Erickson-Fritz Apartments, award-winning historic affordable housing (LRS Architects)
BY BRIAN LIBBY
On March 9, Portland's City Council approved Ordinance #187616, which authorizes a more limited review of projects with an affordable housing component by the Design Commission and the Historic Landmarks Commission, through a Type IIx procedure, rather than a Type III procedure.
The new change allows affordable housing projects with city funding "to be approved through a modified process where they come before the Design Commission for a Design Advice Request and get feedback," explained Design Commission chair David Wark in an interview this week. "After the DAR, assuming it's following the design guidelines (some have had to start over but that’s rare), instead of going through a Type III process with the Design Commission it would go through a Type IIx process and be approved by City staff."
In other words, although affordable projects with city funding will still have to appear before the Design Commission once, to get design advice, the commission will have less power to enforce design improvements on these projects.
Wark explained that the idea switching from a Type IIx versus a Type III review process for affordable housing projects was "brought up by the Design Commission in our retreat last year. One of the questions we asked ourselves at the retreat was, ‘How can we help streamline the design review process for affordable housing without compromising the quality of new buildings?’ This was one of those ideas. But it hadn’t been vetted. We talked about this idea in a subsequent meeting with Mayor Hales and Commissioner Saltzman. They were pleased that we had been discussing many ways to help applicants get through the Design Review process in a more efficient manner. But like a lot of good initial ideas, ideas that appear viable, they get latched on to and implemented quickly rather than allowing them to grow into themselves and providing time to address potential issues or questionable outcomes."
Although City Council voted 5-0 in favor of the change, which comes as the city is amidst a state of emergency related to homeless and affordable housing, the move was not without opposition, most notably from Restore Oregon, which objects to the impact this move may have on historic preservation.
David Wark (Hennebery Eddy Architects)
"We are concerned that the proposed downgrading of design review for historic properties will have significant negative consequences, while having a negligible effect on bringing new housing to market faster," Restore Oregon executive director Peggy Moretti said in her City Council testimony before the vote. "What is approved during our housing emergency will outlive all of us. It will stand in our community for decades. The purpose of a Type III review is to ensure that what is developed respects and protects our historic buildings, is compatible with the neighborhood, and upholds standards of quality in its design and construction. Your proposal says it does not exempt compliance with historic standards or district guidelines. But an over-taxed BDS staff that is not trained in historic review, coupled with huge bureaucratic pressure to move projects forward fast, makes the likelihood of a quality Type II design review that pushes back when necessary seem slim."
"But more importantly," Moretti went on, "This proposal to short-circuit a thoughtful and transparent public review will only trim a whopping 9 or 10 days from the process. By the city’s own analysis, a Type III review takes 51 to 90 days; and a Type II takes 42 to 80 days. This will do nothing to expedite the process in a meaningful way, but could leave the city with some very incompatible new development or mangled historic buildings that will stand for 50 years or more!"
Wark agreed that the right to send bad projects back to the drawing board was a particular concern under the new plan.
"We’ve had a couple of cases where the first DAR was not in alignment with the design guidelines," he said. "For example, in my State of the Design Commission presentation to City Council last year, I presented the West Burnside Fred Meyer, which needed a second DAR to get back on track. The result of that process is a highly successful project. What happens with that circumstance in this modified Design Review process? Who makes that decision? Is it staff, city management, the applicant, the Design Commission? What if the applicant has a schedule that hasn't allowed for a second DAR? That was one concern. A second concern is city staff. Staff is already under enormous pressure. With the city’s financial involvement in a particular project, does that pressure increase? We were told no, that staff would still be obligated to make good decisions. I know the Historic Landmarks Commission was also concerned about staff being pressed for time. I won’t speak for them, but HLC did voice a concern about historic districts, and I agree with this: that historic districts are more sensitive to the negative impacts of an unresponsive building than other parts of the city. The impacts that an unsuccessful project within a historic district are amplified. And the Design Commission supports that concern."
Both Wark and Moretti believe that there are other ways to reduce the impact on affordable projects, particularly in lowering fees.
"The Design Commission is only one part of a large and complex development approval process. What are additional ways in which the City can promote and otherwise support affordable housing? Can the application process for city funding be simplified and streamlined to attract more developers? Can System Development Charges, which are a major expense for every project, be reduced? Maybe there’s a graduated SDC rate applied to affordable housing projects. You could make those fees more in lock step with the city's goals. That would save money. And is there a way to expedite permits for construction? That would save time."
I also asked Wark about the charge made even at times in the architecture community that the Design Commission has over time broadened its purview beyond the original one to look at a building at the street and pedestrian level.
"I’ve been on the Design Commission for nine years and it’s been pretty consistent in the breadth and scope of what we’ve reviewed, as it relates to urban design – from landscaping to the overall composition of buildings to new district master plans," Wark added. "A building has to meet all of the guidelines, not just some of them, hence the comprehensive review. While the current Design Commission didn't write the guidelines, we feel some guidelines need to be simplified, clarified, or edited out entirely. It would help everyone if we were dealing with fewer guidelines. But I don’t know if that would reduce the scope of the guidelines, or whether it should. I’m not sure what the scope of Design Commission review was in the '80s, or in the '90s but, I’d imagine over the decades it has evolved. Given the architectural precedents when commission started, I'd guess their concerns focused on the pedestrian realm in the South Auditorium district, PSU, and in the West End, where a lot of those buildings were anti-urban. So focusing on the pedestrian realm would have made sense because that’s where the City needed immediate help. But I think it has evolved over time."
"I would agree that we’re comprehensive in our review of design proposals, because that’s what the guidelines are asking for," Wark added. "Possibly the most subjective guideline is design for coherency. That is where a commissioners look at the overall concept and composition. Does the design proposal clearly communicate an idea that is knitted together in a successful way? Is there an outlier that’s inconsistent with the concept? And then there are guidelines related to more quantifiable details such as the percentage of glass: there’s a prescriptive amount of glass as it relates to the overall wall area at the ground floor. But we’re flexible with many of the guidelines as the realities of a particular site can warrant modifications. Some are just automatic, like the dimension for bicycle parking is outdated. It needs to be updated as well as many others. And the sooner we update all of these, the less work, time, and expense everyone has to put in."
Meanwhile, it's understandable that City Council would want to take some kind of action to address and enable expedited affordable housing. Something has to be done, and councilors are never going to find a perfect solution that everyone signs off on. Sometimes process in Portland can be lengthy, and costly. And it's laudable that Council has sought steps to address the backlog that's also plaguing the Design Commission, given how much development there is today in the central city and how all of the commissioners are volunteers, taking time out from their full-time jobs. Imagine if Charlie Hales or Dan Saltzman, for example, had to each have an additional job besides what they do for the City of Portland, something that's always been the case for Wark and his fellow Design Commission members.
Even so, we must make sure that the current uproar over affordable housing does not cause Portland to compromise its values. As Moretti noted, the change approved by City Council last week will only marginally streamline the process, yet it could enable bad architecture that stands for a half-century. Portland's success as a thriving metropolis that attracts leaders from all over the world to see how it's done is predicated not just on the kind of equity that drives us to want to house the homeless and lower-income residents, but also on the matrix of urban planning and architectural standards we have established over the past 40 years or more. If City Council is serious about streamlining the regulatory process for central-city buildings, for the sake of affordable housing or in general, it will make a series of moves such as reducing fees, and it will view this Design Review change as a temporary solution at best. Sure, let's give this a try, but as an experiment, not a bona fide solution.
"One can conclude that the pressure to address affordable housing – to do SOMETHING, even if the impact will be negligible – is trumping everything else," Moretti said by email. "Neighborhoods will need to pay close attention."
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"yet it could enable bad architecture that stands for a half-century",,,50 years? Is that all we're building? Looking at our recent additions to the built environment it appears to be the case. Enduring? Sustainable? Don't be naive. We're building on the cheap for the quick buck. but sure let's commence with the formalities that allow us to believe we're standing firm on strict "Portland" design guidelines. Portland fancies itself the bell of the ball. In truth it's the less fortunate cousin who is flushed with unexpected attention given its richer, prettier siblings have their hands full and are willingly passing offers...for now. Portlanders ought to stop pretending and start preserving. We've heard enough talk about what is "Portland". It's high time we had some teeth in that big mouth of ours...
Posted by: David Dysert | March 18, 2016 at 10:46 PM