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Final Draft Land Use Code 7/24/20

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Illustrations
Is there a minimum SF requirement for ADUs? Have seen 400 SF in the code before - which would make most currently conforming garages (at least in the R-3 Zone with an 8 ft setback for 1-1/2 Story Structures) an unviable option to turn the top floor into an ADU, as the setback increases for a 2-story, which would be required to meet the minimum square footage to be a livable space/be classified as an ADU. Would love to see more affordable rental options in Portland but if the common 2-car garage size is not an easy option to convert to a 2-story in the setbacks this seems like it is limiting options for housing density where deemed appropriate/acceptable due to affordability and feasibility. Especially in largely Single-Family zones where options for density & units for the "missing middle" renters to move to are few and far between.
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Content
Please consider a 5ft. min rear setback forALL Accessory structures including detached ADU's. 20' is far too restrictive for most lots in the R-5 zone and would inhibit a layout which seeks to recess garage doors and accessory structures beyond principal structure front facades. The 20 foot rear setback space in most instances would be much better utilized as living space. Additionally, many existing garages and accessory structures currently lies within 20' of rear property boundaries.
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Graphic Design
18' max height for detached ADU's seems too low and inflexible for the variety of ADU's which could be built. I assume this measurement would be taken at the midpoint on gable/sloped roofs? How are dormers (particularly large shed dormers which may be necessary to make a livable unit above a typical garage) handled? I would suggest raising the ADU height limit to match principal building height (35' in the cae of the R-5 standards).
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