Agenda Item - 2022-05-17 - Number 6.1 - Written Comment - Samuel Goldberg 1000 HOUSING R ile
friends �. HOUSING
ofGregm CO OREGON UNCIL Housing Land Advocates
May 17, 2022
Lake Oswego City Council
380 A Avenue
Lake Oswego, OR 97034
RE: Code amendments to comply with the minimum compliance provisions of Division 46
by allowing middle housing in all areas where detached single-family dwellings are allowed.
(LU 22-0007)
Dear Mayor and Councilors:
This letter is submitted jointly by Housing Land Advocates (HLA), the Fair Housing Council of
Oregon (FHCO) and 1000 Friends of Oregon (1000 Friends). HLA, FHCO, and 1000 Friends
are non-profit organizations that advocate for land use policies and practices that ensure an
adequate and appropriate supply of affordable housing for all Oregonians.
HB 2001 IMPLMENTATION
Today, we write in support of the Lake Oswego adopting code amendments that implement HB
2001. We ask for a few amendments to improve the prospects for increasing access to more
affordable housing types in Lake Oswego.
Please consider supporting more housing design options by including the possibility for builders
to create detached homes in -plex developments. Giving more flexibility by allowing detached
design options for duplexes, triplexes, and quadplexes will help the City achieve its housing
goals by increasing the number or potential lots where a detached design will create more
workable options for home builders. At the same time,the smaller building envelope of detached
structures could alleviate some concerns about buildings that are larger than their surrounding
neighbors. With detached units as an option, developers can also build around existing
homes on a lot to avoid a costly and unnecessary teardown—preserving naturally
occurring affordable housing.
1221 SW Yamhill Street, Portland, Oregon 97205
1000 HOUSING R ile
friends �. HOUSING
of OregonCOUNCIL OF OREGON Housing Land Advocates
Each parking space required for a development adds between $5,000 and $10,000 to the cost of
homes. Reducing minimum parking standards goes a long way in reducing barriers and the cost
of middle housing development. Of course, many developers choose to create off-street parking
to accommodate market forces—many people expect off-street parking at their home.
However, more flexibility in your code will create housing opportunities for people in your
community who do not have a personal vehicle or have readily available on-street parking in
their neighborhood. We encourage you to follow the lead of other cities like Bend and
Milwaukie (Oregon) and eliminate parking requirements for duplexes and triplexes and require 2
total for quadplexes. Alternatively,you can count on-street parking on a lot's street frontage as a
credit towards parking requirements. It is often the case that a developer would need to eliminate
on-street parking to create access (driveway) for off-street parking spots.
A final amendment to consider in your deliberations are density bonuses (e.g. 5 units
being allowed in a site that meets the siting requirements of a fourplex, or allowing 4 units on a
site that meets the siting requirements of a triplex) for developers that are willing to guarantee
that one unit remain affordable (to, for example, people making 80%AMI), for a set period by
deed restriction. Density bonuses should also be considered for incentivizing units that are
accessible to people with disabilities and tree preservation.
GOAL 10 FINDINGS
As you know, all amendments to the City's Comprehensive Plan and Zoning map must comply
with the Statewide Planning Goals. ORS 197.175(2)(a). When a decision is made affecting the
residential land supply, the City must refer to its Housing Needs Analysis (HNA) and Buildable
Land Inventory (BLI) in order to show that an adequate number of needed housing units (both
housing type and affordability level) will be supported by the residential land supply after
enactment of the proposed change. Goal 10 findings are also required for code changes affecting
residential development feasibility, such as parking standards and setbacks.
We thank the planning staff for responding to our initial concerns regarding a lack of required
Goal 10 findings by including a detailed assessment of existing housing needs. Further, the
1221 SW Yamhill Street, Portland, Oregon 97205
1000 FAIR
HOUSING
friend,'
COUNCIL
OFOREGON Housing Land Advocates
findings provide a frank and transparent look at how units projected in the 2013 HNA have not
materialized, which makes a strong argument for why the middle housing code changes are
necessary. We also appreciate the staff's inclusion of an estimate of the increase in housing
capacity which will result from these changes. Fully analyzing the impact of these changes
allows decisionmakers and the public to determine the best approach to meeting the City's
housing needs.
Thank you for your consideration of our comments.
Sincerely,
f e
40- go atuttea,
Allan Lazo Alexis Biddle
Executive Director Great Communities Program Director and Staff Attorney
Fair Housing Council of Oregon 1000 Friends of Oregon
Cc: Kevin Young, DLCD
1221 SW Yamhill Street, Portland, Oregon 97205