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' <br /> 8.A <br /> Page112 <br /> Appeal of Issuance of Architectural Permit Page 4 of 13 <br /> 448 Saint Francis St. <br /> Project No. AP-2010-9 <br /> and environmental benefits to the neighborhood caused by the removal of the would be <br /> substantial, reasonably quantifiable, and totally avoidable. <br /> a. Appellants would have demonstrated that the Tree is extremely valuable and <br /> beneficial because of its large crown (per GoogleEarth, ca. 50' x 33' — or <br /> approximately 1%2 times larQer than stated by the second arborist) and by <br /> establishing that in an urban context, the size of the crown of the Tree and the <br /> and not its girth or other Forest Service indices of value are the relevant standard <br /> to assess the aesthetic, sociaVcommunity, and environmental of the Tree. <br /> b. Applying these more appropriate valuation standards, Appellants would also <br /> have demonstrated that, $3,190, the appraised value of the Tree, substantially <br /> understates the real value of the Tree to the community, and, in the event that the <br /> Tree is removed, enables the Applicants to avoid paying a fair amount into the <br /> City's tree fund to compensate for the destrucrion of the Tree. <br /> c. By referencing the first and second arborist reports, Appellants would have <br /> also demonstrated the obvious conflict of interest that arises when property <br /> owners directly pay arborists to produce legally mandated reports upon which the <br /> Planning Department i•elies that are intended to be factual, neutral, and without <br /> bias, but which, in fact, provide analysis and recoirunendations that generally <br /> benefit the property owners. � <br /> Conclusions of Fact and Law that Appellants would have Demonstrated: The Planning <br /> Department failed in its duty (a) to follow the Guidelines, (b) to balance the desire of the <br /> property owner with the aesthetic, sociaUcommunity, and environmental interests of the <br /> adjoining and nearby property owners, of the neighborhood, and of all residents of <br /> Redwood City by unreasonably authorizing the removal of a valuable element of the <br /> streetscape and the neighborhood, and (c) to insure that vital information provided by the I <br /> arborists about the Tree, upon which the Planning Department relied in making its <br /> determination about the Tree, was genuinely accurate and unbiased. <br /> �---- - <br />