Written Testimony on Historic Preservation and the 2035 Comprehensive Plan - Before Portland City Council

by James S. Heuer, Chairperson, Portland Coalition for Historic Resources

Mayor Hales and Members of the Portland City Council, my name is Jim Heuer, and I write this as Chair of the Portland Coalition for Historic Resources. This volunteer organization represents the largest historic districts in the City, preservation activists, and the two major regional non-profits dedicated to historic preservation: the Bosco-Milligan Foundation and Restore Oregon. I am one of the PCHR representatives from the Irvington Historic District, and we have representatives from the Alphabet District, the proposed Buckman historic district, the Ladd's Addition Historic District and several neighborhoods which are not officially designated but are every bit as important historically at both the State and National level, including Laurelhurst and Eastmoreland.

PCHR representatives will be supplying detailed remarks on neighborhood-specific concerns, but here is the bigger picture:

Portland is an old city. Many people like to think of Portland as a hip and happening place, but much of its appeal to tourists and the influx of the creative classes is our built environment... our picturesque downtown and historic Old Town and Chinatown areas, our vast bungalow neighborhoods dating to the early 20th Century -- providing the same cozy, practical housing for the middle and working classes as they did 100 years ago, and the precious survivors of the halcyon days of the 19th Century when Portland was the richest city per capita west of Chicago. The numbers tell the tale -- if you exclude the areas annexed to Portland in the 1990s, the age of our housing stock is comparable not to that of western cities like Los Angeles, Phoenix or Houston, but instead to Chicago, Philadelphia and Baltimore.

And unlike cities like Cleveland, Buffalo, Philadelphia and others in the east with shrinking populations and a desolate historic core, our historic neighborhoods are vital, popular places to live -- cherished by their residents, appreciated by thousands of heritage tourism visitors, and drawing ever greater numbers of eager buyers – indeed their very popularity threatening the affordability, cultural diversity, and character that has drawn people to Portland in the first place. Moreover, they include some of the highest density areas in the City – many, like the Irvington Historic District, having a population density more than double that of Portland as a whole. But you'd never know this from reading the Comprehensive Plan documents.

Sure, there are some lovely goals and sub-goals that mention these issues, but in the proposed zoning, where the rubber meets the road, the Plan exhibits the same destructive one-size fits all aspirational zoning that has resulted in the current cacaphonous state of development in Portland... Development which has succeeded in disrupting the fabric of our traditional neighborhoods and business streetscapes while achieving minimal overall increases in the concentrated residential density required for meaningful reductions in transportation-based carbon footprint.

The problem is that aspirational zoning applies higher density zone designations wherever the planners hope some-day greater density might happen -- without regard to what is already there. The "hope" is that the real-estate market will produce the density and help the city achieve its carbon footprint reduction goals. Since the planners freely admit that the "realization" of the build-out of those areas will never approach 100%, the only solution is to over zone in hopes of someday getting to the desired density. Sadly, the result is a scattershot of higher density projects -- eroding the character of our neighborhoods -- without ever once achieving the critical mass of density to support 10-minute transit intervals or a major expansion of bicycle corridors crisscrossing the city.

But not only is the already-observed outcome of this scatter-shot approach to increasing density a failure... it is also a direct violation of state law. Portland is a signatory to an agreement with the State of Oregon and is thus designated as a Certified Local Government, which requires Portland to apply its zoning powers to protect and nurture its designated historic districts and to stay current on what parts of the city are or should be historically designated. The Comp Plan's refusal to align zoning with historic resource review guidelines covering thousands of contributing structures in both Historic Districts and Historic Conservation Districts is an affront to this legal commitment.

The Planning and Sustainability Commission and BPS have put increasing density at the forefront of all priorities. This priority has trumped the preservation of Portland's historic character, traditional neighborhoods, and cultural richness -- but un-necessarily so. The fine print of the Comp Plan admits that the Buildable Lands Inventory shows that current zoning designations provide for substantially more residential unit capacity than is called for between now and 2035. Moreover, the vast expanses of Portland that are currently zoned for R10 and R20 densities -- suburban or even rural density levels which have no place in a city aspiring to ever greater population density – encompassing at least 12 square miles of land within the city limits -- seem to have escaped the planners entirely.

The Comp Plan’s lack of attention to these issues is not due to a failure of the community to speak up. Neighborhood associations, and citizens’ groups, not to mention countless individuals via the Map App, have repeatedly raised these issues over the last several years. Nearly all such appeals have been ignored.

Our goal is to present specific requests to modify the Comp Plan to better protect our precious historic resources and the vital cultural and historic fabric of our traditional neighborhoods. We are asking the Council to take our concerns seriously and act accordingly by setting aside resources and time in the “fine tuning” stage of the Comp Plan to address the identified gaps in protection of historic resources in the current Comp Plan proposals.