Sustainable Sites Initiative – Draft Review Comments
Utah Chapter, ASLA
December 31, 2008
Responses to Suggested Review Questions
How relevant is this tool?
It is highly relevant for landscape-based projects. However, it appears most relevant for public projects. It is not as applicable for commercial and residential projects. Overall, we believe this is very valuable tool for landscape based projects.
Would clients be interested in pursuing prerequisites and credits?
It would be helpful if this document demonstrated more clearly how applying sustainable principles in design and operations could reduce costs. Economic incentives will be important to public and private clients. This document should emphasize how it would make economic sense for developers to go thru this certification process. It should provide government agencies incentives for revising regulations and requirements and provide incentives for developers to use this program.
Do you have projects that could meet all of these prerequisites and credits?
We are not aware of any regional projects that could meet all these. However, we believe that a substantial number of projects could meet about 50% of the requirements.
Are there credits or prerequisites that are too hard or too easy to obtain?
2.4 would be very difficult for a commercial developer to obtain because bringing in the public at an early stage would be very difficult.
3.4 and 3.5 are too easy; use of secondary water sources would effectively circumvent the intent of both the prerequisite and credit and not reduce overall water use.
Are there credits or prerequisites that don’t make sense or are not relevant within our bioregion?
3.4 and 3.5 need to address use of secondary water sources (non-potable water from wells, municipal reuse systems). They should be revised to ensure that overall water use is reduced and encourage efficiency of water use as well as encouraging substantial reductions in use of potable (treated) water.
There needs to be more clarity in the site selection portion and more elements added to it. Avoiding sites or areas of sites with steep slopes or sensitive habitat should be addressed here. Although these are addressed as credits in the site design portion, it would be good to avoid these through site selection whenever possible.
General Comments on Chapters 1-4
Consider using more diagrams in chapters 1-4 (e.g., process development diagram)
Clarify applications of this initiative/ document up front. Although the applications are explained in the document, they are spread around. It will be important to explain to the lay person (e.g., private clients, agencies, etc.) the value and relevance of this initiative. Explain clearly up front: how this document could be used and applied; what the benefits are of doing so; who might use it; what types of projects would be applicable.
Describe clearly what the benefits are for going through the process of getting SSI certification. What are the advantages, incentives, benefits, rewards (e.g., a plaque, an award, lower maintenance costs, reduced operating costs, reduced runoff, reduced infrastructure costs, improved water quality, etc.) Clarify economic, ecological, and social benefits up front.
Consider moving some information regarding economics of healthy ecosystems from Chapter 3 to Chapter 1 to provide a stronger basis for using/ applying this tool.
Clarify that this document is building on existing practices, not re-creating the wheel.
Clarify how it related to current LEED system. Is there overlap with LEED or will it be integrated as one system? We encourage it to be integrated and used as one system.
Clarify how a site qualifies as being “sustainable”.
How will certification be enforced in the long run? Who will monitor and follow-up on whether developers are maintaining their sustainable status? What happens is they don’t maintain their sustainable development rating? Will their plaque be taken away?
Define the term “site” more clearly. How big is a “site”? What qualifies as a “site” versus an area or region? For example, is a 30-mile-long linear greenway, river corridor, or trail system a “site”? Is a 2,000-acre wildlife refuge a “site”? Is a 10-square mile regional park a “site”?
Providing more case studies would be helpful. Although this may be the idea of the future Reference Guide, we believe that more examples (perhaps framed in an appendix and referred to in the document) would be valuable.
Although highly useful, this tool seems a somewhat technical and complex, which may be a disincentive for the lay person or average parks administrator, city council member, homeowner, etc. Is this a tool that only the professional would understand and use? Could there be a more simplified companion version prepared?
We believe that this is a great document and a lot of work has gone into producing it. These are great internal guidelines that every landscape architect that designs landscapes could and should be using. However, some of our Chapter members are concerned that the consistent application of a point system by diverse clients may not be realistic and could affect the credibility of the sustainable design movement. For this program to be most effective, it should be integrated and corroborated with LEED and ICLEI. See:
http://www.iclei-usa.org/programs/sustainability/star-community-index
Chapter 4 could provide more details to emphasize both encouragement and requirement. For example, reducing/ restructuring impact fees may be one tool identified to provide a strong incentive for certification.
Individual Prerequisite/Credit Questions
Comments on Chapters 5
1 SITE SELECTION
Conduct an initial inventory of cultural and historical resources at this first stage so sites where development may have adverse effects on these resources can be avoided. If unavoidable, plans for mitigation and/ or treatment should be part of the project from the beginning. For historic landscapes, the HALS Inventory form could be used for the initial assessment: http://host.asla.org/groups/hppigroup/HALSI%20Form1.pdf. Compliance with NEPA, Section 106 and/ or 4(f) might be required and could be done more efficiently if identified early and done together.
Avoiding sites or areas of sites with steep slopes, landslide zones, or sensitive habitat should be addressed during site selection. Although these are addressed as credits in the site design portion, it would be good to avoid these through site selection whenever possible.
1.1 Prerequisite Preserve threatened or endangered species habitat - This item recognizes only T&E species habitat. It should be expanded to preserve sensitive and critical habitats for a broader spectrum of species (e.g., protecting winter deer and elk habitat is extremely important and benefits a broad range of other species). Other important species are candidate or sensitive species but do not have official T&E species status at the state or federal level.
Consider adding a credit for selecting sites with a potential for ecological restoration Floodplain functions identified in 1.2 seems too limiting. Consider addressing wetlands also.
The terms “protect”, “preserve”, and “restore” should be clearly defined. Does “protect” include enhancing what is already there? Do “preserve” and “protect” mean don’t touch or manage?
2 PRE-DESIGN ASSESSMENT AND PLANNING
Pre-design works well for parks or master-planned communities, but not so well for commercial development. This is good for public projects, but how can private developers get credits? Will this credit make or break qualification for certification? Are credits going to be weighted or can partial credit be given? Can site design modification get credit?
3 SITE DESIGN – ECOLOGICAL COMPONENTS
3.2 Prerequisite Use appropriate, non-invasive plants/ 3.9 Credit Promote a sense of place with native vegetation – The integrity of some historic sites may be compromised if plants used historically are replaced by native vegetation. The significance of the site must be considered before altering plantings and consequent maintenance practices.
3.3 Prerequisite Preserve special status trees - Define “no-disturbance zones.” Also need measures to maintain trees during construction, i.e. consultation by certified arborist.
3.4 Prerequisite Reduce potable water consumption for irrigation/ 3.5 Credit Minimize or eliminate potable water consumption for irrigation - Eliminating potable water from landscape irrigation use is not feasible in places where supplemental water is necessary, but no secondary or greywater source is available.
3.5 Credit Minimize or eliminate potable water consumption for irrigation - Needs to clarify and emphasize that water use in general needs to be reduced; the focus shouldn’t be just on potable water. Reducing use of natural surface and subsurface water is good, but this credit should also address and account for secondary water, which is used extensively in most western states. In Utah, Idaho, and Wyoming, secondary water is not treated (potable) water but still needs to be conserved.
3.6 Credit Preserve and restore plant biomass on-site - BDI does not include cryptobiotic soil crusts, an important erosion-preventing cover type in arid regions: http://www.nps.gov/archive/care/crypto.htm. This credit appears to be biased to eastern U.S. and other more hydric environments with lots of trees. It may be hard to achieve the credit in Utah or drier regions in the west where trees are not as common and shrublands and grasslands dominate the landscape. In these drier regions, trees are often associated with riparian areas or other wetter environments and may not be the best choice for increasing biomass, fitting with the landscape character, and conserving water use. Preserving existing biomas should be the highest priority.
4 SITE DESIGN – HUMAN HEALTH COMPONENTS
It would seem that one or more prerequisites would be important here. Consider redefining 4.2, low point value, as a prerequisite. Consider redefining 4.3, or aspects of it, as a prerequisite. Consider redefining aspects of 4.6 as a prerequisite.
4.9 Credit Design stormwater management features to be a landscape amenity - There appears to be some overlap of 4.9 with 3.16 and 3.17; consider better integrating 4.9 with these and clarifying how they are related or expanding 4.9 to address other purposes besides stormwater management. For example, municipal groundwater recharge facilities and constructed wetlands can also provide multifunctional amenities for wildlife, recreation, open space, aesthetics, and environmental education and interpretation.
4.11 Credit Protect and promote unique cultural and historical site attributes - Consider redefining this credit as a prerequisite. It would seem that Option 1 should be a prerequisite.
5 SITE DESIGN – MATERIALS SELECTION
5.4 Credit Reuse on-site structures, hardscape, and landscape amenities - This is actually a historic preservation issue, and should be identified and treated as such on sites identified as historically significant. See The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for the Treatment of Cultural Landscapes for more information see: http://www.nps.gov/history/hps/hli/landscape_guidelines/index.htm
We also believe that this is a recycling issue and should be done on all rebuilt projects regardless of historic significance. However, greater importance should be paid to this topic if the site is historic.
6 CONSTRUCTION
6.5 Credit Control and retain construction pollutants: Prevent polluting the air with dust and particulate matter - This is an especially important public health issue in arid environments such as the Southwestern U.S. where Valley Fever, coccidioidomycosis occurs.
7 OPERATIONS AND MAINTENANCE
It is not clear how operations and maintenance would be monitored to ensure that the practices and guidelines identified in the Landscape Maintenance Plan are being followed and to what degree. Some of these items would be more important (i.e., have a greater impact) than others and could be identified as separate credits. For example, a credit could be developed for reducing use of chemicals (e.g., pesticides and fertilizers) and other compounds that may be detrimental to ecosystem functions or human health. The emphasis should be on organic, biodegradable, and mechanical controls for maintenance and operations.
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Jul 10 2009