy conditions in
15
Callistemon spp.
1.1
their natural habitat, such as Melaleuca sp. and
15
Grevillea robusta
1.1
Salix sp., are notorious for causing damage.
16
Camellia spp
0.9
Even smaller shrubs such as oleander and
17
Ulmus SDD.
0.7
camellia showed an unexpectedly high
18
Hedera spp
0.4
incidence of damage to pipes.
19
19
F,scallonia -,nn
Magnolia spp.
0.2
0.2
The data also revealed the occurrence of a
19
Malus spp.
Pittosponun undulatum
0.2
0.2
significantly higher number of pipe blockages
19
Quercus spp
0.2
during the fall and winter period than
19
Thuja plicata
0.2
throughout the growing season. This might
19
Tristania laurina
0.2
suggest that root growth continues in drainage and sewage pipes during the fall and winter, or
perhaps because these seasons are associated with frequent rains, the failure of drainage is
noticed more often than during the dry summer.
Conclusions and Recommendations
Correct selection of tree species will result in fewer pipe blockages, fewer tree removals, and less
labor for root cutting.
Near and above pipes, plant palms, ferns and monocotyledons because they develop roots in a
very tight rootball close to the stem.
Although roots have been accused of causing much damage to pipes, in most instances searching
roots entered through a crack. Therefore use P.V.C. pipes. P.V.C. pipes and their joints are more
flexible; as a result, they are less likely to crack after soil settling. Additionally, their joints are
sealed and water leakage is prevented.
Remember, if roots are cut in the pipe, they will respond with rapid re -growth of a thick mat of
finer roots (the same as when a stem is topped), resulting in a fast blockage of the pipes.
Therefore replacement of the affected section with P.V.C. pipe is more lasting and usually
prevents tree removal.
Roots grow more easily in loose or sandy soils where their distribution will be even. However, in
situations where a landscape must be done in rock or clay soils, the probability is that roots will
grow alongside pipes where soil was disturbed by trenching. Plant trees a few yards away from
the trench and use bottlebrush, shrubby grevilleas and junipers.
Never plant figs, eucalypti, willows, liquidambars, jacarandas, poplars, oleanders, maples and
camphor trees near sewage or drainage pipes or septic sinks.
Pesticide Use - Due to constantly changing laws and regulations, no liability for the suggested use of chemicals in
this Newsletter is assumed by the ONW Newsletter. Pesticides should be applied according to label directions on the
pesticide container.
Permission to Reprint material appearing in the ONW Newsletter is granted with the request that you credit the
source: Ornamentals Northwest Newsletter, date, volume, issue, page numbers. Do not excerpt or reprint in such a
manner as to imply the author's endorsement or criticism of a product or concept.
Nondiscrimination - The information in the Ornamentals Northwest Newsletter is provided with the understanding
that no discrimination is intended and that listing of commercial products implies no endorsement by the authors.
Criticism of products or equipment is neither intended nor implied.
ATTACHMENT D
Director of Public Works Letter
Dated February 10, 2016
w
Department of Public Works
Douglas S. Stack, P.E.
Director
February 10, 2016
Robertson & Olsen, LLP
Walter M. Crandall, Esq.
2601 Main Street, Suite 500
Irvine, CA 62614
RE: Appeal Request for Ficus Tree Removal at 120, 140,and 150 East Main Street
Dear Mr. Crandall:
This letter serves as the City of Tustin's ("City") response to the appeal submitted by Cox
Market Plaza on January 9, 2016.
On October 26, 2015, the Cox Market Plaza submitted a request in accordance with
Tustin City Code ("TCC") section 7306(b) asking the City to remove three ficus trees
located within the public right-of-way at 120, 140, and 150 East Main Street in the City.
In accordance with TCC section 7301, the City maintains and exercises full power,
authority, and jurisdiction over all trees, plants, or shrubs in or growing upon or over any
public parkway street, highway, alley, right-of-way, and City -owned property in the
City. While the City's Manager of Field Services is authorized to remove trees which are
determined to be blighted, diseased, or unsafe to the public (TCC section 7306(a)),
TCC section -7306(b) states that "a healthy tree specimen will not be removed unless it
has caused damage to adjacent property or is determined to be unsafe."
The Cox Market Plaza failed to provide sufficient evidence that the three ficus trees it
requested the City remove either caused damage or were unsafe. As a result, on
December 10, 2015, the City Field Services Manager denied the request for removal.
I have reviewed your letter appealing the City's December 10, 2015 denial, the
attached 1987 article entitled "Ranking of Trees According to Damage of Sewage
Pipes," and the photographic and video documentation you provided. The evidence
provided still does not sufficiently demonstrate that these particular trees are unsafe or
have caused damage. While the video does appear to show plant roots within the
sewer line, it does not prove the roots grew through and damaged the line or that they
are from any tree in particular. The City does not share your position that the mere
"potential" to cause damage to a sewer line justifies the removal of any tree.
Moreover, the TCC does not authorize this Department to remove City trees without a
determination that a specific tree is unsafe or causing damage.
300 Centennial Way, Tustin, CA 92780 • P: (714) 573-3150 9 F: (714) 734-8991 • www.tustinca.org
4
Page 2
Mr. Crandall
10 February 2016
As a result, the appeal by Cox Market Plaza is denied. Should you wish to appeal this
matter to the City Council, you must submit a written appeal within 30 days to the
attention of the City Clerk.
While I am not able to reconsider your appeal, should you wish to provide further
evidence in the future to identify with specificity that a tree that is unsafe or causing
damage, as well as any documentation to demonstrate efforts by the Cox Family Trust
to properly maintain the sewer line, grease interceptor and surrounding area to Code,
please do not hesitate to submit a new request to the City's Manager of Field Services.
Best regards,
D la S. Stack, P.E.
e r Public Works/City Engineer
Jeffrey C. Parker, City Manager
Erica N. Rabe, City Clerk
Jason Churchill, Field Services Manager
ATTACHMENT E
Cox Market Plaza Appeal Letter
Dated March 10, 2016
ROBERTSON & OLSEN, «P
A LAW PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
March 10, 2016
Ira Hand Delivery and Email
City of Tustin
Attn: City Clerk
300 Centennial Way
Tustin, CA 92780
cityclerk@tustinca.org
Re: Appeal of Tustin Department of Public Works' Denial of Appeal of Request for Removal
of Ficus Trees at 120, 140, and 150 East Main Street, Tustin, California
Dear Sir/Madam,
This office received the letter dated February 10, 2016 from the City of Tustin's ("City") Director
of the Department of Public Works. In the letter, the Director denies the Cox's Market Plaza's
appeal of the City Field Services Manager's denial of a request to remove three of the City's ficus
trees that are causing damage to the Cox's Market Plaza property at 120, 140, and 150 East Main
Street, Tustin, California.
Cox's Market Plaza through its owners, the Cox Family Trust, hereby appeals the Director of the
Department of Public Works' denial of their prior appeal, and appeal this issue to the Tustin City
Council. Should the City Council decide not to reverse the Department of Works' denial of the
request to remove the ficus trees based on this letter and the documentary evidence provided to the
Department of Public Works, which is incorporated herein by reference, Cox's Market Plaza
requests a hearing on this issue.
In summary, Cox's Market Plaza submitted evidence that it is exhausting almost its entire property
maintenance fund to clear the sewer lines beneath the property due to the invasion of the City's
ficus tree roots. Instead of demanding payment for these expenses from the City, Cox's Market
Plaza offered to donate a specific amount toward the removal of these trees and the planting of other
trees with roots that are less likely to cause this type of damage in the future. Cox's Market Plaza's
offer will remain open should the City reverse the denial of the appeal and grant the request for
removal of the three trees before, or during, the hearing requested above.
Through its prior correspondence, the City has acknowledged that the evidence submitted to it
demonstrates that plant roots have penetrated the sewer lines under Cox's Market Plaza. Despite
evidence that the plant roots are unmistakably ficus roots, the City attempts to deny responsibility
for the damage caused by its trees. In the December 10, 2015 letter denying the original request, the
City states, "there is no evidence that the Ficus trees you have identified are unsafe in any manner,"
and, "Further, the evidence submitted with your request is insufficient to establish which, if any, of
the identified Ficus trees have caused damage to your property." In the second letter denying the
www.roIawfirm.com
ORANGE COUNTY: 2601 MAIN STREET SUITE 500 IRVINE. CA 92614 (714) 361-2111 (714) 361-2110 FAX
LOS ANGELES: 9696 CULVER BOULEVARD SUITE 301 CULVER CITY, CA 90232 (310) 388-4870 (310) 368-4871 FAX
Page 2
Tustin City Clerk
Re: Appeal of Denial to Remove Trees
March 10, 2016
prior appeal, the City states, "The evidence provided still does not sufficiently demonstrate that
these particular trees are unsafe or have caused damage."
Based on previous City Agenda reports published online, Cox's Market Plaza anticipates that the
City will argue that, "The responsibility to maintain a sewer line belongs to the property owner, and
roots do not enter and grow inside a sewer line unless there is a break, crack or offset in the line
which then causes leaking and attracts the roots to the water." This logic is flawed, self-serving,
and disproven by arborists and engineers demonstrating that tree roots have the ability to break,
crack, crush, offset and bend sewer lines just as they do the concrete laying above them on the
surface.
If Cox's Market Plaza is forced to seek a writ of mandate from the Superior Court, the City will be
held to its duty to identify which of its trees are causing the damage to the adjacent properties, to
remove trees that are causing damage to adjacent properties, and to reimburse the property owners
for the damage caused by City tree roots that are invading adjacent properties.
For these reasons, per Tustin City Code Sections 7306(b) and 7307, Cox's Market Plaza respectfully
requests that the City of Tustin reconsider the denial of the request to remove these three ficus trees,
and replace these three ficus trees with a tree species that is more appropriate for urban planning in
order to prevent any further damage to its property.
Nothing in this letter, or otherwise, is intended to be, nor shall it be deemed to be, a full and
complete statement of the facts in this matter. This letter shall not be construed as a waiver of any
legal or equitable rights or remedies, all of which are expressly reserved and may be exercised or
asserted by our client at any time without further notice except as required by applicable law.
Please do not hesitate to contact me should you have any questions.
Very Truly Yours,
Walter- M. Cra+ida &
Walter M. Crandall, Esq.
cc: Philip K. Cox, Cox's Market Plaza
Jeffrey C. Parker, Tustin City Manager
David E. Kendig, Tustin City Attorney
ATTACHMENT F
Cox Market Plaza Supplement Correspondence
Dated June 3, 2016
ROBERTSON &OLSEN, LL•
A LAW PART NERS"M 1NCLUI)MG f ROFESS1oNAL CORPORATIONS
June 3, 2016
Via [IS. Mail
Kendra L. Carney
Woodruff, Spradlin & Smart
555 Anton Boulevard, Ste. 1200
Costa Mesa, CA 92626
kcarney@wss-law.com
Re: Follow-up to Cox's Market Plaza's Appeal of Denial of Request for Removal of Ficus
Trees at 120,140, and 150 East Main Street, Tustin, California
Dear Ms. Carney,
Thank you for your phone call yesterday regarding the letter dated March 10, 2016 where Cox's
Market Plaza appealed the City of Tustin's ("City") Director of the Department of Public Works'
denial of Cox's Market Plaza's appeal of the City Field Services Manager's denial of Cox's Market
Plaza's request to remove three of the City's ficus trees that are causing damage to the Cox's
Market Plaza property at 120, 140, and 150 East Main Street, Tustin, California.
Cox's Market Plaza hereby restates its request for a hearing on this issue should the City Council
refuse to reverse the Department of Works' denial of the request to remove the ficus trees based on
the prior letters and the documentary evidence provided to the Department of Public Works.
In further consideration of Cox's Market Plaza's request for the removal of the Ficus trees, please
find enclosed two letters from Greg Applegate, a registered consulting arborist from Arborgate
Consulting, Inc. located in Tustin. In his first letter, Mr. Applegate verifies that the tree roots
causing damage to Cox's Market Plaza are ficus roots and appear to stem from the City's Ficus
trees adjacent to the property. Mr. Applegate also explains that Ficus roots grow horizontally
underground where they are known to trespass into the properties of adjoining businesses and that
Ficus roots are strong enough to off -set, crush, and block sewer lines. The damage to the brickwork
of its building and blockage of its sewer lines experienced by Cox's Market Plaza forms the basis
for its request for the removal of these trees.
One potential solution recommended by Mr. Applegate to prevent further damage to the brickwork
of the building and the sewer lines is for the City to remove the sidewalks to out the Ficus roots and
to then install root barriers; however, Mr. Applegate cautions, this solution brings with it the
potential drawbacks of the trees toppling over if the roots are clipped too closely to the base of the
tree; and, Ficus tree roots are known to break out from root barriers by growing vertically down and
then up and around the barriers. Mr. Applegate concludes that because the roots are causing more
damage to adjoining businesses than benefits, such as Cox's Market Plaza., removal of the Ficus
trees is the most reasonable solution.
www.roIawfirm.com
ORANGE COUNTY: 2601 MAIN STREET SUITE 500 IRVINE, CA 92614 (714) 361-2111 (714) 361-2110 FAX
LOS ANGELES; 9696 CULVER BOULEVARD SUITE 301 CULVER CITY, CA 90232 (310) 388-4870 (310) 388-4871 FAX
Page 2
Ms. Carney
Re: Follow-up to Appeal of Denial to Remove Trees
June 3, 2016
Without any legal obligation to do so, Cox's Market Plaza has previously offered to pay up to
$3,180.00 toward the removal and replacement of the Ficus trees surrounding its property at the
corner of Main and El Camino Real. If the City's contractor's price exceeds this amount, please
advise us of a suggested amount, for my client's consideration. If the City agrees to remove the
Ficus trees and plants a more appropriate tree species for urban planning, Cox's Market Plaza is
willing to extend this offer one final time, and is also willing to waive the damages it has incurred
due to the City's Ficus trees. If the City fails to accept this offer, Cox's Market Plaza will have no
choice but to turn to the Court for a writ of mandamus ordering removal of the trees and will seek
monetary damages to compensate it for the injuries caused by the City trees' trespass. This offer
will expire at the close of business on July 1, 2016.
Nothing in this letter, or otherwise, is intended to be, nor shall it be deemed to be, a full and
complete statement of the facts in this matter. This letter shall not be construed as a waiver of any
legal or equitable rights or remedies, all of which are expressly reserved and may be exercised or
asserted by our client at any time without further notice except as required by applicable law. This
letter is an inadmissible settlement offer pursuant to California Evidence Code section 1152(a).
Please do not hesitate to contact me should you have any questions.
Very Truly Yours,
Wauvh- M. Cra*ulaw
Walter M. Crandall, Esq.
cc: Philip K. Cox, Cox's Market Plaza
ARBORGATE CONSULTING, INC.
�MN11�11 t.1
It JIM A IM MIIII IIalot
March 31., 2016
Mr, Phil Cox
Cox's Market Plaza
435 El Camino Real
Tustin, CA 92780
Re: Ficus m. Nitida Street Trees
Dear Mr. Cox:
Thank you for asking me to meet with you and discuss the root problems you have experienced
around your property at the above address. You explained that roots have come into drain lines
and sewer lines almost completely around the property and even inside some of the stores. The
City has been reluctant to deal with the damage issues and has asked for proof that the roots are
from the City street trees.
Observations
The street trees on two sides of your property are Indian laurel, Ficus microcarpa Nitida. On
average they have about 15 to 20 inch trunk diameter and have been planted here on Main and El
Camino for as long as I can remember.
You had saved root samples from past drain line or sewer line clearance jobs and allowed me to
examine them. It is clear from the color, texture, and more horizontal lenticels on the root
epidermis that they are in fact Ficus roots.
Analysis
As a consulting arborist working here in Orange County since 1975, I am very familiar with this
species is southern California. My office has been in North Tustin for the last 20 years. While
working with Disney I worked alongside the man whose family introduced this tree. I have had
consults all over southern California working with the problems this species has created. As a
member of the Street Tree Seminar, I have heard many discussions from various street tree
superintendents grousing about what to do with the large number of these lovely trees in their
inventories.
In the past the City responded to your requests by asking how can they know they are from the
City street trees. You and I discussed DNA testing to answer this question, but came to the
obvious conclusion that since there are no other trees planted on the property or nearby, that
there should be no need for elaborate scientific methods. Even if that was not the case, one of
A"ORGATE CONSULTING, INC.
Hor6cultute & Arboriculture
1131 Lucinda Way, Tustin, CA 92780, Ph. 714.731.6240, Cell: 714.292.7184, Fax 714.731.6138
3/31/2016 Ficus m. Nitida Street Trees page 12
the drawbacks to even using DNA testing is that nearly all Ficus microcarpa Nitida are grown
from cuttings, malting them essentially clones, i.e. having identical DNA.
I have seen situations where this species was planted in a parking lot island; the roots grew under
the parking lot island curb; grew under the asphalt; under the curb and sidewalk; under the
building foundation and came up in the area drains inside the adjoining businesses. This
situation is not as extreme as that, but I have no difficulty understanding, even expecting, that
these trees can do as much. In this situation the roots do not have as much distance to grow and
do not have the two sets of curbs to grow under. I have seen young Indian laurels put out new
roots 8 to 10 feet from the trunk in one year.
One of the factors that led to the current troubles is that many cities jumped on this then new
species before anyone had much experience with it. Many cities all over southern California are
having the same problem with excessive root damage. When it comes time to select a new
replacement species, hopefully more thought will be put into selecting a tried and true tree
species. The booklet "Street Trees Recommended for Southern California" by the Street Tree
Seminar is likely to be of assistance with the selection process.
Since there is little the City can do to keep these roots out of your property after allowing them to
grow to this size, removal is the most reasonable solution. About the only other option would be
to remove the sidewalk and install a continuous root barrier between the trees and your property.
Since the roots may still come in by following sewer lines, drain lines, or other underground
utilities, those points would need to be wrapped and sealed with BioBarrier fabric. Even then,
there is a chance some roots may grow under the root barrier. In my experience the vertical ribs
on most commercial root barriers deflect roots downward so that they are more likely to be able
to reach the bottom of the root barrier and come up on the other side.
A better solution is to use 80 ml moisture barrier for the root barrier. It is smooth, and since
Ficus are shallow rooted, when the roots encounter the barrier they are more likely to turn
horizontally than grown down and under.
1 remember a number of years ago when the Old Town area had a redesign and root barriers were
installed around the already large street trees. It was only a couple days later when the wind
came up that several toppled. Roots should never be cut closer than 5 times trunk diameter on
such trees. I was somewhat surprised, but happy when more didn't fall over.
The best solution would be to start fresh. These trees have outlived the average life expectancy
for urban street trees, i.e. trees confined in small sidewalk cutouts. They have reached a point
where they do help create a lovely streetscape, but they were a poor choice in the first place and
have reached a point of diminishing returns, i.e. where they are causing more damage to
adjoining businesses than benefits. A sudden change to new street trees throughout old town
Tustin would be hard to accept politically, but a phased replacement would be more acceptable.
A review of the booklet, "Reducing Infrastructure Damage by Tree Roots", by Costello and
Jones from the UC Cooperative Extension, would provide strategies to help the replacement trees
last longer and cause less damage.
ARBORGATE CONSULTING, INC.
Horticulwre & Arboriculture
1131 Lucinda Way, Tustin, CA 92780, Ph. 714.731.6240, Cell: 714.292.7184, Fax 714.731.6138
3/31/2016 Ficus m. Nitida Street Trees P a g e 13
Recommendations
1. As part of a phased project, remove existing trees and as much of their roots as practical.
2. Determine the most appropriate species and size for replacement.
3. Do a percolation test at the same depth as the bottom of the planting pit.
4. If percolation is less than I Vhr., install a positive drainage system for all the planting pits or
structural soil areas.
5. Consider using a type of structural soil under the paving, bordered by at least a 3' deep moisture
barrier, to maximize root space and minimize root damage. See link below:
https://www.asta.org/uploadedFfles/CMS&Ieetings_pnd Events/2010—Annual Meeting Handou
ts/Sat-B 1 The%24Great%20Soi1%20Debate_Structural%20Soils%20Under%20Pavement.pdf
Please call me if you have any questions.
Respectfully submitted,
Arborgate Consulting, Inc.
Greg Applegate, ASCA, ASLA
Registered Consulting Arborist #365
Enclosed: resume
A"ORGATE CONSULTING, INC.
Horticulture & Arboriculture
1131 Lucinda Way, Tustin, CA 92780, Ph. 714.731.6240, Cell: 714.292.7191, Fax 714.731.6138
ARBORGATE CONSULTING, INC.
ANINN"I t'111 *1 f IX RIN (51111M
May 22, 2016
Mr. Phil Cox
Cox's Market Plaza
435 El Camino Real
Tustin, CA 92780
Re: Ficus Street Trees in Tustin
Dear Mr. Cox:
Thank you for asking me to examine various Indian laurel street trees around the City of Tustin.
We examined trees from those at El Camino Real and Main to those on El Camino Way, First
Street, Prospect, South B Street, and South C Street.
Observations
Based on the amount of lifted sidewalks and new paving around ficus street trees, one noticeable
factor in how much damage was being done was whether or not the tree was in a cutout or in a
parkway. Those in sidewalk cutouts caused significantly more damage. Those in very narrow
parkways, such as the Ficus in front of Parque Santiago, caused more damage than those in wider
parkways. Naturally, this is to be expected.
The paving around the Indian laurel on El Camino adjoining your property was recently repaired
and roots cut on the south side. The roots were cut about 18 inches from the trunk on the east
side and to an unknown depth. Roots may have also been cut on the north side, but sand was
piled over that area.
I'm sure it comes as no surprise that the one on the west corner of the building at 137 Prospect
appears to be damaging the building itself. Note the lower photograph on page 3.
Discussion
Indian laurel was a common street tree in years long past, but has never been listed in any edition
of Street Trees Recommended for Southern California. In discussing its use with one of the two
Evans brothers that introduced this species to southern California, Bill Evans of Disney fame, he
said he never intended it for street tree use. Anyone familiar with this tree's potential size and
the nature of its roots would not place it near buildings or paving. However, it is a tree that looks
great year round and the cities that have planted it have been pressured into keeping them as long
as possible mostly by local tree lovers who do not individually pay for the damage they do.
ARBORGATE CONSULTING, INC.
H)rr cWwre & ArboricWture
1131 Lucinda Way, Tustin, CA 92780, Pk 714.731.6240, Cell: 714.292.7184, Fax 714.731.6138
5/22/2016 Ficus Street Trees in Tustin Page 12
Those who pass through the areas with large old ficus appreciate the look, but those who live or
have businesses on streets lined with them have an entirely different view of this species. Many
call them "living jack -hammers" or worse.
Certainly they are costing the City much more than more appropriate smaller species, but they
are also costing those who live or have businesses on these streets much more. Many cities have
also had a larger number of law suits for trip and fall accidents due to the difficulty in
maintaining the sidewalks around these trees in a safe condition. This says way too little of the
pain and sometimes crippling injuries that mostly older citizens have suffered. Also consider the
great risk that the line clearance workers have that trim those ficus that are under electrical lines.
This is extremely hazardous work.
I know that the Ficus adjoining your property have cost you a considerable amount of money,
time and concern. They have also been a concern to your renters. I am sure that other business
and property owners have been similarly affected.
Now that these trees are large mature trees, there is little that can be done to stem the tide of
lifted paving, trip and fall accidents, building damage, blocked sewer lines, and other
infrastructure damage.
Since these trees were planted there are more tools and strategies for dealing with new plantings
of larger trees in smaller openings or spaces. However, this is one species that has 'but -witted"
many such newer options. Root barriers have been grown over by Ficus roots and joints between
root barrier panels have been broken open. Silva -Cells provide more root space, but cost too
much to make enough root space to accommodate this large species and certainly do nothing to
confine them.
Look up at an average Tustin Ficus street tree that has not recently been heavily pruned, and try
to estimate the volume of wood in the limbs and branches. There is at least that much root
volume below ground. A large part of the problem is how difficult it is to know where all the
roots have grown. In your case, they are coming up in back of your building, coming up in area
drains and off -setting, blocking or crushing sewer lines. This is too large and too aggressive of a
species for sidewalk cutouts and even most residential streets with typical parkways.
The City itself has recognized the issues with this species and has said in writing that they need
to be removed and replaced. A number of streets have had many removed already and there are
less than half the planting spaces with Ficus than there were originally, such as on South B and C
Streets. It seems to be a "catch 22" situation. The longer it takes to remove them, the more
related expenses there are that take away from the budget to replace them. The situation will not
get better by putting if off longer. The problem is growing about as fast as the trees do.
Recommendation
Do whatever it takes to step up the rate of removal of these trees. I would not be surprised if
business and property owners are willing to have a special assessment district created to pay for
this much needed operation, especially the owner of the property at 137.
Priority should be given to areas where the trees are in sidewalk cutouts and where the buildings
are in closer proximity to the trees.
ARBORGATE CONSULTING, INC.
Horticulture & Arboriculture
1131 Lucinda Way, Tustin, CA 92780, Ph. 714.731.6240, Cell: 714.292.7184, Pax 714.731.6138
5/22/2016 Ficus Street Trees in Tustin Page 13
Photographic Documentation
Naft ant Gait opposite the left edge of the pavers and the pile of sand and pavers on the north side,
41
M r
Note the separated bricks at the lower edge, by the asphalt patch.
ARBORGATE CONSULTING, INC.
Hotticulture & Arboriculture
1131 Lucinda Way, Tustin, CA 92780, Ph. 714.731.6240, Cell: 714.292.7184, Fax 714.731.6138
5/22/2016 Ficus Street Trees in Tustin Page 14
.y r
paving and curb to be removed and replaced, and standing water for mosquito breeding.
ARBORGATE CONSULTING, INC.
Hotticultute & Arboriculture
1131 Lucinda Way, Tustin, CA 92780, Ph. 714.731.6240, Cell: 714.292.7184, Fax 714.731.6138
5/22/2016 Ficus Street Trees in Tustin P Is
Beyond the obvious paving damage, its hard to know how much infrastructure has also been damaged
Please call me if you have any questions.
Respectfully submitted,
(",
k�
Arborgate Consulting, Inc.
Greg Applegate, Registered Consulting Arborist 9365
ARBORGATE CONSULTING, INC.
Horticulture & Arboriculture
1131 Lucinda Way, Tustin, CA 92780, Ph. 714.731.6240, Cell: 714.292.7184, Fax 714.731.6138