High Quality
Open the downloaded document, and select print from the file menu (PDF reader required).
F
RIENDS OF
U
RBAN
R
ENEWAL
110
SE
C
ARUTHERS
S
TREET
P
ORTLAND
,
O
REGON
97214
June 17, 2008Hon. Tom Potter, Mayor and Portland City CouncilSuite 3401221 SW Fourth AvenuePortland, OR 97204-1995
Re: Proposed Amendments to River District Urban Renewal PlanLetter of Opposition
Dear Mayor Potter and Members of the Council:The undersigned Friends of Urban Renewal and concerned citizens of the City of Portland and leaders in the area of Urban Renewal law and policy in Oregon, as a groupand individually, oppose the City's proposed amendments of the River District UrbanRenewal Plan. Attached to this letter are copies of our prior letters to the PortlandDevelopment Commission, a Memorandum from City Attorney Linda Meng, a letter from the Central Eastside Industrial Council, a letter from Portland Business Alliance, anarticle from the Portland Tribune, two editorials from the Oregonian and one from thePortland Tribune. Please place this letter with its attachments in the record of materialsfor this proceeding.Briefly, there are several legal and factual problems with the two substantiveamendments before City Council. With respect to the amendment which expands theRiver District boundaries by adding an additional 41.98 acres and increases maximumindebtedness by $325 million ("Expansion Amendment"), the plan and report lack adequate substantiation and documentation in many instances as required under ORS457.085. With respect to the amendment which creates a noncontiguous “satellite,” or “island” district encompassing 8.53 acres of David Douglas School District property andincreases the maximum indebtedness by $19 million to fund the capital construction of anelementary school ("Satellite District Amendment"), the plan and report lack adequatesubstantiation and documentation as required under ORS 457.085. In addition, theSatellite District Amendment has insurmountable legal issues associated with its creation,including the lack of legal authority to create a non-contiguous urban renewal districtunder existing Oregon law, the inability to substantiate a finding of blight, lack of authority to build a school under ORS Chapter 457 and City Charter prohibitions againstfunding core school functions.
Mayor Potter and City CouncilPage 2 of 7
1.
The Expansion Amendment
The Expansion Amendment suffers from lack of adequate documentation under ORS457.085 and lack of specificity in order to enable City Council to make its requisitefindings under ORS 457.095. Specifically, the following examples are identified:
•
There is no description of existing conditions of blight in the existing River DistrictUrban Renewal Area and no basis for finding that the urban renewal area is blighted,necessary for a substantial amendment of an urban renewal plan that has beenextraordinarily successful.
•
The amendments state as a given Council policy on a TIF Set Aside which has never been legally incorporated into the Plan by amendment.
•
The amendment’s housing policies are speculative, based on a process for developinga housing implementation strategy that is still underway.
•
The amendment states that “additional streetcar lines may be developed in the Area,including the Eastside Streetcar line and Burnside Couch Streetcar line” but notransportation inadequacies in these are described in the report as a condition of blight.
•
The amendment calls for redevelopment of 3
rd
and Alder and 10th and YamhillGarages but no parking deficiency is cited as a condition of blight within the urbanrenewal area. The condition of the buildings does not render them unsafe or unfit for occupancy.
•
The Access Center is not described in any detail but is estimated to cost $17 million.The facility serves social service needs but lack of social services is not cited as acondition of blight in the urban renewal area.
•
The Fairfield hotel provides low income housing, but lack of low income housing isnot cited as a condition of blight in the urban renewal area.
•
The Lincoln Building rehab is not cited as a project but is cited as the reason for selection of the area in the report.
•
The Post Office project is estimated to cost $27 million, but the project description provides little indication of the nature of the anticipated redevelopment.
•
The amendments state in connection with the Major Retail Project that “additional projects in support of the downtown retail core may be implemented.” This is aninadequate description of a potentially high cost project.
Mayor Potter and City CouncilPage 3 of 7
•
For the $35 million Multnomah County expenditure which includes public buildingsthere is no explanation of how the building serves or benefits the urban renewal planas required under 457.085(2)(j)
•
The economic development project is only described in terms of a strategy to bedeveloped in the future yet has an estimated cost of $54,025,702.The report on the amendments does not provide an adequate basis to support thenecessary findings of ORS 4578.095:
•
The analysis of fiscal impacts of the proposed Old Town/China Town expansion area(and other expansion areas as well) summarily concludes that because “All of the property being taken into the RD is property which came from another urban renewalarea,” “The impact on municipal services does not increase by moving a propertyfrom one area to another” even when the movement provides project funding thatwould not otherwise be available.
•
The report does not cite or provide analysis of lack of low income housing as acondition of blight in Old Town/China Town. Such a lack is not included in thestatutory definition of blight.
•
The report does not cite lack of access to social services as a condition of blight inOld Town/China Town. Such a lack is not included in the statutory definition of blight.
•
The report for Old Town/China Town states that “the combination of housing,transportation, economic development and commercial development assistance in theOld Town/Chinatown Expansion Area will address a
growing
lack of proper utilization that is resulting in stagnant and unproductive condition of land.” There isno evidence to support a “growing lack of proper utilization.”
•
The evidence of blight for the Lincoln Building expansion area is inadequate. Itsinability to meet recently adopted seismic standards does not render it unsafe or unfitfor occupancy. It is cited as having a healthy improvement to land ratio and rated in“A” condition.
•
The evidence of blight for the East Retail Core expansion area is inadequate. Thisarea includes a portion of the Pioneer Place project developed in the 1990’s under theDowntown Waterfront Urban Renewal Plan. Seven of eight buildings in the area arerated in “A”condition.
•
The expected impact of the McCoy Building expansion area states that the purpose of the project is to provide funding to Multnomah County.
Add a Comment