Sunday, September 03, 2006

Draft letter to Design Review

August 7, 2006
In response to: LUR Application # 06-118229

(This Letter was written prior to receiving a copy of the Design Review / LUR Application and will be revised to include specific comments or concerns and changes from what we have previously seen for this project that come up after reviewing the application. This letter is intended as a draft for review by the Vernon and Concordia Neighborhood Associations and is not intended for distribution to the City of Portland at this time. All content that may require editing after the Application is received is in italics)

Jean Hester, Senior City Planner
1900 SW First Ave. Suite 5000
Portland, OR. 97201

Dear Jean Hester,

We at the Vernon and Concordia Neighborhood Associations have received a copy of the Design Review Application for the proposed development at NE 20th and Alberta and have several comments and concerns regarding this proposal.
Our neighborhoods have been collaborating the since receiving the Pre-Application Notice and Summary Reports and have been discussing concerns voiced by local residents after a presentation from the architect. The site is a vacant lot with several complaints filed against it. We are delighted to see that the community has become a vibrant place enough to support some of the infill development boom that has reached many of our adjacent communities. However, we were very surprised by the height limits allowed by the zone and the resulting massing taking full advantage of this. Many neighbors have also expressed their concerns regarding existing parking issues and the added demand created by 59 new living units. The overall value of the project and materials selection also has many of us concerned.
Our largest and neighbor’s most voiced concern is regarding the height of the proposed development. The zoning on the site is Ex, with d and h overlays. For this type of mixed-use residential development, a 65’ maximum height is allowed per the zoning code. We feel that the proposed development is taking advantage of this height limit to max-out the buildable area on the site without meeting the regulations set forth in the Zoning Code.
In Zoning Code Section 33.140.030, the characteristics of the Central Employment (Ex) zone are described as: “The intent of the zone is to allow industrial and commercial uses which need a central location…Residential uses are allowed, but are not intended to predominate or set development standards…The development standards are intended to allow new development which is similar in character to existing development.” The proposed development is primarily residential with a few commercial spaces on Alberta. The language of the zoning code suggests that the zone is intended to create centrally located employment opportunities encouraging mixed-use with wider height and FAR allowances. With only three ground floor retail type spaces proposed, this development does not quite meet the standards set forth by the zoning code and does not provide enough of a mixed-use allowing for more jobs at this location.
The final sentence of the aforementioned Zoning Code Section raises even more, varied and somewhat subjective concerns from the neighborhood about the development and height of the proposal. There are no developments along Alberta, or the adjacent communities, that are of similar height or character of the proposed development. The height of the adjacent commercial spaces and homes range from 15’-30’. There is a couple of existing and recently developed four story buildings within a few blocks. Given the 3:1 FAR, adjustments to the massing of the proposal can achieve a lower height without losing the desired density of the development and getting closer to the existing development character.

The building as proposed does not do enough to break down the height and massing along the adjacent residential edge and does not meet Alberta Street in the same manner as existing developments. There has been a lot of effort made by the architect to respond to the existing residential fabric with porch like elements and pitched roofs along 20th Ave. However, this vocabulary wraps the corner onto Alberta and does not pick up the existing character of buildings on this street. Several of the structures along Alberta are one and two story commercial buildings, with storefront at the ground floor. All of these buildings meet the street with a wall extending the length of the property line, emphasizing the main street nature and commerce of the corridor. Recently constructed buildings to the east have met the property line with similar character quite successfully. The plans and elevations indicate a large hole in the Alberta St. façade, to an internal courtyard. This breaks the line and character of the street without adding much for the community. The scaling and massing effort would better be suited to the North where a 65’ wall is currently only 20’ away from the property line, shadowing existing houses and yards of a much smaller scale.
This community faces several challenges with parking even though Alberta is a transit street. The number of residential units proposed demands on site parking as not to burden the adjacent businesses and residents. (This paragraph to be completed after reviewing the application. If they are providing parking, great, we’ll commend them for their efforts; if not we’ll explain our current hardships and demand that they provide parking for a minimum number of residents)
The materials proposed and sustainable efforts to date are vague. As a community, we support sustainable efforts and appreciate the development is taking this direction. The existing buildings on the street are varied in their materials. Some of the newer buildings on Alberta have chosen similar palettes to one another. We would like to emphasize the need to set forth new standards of quality with each development and encourage choices that are in harmony with the existing contextual materials…(More space for comments and concerns regarding the materials proposed and if they even mention anything about their sustainable choices. There is an awfully large amount of impervious courtyard and roof area proposed on a site that is currently doing a good job of managing it’s own storm water. I am interested to see how they are resolving this. Storm water tanks, low greenroof-Could be nice on the residential edge, etc.)
In conclusion, we have several concerns about the resulting impact of this proposed development on our community. Our concerns regarding the overall height, opportunities and character of the proposal are not in response or disproval of infill development along Alberta, but are rooted in the intent of the Ex zoning designation for this site, and are validated in the code description for the Central Employment classification. Difficulties with the massing, failing efforts to step down enough to the adjacent residential properties and how the building lacks to meet Alberta with the same dignity the existing building on the street, raises further concerns that the development is maxing out it’s buildable envelope without questioning whether it really works within the context and character of the neighborhood.

Sincerely,


Vernon and Concordia Neighborhood Associations


CC: Justin Fallon Dollard, planner



JD

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