Portland Resilience Zoning - Proposed Approach

Thank you for clearly articulating the proposal, and for sharing the opportunity to provide feedback.

I would discourage an "or" here. Juvenile or small trees do not significantly allay heat island effects. This is an unbalanced alternative and allows for a detriment long term (a heat amplifying sidewalk or hard surface that lasts decades) with little benefit from a small "offset" (a juvenile tree that does not address the added heat from the non compliant surface, and has no guarantee to survive without routine care). By the time a small tree has grown large enough to shade 750sf of asphalt (if it survives long enough), that asphalt will have amplified urban heat for dozens of years.

Ensure adequate efforts not just to plant the trees, but to maintain and care for them as often juvenile trees need greater attention than mature trees so as to survive longer than a year or two. An example of a community supported tree care program from MA: link

Where structures abut water frontage or are at risk of increased storm water intrusion inclusion of soft infrastructure (also called natural infrastructure) for minimizing risk from sea level rise/store surge should be required aspect of planning, construction or renovation. Amending hard infrastructure on a waterfront (ie concrete, metals, non porous materials) is ineffective in the long term and unwise for a coastal community like Portland.

It makes total sense to protect new development from ground level flooding. What doesn’t make sense is giving developers extra height for doing this basic sensible work. And you certainly can’t call height bonuses “sustainability”.

Is there a way to prevent these from being clustered around the outside edge of a very large continuous parking surface?

What qualifies as "substantial renovation"? Would the SF amount be per building or cumulative on a multi-building site?

I support adding more trees to parking lots, but these standards need more rigor and specifics. We also need to make sure we are cutting and eliminating any parking minimums that remain in the code. Other issues: Small trees won't cut the heat island effect. Research shows they need to be bigger shade trees. The code needs to include specifics about the size of tree wells, planters and island and the type of soil they must be filled with. Specifying loam and compost is crucial to mesh with the city's climate-positive organic land care ordinance. If a parking lots is permitted, we need to REQUIRE canopies and other reflective covers (these can even be made of living plants) and cooler pavement surfaces. We also need to consider the climate impacts and VOCs off-gassed by asphalt parking lots when they are "sealed." This makes the parking lots darker and therefore they absorb more heat. The sealants also create stormwater pollution. Consider requiring new developments with surface parking to have a green roof on the building, as more greenery near a parking lot helps mitigate its temperature extremes. The code also needs to plan for and encourage/incentivize the creation of more pocket parks and tiny forests to offset the urban heat island effect. In addition, the city needs to plan for more splash pads, pools and cooling spaces. All news roofs should be light colored/reflective. I've found that some in the building trades recommend against them because they don't like the "look." They need to be required. We also need to be rigorous about providing a tree canopy to cool our streets and simultaneously slow stormwater runoff. link link link

It's unfortunate the Baxter Boulevard project has wrapped up because it was a generational opportunity to convert a large portion of it to greenspace to help buffer against sea level rise within back cove. The city was without that road for approximately two years without dramatic impacts. The city should consider converting that road to a linear park.

I continue to advocate that the city should come up with a way to redirect tree fee in lieu to the neighborhood where the project occurs. It seems we can create endless earmarked accounts for CIP projects, so why can't we at least create "district" accounts for tree funds to be directed to (follow the precinct maps for example).

Heights should be increased commensurate with the loss of space at grade to DFE, perhaps even another entire story allowed in these areas for buildings in compliance with this proposed requirements.

I do not see the wastewater treatment plant listed as a critical structure needing protection.