The Portland City Council is weighing the merits of the proposed Residential Infill Plan. The Architectural Heritage Center submitted the following testimony about achieving density without sacrificing a sense of place. Among other issues, we urge the city to try a model project prior to making sweeping decisions.

Here is our written testimony to the mayor and city council:

Dear Mayor Hales and City Commissioners:

Part of the mission of the Architectural Heritage Center/Bosco-Milligan Foundation is to promote environmental and cultural preservation through the conservation and reuse of Portland’s historic architecture and neighborhoods. In recent years we have watched with dismay as character-defining housing has been lost without offsetting gains in other public objectives. Unfortunately, this has been combined with a general decline in affordability.

The Residential Infill Project was intended to deal with some of these issues. While a few of the proposed elements appear to achieve the goals of increased affordability and reduced demolition of existing (and therefore, lower cost) housing, many of the proposals are untried. Some of the analysis by staff suggests that they will not achieve the intended goals.

As a result, the Foundation can only support a few of the elements in the Concept Report. We do not think it is ready for adoption in its current form. The sweeping nature of the proposal flies in the face of roughly 40 years worth of comprehensive planning. Our main concerns are as follows:

1) There is no urgency to allow additional housing units. As demonstrated during the recent Comprehensive Plan update, current zoning is adequate to meet projected housing demand, though it does not guarantee an adequate supply of affordable housing. Unfortunately, the staff report suggests that the additional units and additional housing types proposed in the Concept Report also have no guarantee of increasing the number of affordable units.

2) “One size fits all” is not a good planning strategy in a city that values neighborhood planning. The Comprehensive Plan calls for a much more nuanced strategy that recognizes the variation in neighborhoods and housing types. The Concept report should be refined to recognize some of those differences. We recommend a closer look at the work that nationally-recognized urban planning expert Nore Winter is doing in Los Angeles and some other cities as one possible way to improve the approach.

3) The ideas contained in the Concept Report may be ready for some pilot projects, but given the first two points above, they are not ready for blanket application over large areas of the city. It appears that some neighborhoods are supportive of some of the measures and it would be appropriate to test the concepts in the field before they are applied broadly. There will be instances where it is vastly preferable from both affordability and historic preservation standpoints to divide larger older homes into multiple units instead of tearing them down.

Therefore, to decrease the pressure for demolition of existing buildings and consequent erosion of neighborhood character, and increase the opportunity for affordability, the AHC/BMF supports:

1. the proposed reduction in the allowable maximum square footage and the revisions to the measurement of height;
2. proposals which allow additional units within existing buildings when appropriate;

We also support two additional requirements, aimed at decreasing demolition and increasing the number of affordable units built:
3. allowing a third accessory dwelling unit only when the existing building is reused.
4. a requirement for an affordable unit, or units for larger projects, should be included in any final proposal.

These measures are steps in the right direction, but we recommend that additional analysis from experts like Nore Winter for different areas of the city be included in the next phase of the project.

The staff report notes that there is no surety of affordability with any of these housing forms but the entire purpose of the increase in allowable units is predicated on gaining affordable units. We believe that the city should use its newly-granted state authority to tie the increase in allowable units to increasing the affordability for Portland and its residents.

Thanks for the opportunity to comment.


Stephanie Whitlock, Executive Director

Steve Dotterrer, Vice President/Chair, Advocacy Committee