New Zoning for the Former Reform School and Prison Annex Site

On Tuesday the Planning Commission will consider a proposal to rezone the site of the former Reform School and then Prison Annex. The matter's been postponed at least twice since the original Hearing date in November. The developer representative wanted more time as the Staff proposed conditions of approval seemed more than the developer team was prepared for. Staff have also revised the proposed conditions, and it seems very likely the Hearing will be continued and for more discussion and analysis, as the project is not simple and land conditions are complicated. The project also might need some additional refinement.

New zoning proposed

Development concept

• See from November, "Rezoning the Former Reform School and Prison Annex Area" with an overview focused on the history of the site

Since then, even with two supplemental Staff Reports (original in November, then January and February), the project remains a little slippery.

MU-I or MU-III? Not consistent with map

For one, the map calls out an area for MU-III zoning, and the text of the first Staff Report says MU-I.

MU-III is more commercially oriented than MU-I, and that's a significant difference.

House lots and apartment block deployment
Phases C, D, and E

At least some of the project concept looks like traditional single standalone housing and an apartment complex.

Phasing plan

But that diagram doesn't match up very well with a different map on the phasing plan.

Herren Cemetery (2021 appraisal)

Those phasing maps also don't show any cutouts for known cemeteries, discussed in a 2021 appraisal from before sale. That is a little weird, and does not inspire confidence that the project will be very sensitive to existing conditions. Just as a matter of PR, why wouldn't you call out the cemeteries and say you'll have a special park area for them?

Since the City says  "There are eight known archaeological sites and 20 archaeological isolates within the proposed development area," they add as a Condition of Approval:

Prior to ground disturbing activity, the applicant shall provide evidence of completed consultation with the Oregon SHPO and the Tribes and demonstrated compliance with SRC 230.105, Preservation of Archaeological Resources.

From the latest Staff Report

Indeed, an even greater existing condition is the creek and flood plain around it, and much of the delay seems to have arisen over negotiations about how to deal with it. The Developer seems to want very minimal compliance with riparian and flood zones.

A 120-foot buffer too small even?

Staff Revised a condition in response to Developer criticism.

The earlier one:

Condition 4: Prior to issuance of any development permits, the applicant shall establish a Riparian Corridor Buffer along Mill Creek based on a site-specific assessment using the Oregon Department of State Land’s (DSL) Urban Riparian Inventory and Assessment Guide methodology. This study shall be conducted by a qualified wetland/biological consultant. The width of the buffer should be no less than 120-feet from top of bank or a distance established by a qualified biological consultant utilizing the Urban Riparian Inventory and Assessment Guide (DSL 1998), whichever is greater.

The revised one:

Conditon 4: Prior to issuance of any development permits, the applicant shall establish and identify a Riparian Corridor along Mill Creek of 120-feet from the top of bank within the IG and IC zones and 50-feet from the top of bank for the remainder of the property.

This seems likely to be debated and contested further.

The City itself also is incoherent on bike lanes. There's a real mismatch between "all ages and abilities" and the actual road conditions and proposed standard bike lanes.

Staff Report on bikes

Applicant Statement on bikes

Nearby roads

Kuebler is also deeply problematic for walking and biking.

High crash rate locations

Just at a high level, this project proposal does not seem deeply considered enough. Maybe there's not any leverage in actual approval criteria, but as a general matter, this one could be better and more thoughtful.

The Planning Commission meets Tuesday the 27th at 5:30pm.