The AHC submitted written testimony on the Better Housing by Design proposed draft of May 2018. Below is a copy of our testimony submitted to the Planning and Sustainability Commission, City of Portland. You can read more about Better Housing by Design on the Bureau of Planning and Sustainability website


The Board of Directors of the Bosco-Milligan Foundation, owners and operators of the Architectural Heritage Center, generally supports the responsiveness to Portland’s demographic and economic pressures that is reflected in the Better Housing by Design proposals.

We appreciate the additional protections given to properties with historic resource designations within the proposed modifications of multi-dwelling zone specifications. For example, we support the continued exemption of properties with historic resources (individual landmarks and contributing structures in Historic or Conservation districts) from minimum density requirements for any development of additional residential units (33.445.610.C.6). Moreover, we strongly support the provision that the FAR (floor to area ratios) may be transferred from “a site that contains a Historic or Conservation landmark, or contains a contributing resource in a Historic District or Conservation District,” but the receiving site excludes multi-dwelling zones in Historic or Conservation districts (33.120.210).

However, we are very concerned about the proposed rezoning within two Historic Districts: much of the Alphabet and all of the King’s Hill Historic Districts that are currently zoned RH are proposed to be re-zoned to RM4, rather than RM3. The RM3 zone is characterized as “medium to high density” with “mid-rise” buildings “up to six stories tall.”  In contrast, the RM4 zone is described as “high density,” “an intensely urban zone…with buildings located close to sidewalks”…”a mid-rise to high-rise zone with buildings of up to seven or more stories” (33.120.030). Moreover, in the RM4 zone, a Deeper Housing Affordability bonus can increase the FAR to a maximum of 7 : 1 (Table 120-5), almost doubling the density from the current RH zone base maximum FAR of 4 : 1. Attached is a copy of one of the building prototypes that reflects a deeper affordability bonus with a FAR of 6.84 : 1, eight stories tall with a height of 80 feet (RM4 maximum height is 100 feet). Such a building would surely be out of place on the residential streets in either of the historic districts.

We believe that within the Alphabet and King’s Hill historic districts, it is clearly inappropriate to encourage development on the residential streets of buildings that are so much out of scale (i.e., larger, taller, and denser) than the surrounding historic neighborhoods of primarily detached houses and low-rise multi-dwelling structures. Beyond preserving individual landmark and contributing historic structures, the Bosco-Milligan Foundation/Architectural Heritage Center and the local preservation community seek to maintain the distinctive character of designated historic districts, which contribute to Portland’s unique collection of diverse neighborhoods. We regularly offer a number of popular walking tours of both the Alphabet and King’s Hill historic districts, which we do not want to become only a shrinking number of historic structures scattered within a sea of massive and monolithic apartment and condominium buildings. Unfortunately, we fear the proposed re-zoning will result in exactly that outcome.

In summary, we strongly oppose the proposed re-zoning of any areas of the Alphabet or King’s Hill Historic Districts to RM4. We request that all areas within those historic districts that are currently zoned RH be re-zoned to RM3.

Thank you for your attention to this concern.