Introduction
The Residential Infill Project includes two Proposals intended to drive greater density into Portland’s single family zones: 1) By applying new rules to the existing R2.5 zones (requiring one residence per 2500 square feet of lot area) and 2) By opening the floodgates of demolitions in R5 (1 residence per 5000 square feet of lot area) to achieve R2.5 type density in R5 zones where the underlying lots of record were originally 2500 square feet. While we feel that there is some merit in the first proposal (Proposal 6 in the RIP draft recommendations), the second approach (Proposal 7 in the RIP draft) is a dreadful and misguided solution to a real issue that Portland faces.

While much is currently being made about the shortage of affordable rental housing in Portland, it is equally true that single family home prices are escalating rapidly throughout the city. The City’s mantra that the Millennial Generation prefers rental housing in the inner city is disproved by both local and national surveys that suggests Millennials want single family homes in walkable neighborhoods, regardless of whether they are in suburban or central urban areas. (See What Millenials Want and Why It Doesn’t Matter)

Even if BPS projections of future increases in the share of multi-family housing in Portland prove true, there are also projections calling for 28,000 new single family residences (SFRs) to be built in Portland to accommodate that part of our expanded population who will demand their own stand-alone homes in the next 25 years. To accommodate that growth, Portland right now should be building a net 1200 additional houses each year. Instead, we are building roughly 900 per year, and demolishing 300 to do it, for a net gain of just 600 additional homes... an under- attainment of 50%, which can only lead to further dramatic run-ups in already-unaffordable home prices.

The approach Portland Comprehensive Plans and actual base zoning designations have taken is to expand the coverage of the R2.5 zone, gradually “upzoning” existing R5 zones to accommodate double the number of residences in a 5000 square foot land area. In effect, the City aspires to the potential demolition and replacement of houses in these upzoned areas to gain a 2-for-one replacement rate, for a net gain in the number of SFRs. As with all such “aspirational zoning”, the actual accomplishment of the density goals has been left to the real estate marketplace, which has been slow to achieve the conversion. The RIP recommendations argue that a major reason for this slow rate of conversion to higher density has been the result of rules requiring a single family home to be built on a 5000 square foot lot after a demolition in an R2.5 zone. That led to the proposal to require one house per 2500 square feet in R2.5 zones when new construction occurs. While the objective is laudable -- realizing the intended density of the zone -- the problem is largely theoretical, since there is a lot confirmation process that allows 5000 square foot lots of record to be subdivided into two 2500 square foot lots.

Still, frustrated by both the slow pace of densification in existing R2.5 zones and the affordability crisis in the SFR market, RIP proposals seek both to further expand density in existing, already dense R2.5 zones as well as to target selected lots in R5 zones for lot splitting without changing their R5 designation. Both of the strategies can lead to dramatic increases in demolitions, first in R2.5 zones themselves, and, without justification, in R5 zones as well, based on quirks of underlying historic plats.

In the latter case, RIP proposals have focused on the historic 2500 square foot lots of record in R5 zones as a way to expand R2.5 zoning rapidly without the tedious public process inherent in the Comprehensive Plan and without the need to acknowledge the amount of available capacity already provided by existing zoning. The issue comes down to the fundamental question: do we throw away 25 years of thoughtful city planning and, instead, scatter-shot effective R2.5 zoning around the city, randomly disrupting R5 zones in pockets determined by quirks of historic development, or do we pursue a rational expansion of the R2.5 zones where the infrastructure and proximity to true high frequency transit support it, using the tools already available to the City? And do we explore ways to densify these rationally upzoned areas sensitively and thoughtfully to preserve as much as possible of the historic charm and livability of these neighborhoods. In general, the RIP proposals fall short in both cases.

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The Portland Coalition for Historic Resources is an ad hoc group advocating for the concerns of Portland's many Historic Districts and Historic Conservation Districts. The group also supports and advocates for the nomination of other historic districts in the City, recognizing Portland's unusual history among Western cities leading to a wealth of largely intact early 20th Century Streetcar Suburbs in the inner core. Those historic Streetcar Suburbs today are among Portland's most cherished neighborhoods and are not only prized places to live but also attract tourists from around the country.

PCHR members have reviewed the documents provided by the Residential Infill Task Force BPS Team and in general have grave concerns. We find that supporting information appears to have been hastily assembled, that the arguments in favor of the proposals lack factual basis, and to the extent that the proposal as currently set forth would be implemented, there is a very good chance of unwarranted disruption and dislocation within Portland’s already densely populated inner neighborhoods. We are also disappointed that the conveners of the RIP Task Force at the outset excluded the topic of Historic Preservation, thus excluding from the conversation any potential impacts on or conflicts with Portland's designated historic neighborhoods and districts.

Perhaps worst of all, the provisions seeking to achieve more “affordable” “middle housing” appear to offer false hope to the thousands of Portland residents who currently spend an inordinate amount of their incomes on housing. That said, we feel that there are some parts of the recommendations, which could, with some wording improvements, prove valuable to the City.

Summary of Concerns:

• Proposal 1 - Limit the size of houses... - The one-size-fits all approach based on lot size is an overly simplistic solution that ignores experiences in other cities with more thoughtful approaches. The prospect of "variances" granted for exceptions could nullify the effect of the proposal. Proposed size limits in R2.5 zones on 2500 square foot lots are even more flawed then those for R5 zones and 5000 square foot lots.
• Proposal 2 - Lower the House Roofline - Generally a very welcome concept, both in terms of measurement framework and absolute limits. Concerns remain as to reasonable flexibility where the context calls for it, consistent with protecting the integrity of the rules themselves in the face of poorly regulated variances.
• Proposal 3 - Make Front Setbacks Consistent... - Another welcome proposal, but the wording needs to be fixed to avoid matching setbacks to recently built infill homes with inappropriate setbacks. No variances should be allowed to this regulation.
• Proposal 4: Allow more units within the same form as a house near Centers and Corridors - A proposal which will achieve very little in terms of increases in affordable housing, while exacting an inordinate cost in congestion, loss of viable single family homes, and disruption of neighborhood fabric at locations scattered across the City. The relatively limited exploitation of the long-existing corner duplex rule suggests that this proposal would simply scatter a few units across the city where lower home values or special situations allow for exploitation of the rule.
• Proposal 5: Allow cottage clusters on lots larger than 10,000 square feet. - A potentially useful concept when mass demolition of existing, viable single family housing is not required. Extending this concept to R10 and R20 zones, where such large lots already exist, could mitigate the density penalty of these suburban-style zones across the 6 square miles they occupy in Portland.
• Proposal 6: Establish a minimum unit requirement for R2.5 zone lots. - This appears to be a solution in search of a problem. While it is true that if a home on a 5000 square foot lot in a R2.5 zone is demolished, only one house can be built -- if the lot is not legally split by the owner. Such splits, however, are commonplace. A reduction in the inordinate BDS charges for such splits could remove one significant stumbling block to these splits.
• Proposal 7: Allow new houses on historically narrow lots - By far and away the worst, and most potentially destructive proposal in RIP. Puts many thousands of viable, relatively affordable, single family homes at risks in areas designated as R5 zones because their transit and infrastructure are designed for medium-high density R5 zoning, not R2 or higher density zones. Sadly, this proposal is supported by affordable housing advocates who seem to assume that the newly constructed skinny houses replacing the demolished historic homes will actually be lower in cost than the homes they replaced -- an assumption not supported by real estate economics or actual observation.
• Centers and Corridors Concept - The amendment to the Comprehensive Plan goals to encourage "middle housing" along "centers and corridors" within 1250 feet of "high frequency transit", was poorly vetted and hastily adopted. Most egregious was the 1250 foot metric itself. Not only is it a radical departure from Portland planning practice, but also a mis-application of research findings relative to acceptable walking distances from high frequency heavy-rail transit like BART or the Washington METRO, to medium-to- low frequency bus routes. We recommend that no radical, new zoning allowances be introduced using the 1250 foot rule, and that, at most a 500 foot rule, applying only to bus routes with a minimum of 15 minute frequencies during peak hours, be used in high potential experimental sites.
• Misreading of history - Proponents of the current proposals argue that single family zoning is a product of the 1950s with a possible racial motivation. This is ludicrous. Portland inner neighborhoods were shaped by strongly worded deed covenants made legal by a court case in 1879. These covenants protected property values in single family areas and were extremely popular with home buyers in the late 19th and early 20th Centuries because those buyers understood what most home owners today understand: that their home would be the single most important investment they ever made. Nearly all of Portland's inner neighborhoods were once covered by these covenants.

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Politics has been called "the Art of the Possible", and this has been in vivid display in the effort by the grass roots organization United Neighborhoods for Reform (UNR) to better regulate and slow down the pace of demolitions of single family homes - currently exceeding 300 per year.

You can watch a UNR video showing how demolitions are affecting neighborhoods: https://www.youtube.com/watch?v=Uqo-M8eFNXo&feature=youtu.be

As a member of the ICA's Land Use Committee who is volunteering as a member of the UNR steering committee, I've been a close observer of the work the group has done since its formation in the summer fo 2014.

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