3LU 07-166143 AS AD

PC # 07-122610

 

Supplemental Comments of Lynne Coward

 

January 4, 2008

 

 

As an owner/ resident of lot #1 in the subdivision approved by the Hearings Officer in 1996, and, as the Land Use Chair of the Sullivan’s Gulch Neighborhood Association from 2000 through 2006, I testified at the December 19th hearing.

 

I wish to submit the following comments in opposition to the proposal:

 

Design as a Critical Factor

 

Throughout the Hearings Officer’s Report and Decision (96-01106 SU AD), the word DESIGN is mentioned. 

 

Pages 7 and 8, Lots and Parcels

 

The report mentions the unusual lot patterns and the substandard size of lot 8.  To quote selected passages:  (with emphasis added in bold)

 

“In this case, the less than regular lot pattern and sizes is a positive, rather than negative, feature because they are obviously a result of careful building designs that respond very specifically to the existing neighborhood character…”

 

“The size, width, shape and orientation of the proposed lots are appropriate for the location in large part because of the design of the proposed buildings…A different design could result in a much less attractive and safe pedestrian environment.  This proposal is acceptable in large part because of the proposed building footprints and designs...”

 

Page 12  Lot 8.  Last paragraph in  A.2

 

“The proposed lot size adjustments are reasonable if the lot is developed as shown in the drawings submitted.  Many features of the façade and the building plan allow the lot to be developed in a way that is in keeping with the zone.  Therefore, this criterion can be met only if the lot is developed substantially as proposed.”

 

 

Comment: By asking to replace A.2 with their own plans, the applicants are asking to eliminate design—the very element that was critical to the subdivision’s approval. 

 

The applicant’s, Ankrom Moisan Associated Architects (AMAA), proposed plans vary significantly from those presented in ’96 and from subsequently permitted plans.

 

The windows in the AMAA plan are predominantly square—rather than the elongated rectilinear windows of the original.  The roofline is flat relative to those of the existing row houses.

 

Like the Holladay Park Plaza building across the street, the facades are institutional and relatively uniform—giving little identify to individual units.  The original plans had numerous small balcony windows, doors and direct connection to the sidewalk on NE 16th Ave.  In other words, the original designs addressed the pedestrian quality of an urban neighborhood.  The proposed building does not reflect its other neighbors.  Further, the AMAA plan turns its back on the rest of the block---eliminates the balconies overlooking the alleyway---the social space of the block.

 

In their application (pages 5 and 6) AMAA supplies two images to support their contention that “the proposed building form is similar to neighboring structures”.

 

Image 1 is of the row houses on NE 16th Ave.  I can see no similarity of design with its near neighbor for the reasons stated above and additionally the specific materials used.

 

Image 2. The 1600 NE Broadway condos are in a CS zone bordered on front and back by major transportation arterials.  It is in such a location that a building of the scale AMAA is proposing belongs.

 

 

Proportion

 

Comment:  Proportion is a major component of compatibility.  Compatibility is achieved by considering the context and creating a respectful relationship to the other elements.  The proposed condo building consumes both visual space, and with its parent building across Clackamas, much of the sunlight afforded block 177.

 

 

The Sullivan’s Gulch Neighborhood Association and Block 177 Support Density and have worked with developers and the City to fit units into our neighborhood.

 

Sullivan’s Gulch NA in January of ’02 actively supported the substantial (100%) density increase that allowed the 1620 NE Broadway 88-unit condo development (LUR 0200020 AD).  The NA was extensively involved in the rezoning of the former Albina Fuel Co. property (LU 00-00672 CP ZC) that will result in 219 housing units; the NA supported a PUD with 14 units set in among single-family homes (LU 02-122705 PU).

 

Residents of Block 177 met with Alan Kravitz, the former owner of lot #8 and gave their approval to his plan for a 65’ 18-unit condo building.  (The number of units apparently changed during the permitting process.)  See attached minutes and communication to Mr. Eric Engstrom.  (Attachment 1)

 

Pacific Retirement Services (PRS) presented their already-developed plans to the neighborhood and block neighbors in January of last year.  While initially delighted with Holladay Park Plaza as a neighbor, block residents felt overwhelmed by the scale of the proposed project.  They engaged Michael Harrison to give an initial review of the ’96 decision.  Based on his comments (some of which will be included in this submittal), the residents who had seen the original drawings , but who were unaware of the ’96 decision-- decided to use that decision as their going –in position.

 

Unfortunately the conversation between the block and PRS has not progressed  from the initial positions.  Based on their acceptance of the ’04 the Aiyana (Kravitz) plan, it is my belief that the block would have readily accepted a proposal for a similar project, in effect, what PRS purchased.  PRS, beyond expanding the alleyway by 2 feet, has not offered to reduce the scale of their project.

 

 

General Statement: 

 

At the heart of this decision is whether to nullify the Hearing Officer’s 1996 decision.  The applicant is asking to use the full rights of RH zoning coupled with a transfer of development onto a lot whose very status was afforded by its inclusion within a comprehensive plan for the entire block.

 

At stake here is the public’s role in land use decisions.  {Oregon’s Statewide Planning Goals and Guidelines (OAR 660-015-0000(1) Goal 1}.

 

The recognized neighborhood associations of Sullivan’s Gulch and Irvington worked effectively with the developers, their architect, and the City to arrive at a plan that was not only acceptable, but expemplary of Portland planning principles and the goal for increased density on infill property.  Residents of block 177 bought into these goals and have invested themselves heavily into their units—fully accepting the reality of a 65’ compatible condo building on lot 8.

 

Now, an out-of-city development company is asking that Portland ignore the neighborhood process that resulted in the ’96 decision, and, instead, grant them development rights without regard to the duly developed and approved plan for the block.

 

Holliday Park Plaza through its management, Pacific Retirement Services, owns several other parcels just east of NE 17th Ave.  I believe it would be to the benefit of surrounding residents who have reinvested in their home to know the extent of PRS’s plans for expansion and to work with PRS to reach a mutually agreeable plan.   A clear goal of the Sullivan’s Gulch Neighborhood Action Plan was to buffer the core of the neighborhood, located on narrow side streets, from intense development that would preclude livability.

 

I am asking that the current application be denied and that the ’96 decision be reaffirmed by requiring development to conform to that decision.