My Comments on Metro Community Investment Strategy.

Metro has published their Community Investment Strategy for public comments until October 1st. 

Comments should be sent to arrive NLT October 1 ( I recommend you send EARLIER) by e-mail to 2040@oregonmetro.gov, or snail mail to:

Metro

Community Investment Strategy comments

600 NE Grand Ave.

Portland, OR 97232

The summary of the Investment Strategy and COO recommendations are in a 24 page document HERE.

The details are found in supporting documents HERE. (One of those documents,  Draft Capacity Ordinance and Exhibits includes proposed changes in the Framework plan and the Functional plan). 

While comments on the COO recommendations and other sections of the strategy may be useful, my view is that comments on the Framework and Functional plan language are the most critical, and especially the draft Functional Plan language.  Here's why:

• The only portion of the strategy that can be enforced at the LOCAL level are requirements that are included in the Functional Plan. 
• Changes in the Framework Plan may set Metro policy but they are NOT enforceable at the local jurisdictional level. 

This distinction is important because the only NEW affordable housing requirement of note, tracking the percentage of renter households spending 50% or more of their income for housing and transportation, is ONLY found in the Framework Plan, and is thus a region wide goal, and NOT a local goal.  

The draft plan has NO new affordable requirement that I can see for local government in the Metro functional plan, and changes in compliance reporting in Title 8 of the Functional Plan ALSO give the Metro Chief Operating Officer the authority to waive ANY functional plan reporting requirement, including local progress toward voluntary affordable housing targets, and reporting on changes in affordable housing supply. 

All of my comments can be found HERE; my recommendations for changes in the Metro draft amendments to the Framework and Functional plan are bold faced in "Corrective Actions" 9 and 10.
(NOTE: My comments are in MS Word 2007-2010 format. Do NOT try to open the file in your browser. To OPEN the file right click the link above and SAVE /download the file to your PC; once it has downloaded THEN double click the file and it will open). 

In particular I recommend that a ONE word change be made to Title 6 Functional plan language related to planning in "Centers, Corridors, Station Communities, and Main Streets ".  The current draft only "recommends" that "needed housing" (as defined by ORS) be included by local government in their planning; and I suggest that "recommend" be changed to "require" that local government consider ORS defined "needed housing" in their planning for Centers/Corridors. 

Even without a specific set aside existing Metro Functional plan language [Title 7 (307.740 B.3.] already requires reporting on changes in affordable housing in Centers/Corridors. However, Metro has waived existing required local semi annual reporting on changes in affordable housing supply due in both 2007 and 2009, but if that data were available it likely would should little affordable housing activity and/or a lack of equitable distribution. 

Metro projects some $3.8 billion of residential incentives will be made in Centers and urban renewal areas, so the failure to require that "needed housing"  be included in local planning for Centers, etc would allow spending of those incentives exclusively for multifamily home ownership units and high end rental units.

Originally created and posted on the Oregon Housing Blog.