WE NEED YOUR VOICE AGAIN TO SUPPORT Abundant Housing IN PORTLAND ON JUNE 10th.

City Council is holding a second hearing for DOZA to hear testimony on amendments. DOZA is a project from BPS & BDS aimed at simplifying the design review process and improving the clear & objective path to building housing in our highest opportunity centers and corridors. The next hearing is Thursday, June 10th, and we need your testimony of support.

Amendments

What we support: 

• Amendment #4: Affordable Housing Review (Rubio) - Allow more affordable housing projects to choose between a Type II and Type III procedure. Expands the eligible projects to those using a wider variety of funding options beyond City Subsidy projects. Thresholds are 50% of units at or below 60% median family income (MFI).

  • PNW supports this amendment to give affordable housing developers options for Design Review, based on the needs of their individual projects

  • If developers are providing long-term truly affordable housing, they should not be excluded, if they are not receiving City funds

  • Affordable builders we’ve heard from strongly support providing Type II as an option for affordable housing that isn’t receiving City funds

What we oppose: 

• Amendment #5: Threshold for Design Review - Reduce the threshold requiring design review instead of Standards, from 75’ to 55’, except for projects meeting the affordable housing eligibility requirements in Amendment #4. Those affordable housing projects can choose to use the design standards or go through design review.

  • PNW opposes any amendment that discouraging housing in our high opportunity neighborhoods by exposing it the risky and costly appeals 

  • BDS just released data showing that projects with housing are 20X more likely to be appealed than projects without housing

  • Every time a building with housing is appealed, it discourages future housing from being built, even if that appeal is eventually dismissed 

  • We can avoid these appeals, by adopting the Planning & Sustainability Commission’s recommendation to give all buildings with housing up to 75’ tall the option to use appeal-proof Design Standards

  • These Standards raise the bar for building designs due to 5 years of collaborative discussions and hard work with the public, City staff, and the Design and Planning &  Sustainability commissions 

  • Design Standards continue to allow the community to provide meaningful feedback to developers through the Neighborhood Contact process

• Amendment #7: Ground floor active use in Arbor Lodge (Ryan) - This amendment adds a new Context standard for the eastern edge of the Arbor Lodge neighborhood along North Interstate in the CM3 zone that requires ground floor active uses in new buildings.

• PNW opposes this amendment as it could require new projects with housing to subsidize retail space leading to higher rents or less housing

• Comprehensive Plan only required active uses in projects with housing, if there would be sufficient demand to support it

• In other parts of Portland, it should be an option not a requirement

• Unanimous opposition to this requirement from affordable builders, because it can kill projects by requiring housing to subsidize empty storefronts
  

Neutral:

• Amendment #2: Makeup of Design Commission (Ryan) - Move positions with expertise in natural resource management and sustainable building practices to the larger list of development-related experts from which 5 members are chosen, instead of reserving a position for each expertise.

  • While Portland: Neighbors Welcome is neutral on this amendment, we would like to see the spirit of our original proposal-- to include a permanent member with experience living, designing, or building affordable housing on the Design Commission-- continued in other conversations in the future. 

  • We look forward to engaging with the City and others in these future conversations on equity and diversity 

• Amendment #3: Main Street Standards (Mapps) - This amendment adds 5 optional design standards for projects on sites with the Centers Main Street overlay (m-overlay) in the Inner Pattern area.

  • PNW is neutral on this amendment and supports the 5 years of work by staff, Design and Planning & Sustainability commissions to develop culturally neutral Design Standards

  • Our Design Standards should encourage Main Streets with a diversity of cultural and architectural styles

  • Council should consider character statements as a way for neighborhoods to inform designs in their neighborhood instead of codifying a single style

• Amendment #8: Directive to create character statements (Wheeler) - Direct the Bureau of Planning and Sustainability to create character statements with area-specific plans that have the Design overlay zone.

  • Character statements should be very short - even as little as a single sentence - concentrating on details that comprise character, enhance neighborhood identity, and offer architects useful guidance during project design.

  • Statements should not become de facto rezonings prescribing height, FAR, or massing or hyperlocal design manuals that can kill projects or drive up costs, like the Macadam Character Statement with phrases like “new development should be designed to limit scale impacts”.

Here are our previous testimony recommendations, in case you’re curious what we said last time:

a committee of volunteers giving ‘design review’ wasn’t necessary to build the lovely affordable apartments above.

More projects should have the same option. We don’t have to sacrifice good architecture to make that possible.

Portland is considering a long-awaited change to how it regulates the design of new buildings. Though it could be better, it’s mostly good. Unfortunately, some homeowners in high-end neighborhoods are trying to use it to win undemocratic veto power over new buildings near them.

Portland’s so-called DOZA project would create an objective, appeal-proof point system as an option for evaluating the design of most new buildings in the so-called “design overlay” of multifamily areas in mostly higher-end, closer-in neighborhoods. This would offer projects an alternative to “discretionary design review,” which sends almost every new building through a subjective committee process that’s hard to predict, can last for more than a year and — worst of all — is vulnerable to obstructive NIMBY appeals.

The subjective design review process would still be an option for architecture teams that prefer to color outside the lines. But it shouldn’t be the only option. This is what we’ve heard from the many affordable housing builders and advocates who’ve signed our coalition letter on the subject.

And the city definitely shouldn’t open the door to anything that could evolve into a patchwork of hyperlocal design standards controlled by homeowners in well-off areas.

Talking points: reforming Portland’s design regulations

The Design Overlay Zone Amendment project (DOZA), is a project from Portland’s Bureau of Planning and Sustainability aimed at simplifying the design review process for our highest-opportunity centers and corridors.

DOZA allows more buildings with housing: 

• To receive approval by earning Design Standards points based on clear criteria. Oregon law requires this clear and objective path for housing projects, which streamlines approval and is easier for small builders and property owners to use.

• To use the Type II review by staff, if they choose the discretionary design review path. While not as predictable as the objective Design Standards, Type II avoids the public hearings at the Design Commission required by Type III review.  

Both the improved Design Standards and Type II staff review can reduce delay and costs in building housing, making it more likely that new housing will be built. 

Building denser, mixed-use housing in high opportunity neighborhoods is good for the planet and good for the people who live here. Simplifying the design review process will encourage more abundant and affordable housing, and help fill the gap in our much-needed housing stock. 

Great parts of DOZA that Council should support:

1. Allowing taller buildings with more housing to use simple Design Standards instead of going through a long & expensive design review, to encourage more housing in our highest-opportunity neighborhoods like Slabtown, Hollywood, and Kerns.

2. Clarifying that the Design Commission cannot reduce the size or height of buildings, which can reduce the amount of new housing built.

3. Limiting Design Advice Request meetings to 1 per project to remove months of meeting time to submit new housing projects for approval. 

Council can improve DOZA by:

1. Expanding Type II review option to:

   • All regulated affordable housing projects certified by the Housing Bureau, NOT just projects receiving City dollars.

   • All buildings up to 75’ that are using the Inclusionary Housing height bonus. This will create more affordable housing than requiring the time-consuming Type III review.

2. Ensuring the Design Commission is ALWAYS informed by affordability by requiring one member with experience living in, designing, or developing affordable housing.

3. NOT doubling Design Standard points required for buildings between 55-75’ tall. This should be a sweet spot for Inclusionary Housing and other affordable housing. 

Council should oppose:

1. Wealthy neighborhoods' privately developed “Main Street” guidelines that make it harder to add housing in our highest-opportunity areas and deepen growing disparities in Portland.

2. Long, overly detailed Character Statements if they become de facto rezonings or prescribe height, FAR, or massing or hyperlocal design manuals that can kill projects or drive up costs.