Op-Ed By David Krogh, AICP

Retired Planner

I am a resident affected by this project and have already submitted comments via your online survey. However, I wish by this letter to get my name into the record and to provide you with specific comments not addressed by your survey format.

I am a retired planner and have been observing with great interest Portland’s procedures in light of the major problems with housing availability and affordability in Portland these past few years. My first observation is that Portland has lost track of the need to plan comprehensively and to view planning issues holistically. This has resulted in multiple separate projects addressing problems in a piecemeal fashion. In such a situation, problems (more often than not) do not get resolved.

I recently was a moderator at the joint ISOCARP/OAPA conference. I attended two other sessions with Portland Planning speakers who talked about the Portland Plan and the SW Corridor Project. In both sessions, speakers admitted that the Portland Plan was lacking in how it addressed housing needs in light of State Goal 10 (Housing). The plan did not adequately address the need for a variety of housing types to fit a variety of income levels. This is likely one reason why there is a “missing middle” in terms of available housing and a housing affordability crisis in Portland today.

The Infill Project is a piecemeal approach to address the above. However, it does not look at the issues of housing availability, variety and affordability in a holistic manner. In fact, this project has the potential to greatly impact the livability and character of many older established neighborhoods in Portland without consideration of the “missing middle”, infrastructure needs, needs for new parks, street maintenance needs, etc. In short, this is a piecemeal approach to planning.

The Infill Project appears to be extremely biased in trying to “inject” substantial density into Portland’s eastside neighborhoods (east of the river out to I-205) with very little impact on Portland’s west side. This protects the integrity of neighborhoods in west Portland while exposing thousands of acres of existing older single family neighborhoods in east Portland (including N, E and SE Portland) to the potential for demolition of older houses and replacement by skinny homes, duplexes/triplexes, and ADU’s.

The density increases proposed by your half mile corridor swath rezonings, the proposed ‘a’ overlay, and the push for ADU’s will result in increases of from 2 to 4 times the current density allowances, depending on the parent zone. The areas involved with these proposed changes will no longer be low density residential. They will, in essence, be moved into a moderate density range. Is the Infill Project attempting to make existing low density areas into areas that can accommodate the “missing middle”? If so, that is not the way concentric zoning theory works and something the flawed Portland Plan should have addressed, but evidently didn’t.

As mentioned, the “a” overlay and zone density increases along a ¼ mile radius from transit streets (a half mile swath) is a substantial change to neighborhood character. This proposes my own property for a change from R5 to R2.5. and my neighborhood is an older neighborhood of craftsman bungalows, cottage style, cape cod, and other varieties of homes.

Under the proposal, I fully anticipate many of these homes will ultimately be torn down and replaced by skinny homes, duplexes/triplexes, and rowhomes, which will clash with existing architectural styles. I anticipate many homes, because of the tight fit of homes on smaller lots, will not provide any landscaping or driveways, and that parking on street will be in complete chaos because of this new density and from all the new apartment buildings going up on nearby transit streets which do not have their own parking.

In short, you’re going to turn our neighborhoods into crowded ant farms, but you won’t be fixing the streets, doing anything about parking problems, or adding new neighborhood level parks to accommodate the thousands of anticipated new residents. How do you justify this by the Statewide Planning Goals? Granted, changes will not come overnight as planning doesn’t work that way. However, in 20 years, our neighborhoods will not be the same as now. The question then becomes, will they be better or worse?

And what about the “missing middle”? Wouldn’t it make sense to hold off on the Infill Project until you can figure out how to accommodate this “missing middle”? Think of the potential to provide for housing needs if you had areas designated in moderate to medium density to contain courtyard apartments, garden apartments, tiny home clusters, communal living clusters, etc.

Take a look at the housing cluster located at SE 41st and Division St. to see how a variety of housing sizes/shapes can be located on a smallish site but including landscaping for separation and buffers. We need more of these types of developments! Again, the housing crisis should be looked at holistically, not in piecemeal fashion, as good comprehensive planning calls out for. If you had areas identified to accommodate the “missing middle” you wouldn’t need to densify the heck out of our traditional single family neighborhoods.

Your proposed bonus unit in the ‘a’ overlay for affordable housing is questionable. How would this be implemented? You need to realize that the 80% mark indicated is still substantially higher than a person earning minimum wage can afford. You need to lower the bar or your level of affordability will be too high. The push for ADU’s is surprising since for years these were not considered to be viable to count as “units”, but now they are?

If you do go ahead with changing the lot size allowance per unit for R5 (from 1/5000 sf to 1/3000 sf), you should change the name of the district to R3 so as not to be misleading.

In defense of home builders, Portland has the reputation of being the most expensive and bureaucratic city to build in within Oregon and most of Washington. Part of the problem is, the bigger Portland becomes, the more cumbersome and expensive the permitting processes. The current archaic commission form of government complicates processes because of the separation of bureaus under different commissioners leads to budget competition and lack of cooperation between bureaus. You might consider major simplification to permit processes with dedicated staff to work just in those areas and with specific processing timelines. If you improved processing and cut expenses, you would see better quality housing being constructed and it would be easier to encourage the construction of more affordable (to all) units.

Finally, I resent that E Portland appears to be singled out for densification while the west side gets to keep its character and integrity. This type of activity has the potential to create not only a new type of gentrification within our older east side neighborhoods, but to change the character and livability of those neighborhoods in a negative way. What is the justification for this, and, why the rush?

I urge you to extend the comment period for this project. I only discovered the project website recently and others I’ve talked to were unaware of it at all (the project has not been well advertised considering the large area of the City it impacts). Please plan for Portland’s growth holistically and get it right the first time, otherwise we will all suffer in the future from today’s mistakes.