The rules Portland uses to determine transportation impacts of new development currently do not take into consideration pedestrian and bicycle trips. That needs to change says Ed Fischer, president of the Homestead Neighborhood Association, who recently called on the Director of the Portland Bureau of Transportation (PBOT) to review best practices for Transportation Impact Studies.
Fischer’s request is part of the Homestead neighborhood’s response to a new five-story, 43-unit apartment building which is currently being constructed on SW Gibbs Street, near the Oregon Health Sciences University (OHSU) on Marquam Hill. As BikePortland has reported, the city will not allow the developer to pour a cement sidewalk on the building’s Gibbs Street frontage.
The construction is well underway, but the developer wants to increase the number of units from 27 to 43. This modification triggered a new round of permitting, including a modified application review by the Hearings Officer (HO). (Presentation of the completed application to a Hearings Officer is the final step in the permitting process for large developments.)
This second HO hearing gave the neighborhood association another opportunity to call-out the limited frontage improvements. In this second review, however, they took the further step of offering pointed criticism of what the city accepts as a Transportation Impact Study.
And the Hearings Officer agreed with them:
Since the law does not require it, the Hearings Officer cannot direct the expenditure of public funds to this project under the facts of this case. In this case, whether to modify the rules to include analysis of pedestrian and bicycle trips and whether to direct PBOT resources to prioritize a fix of the unsafe shoulder is within the sole province of the legislative and executive branch of the City (City Council and the PBOT Director). The Hearing Officer’s non- binding recommendation to PBOT is to use their executive and legislative powers to fully fund the projects identified in the PBOT emails with Mr. Fischer.
In other words, the HO’s hands are tied because he doesn’t have authority to require action from the city. But he thinks the city should do something about the unsafe shoulder new residents will be walking on, and also update city traffic analysis rules which are blind to pedestrians and cyclists.
Portlanders who follow trends in active transportation might be taken aback to see how outdated the city’s administrative rule guiding traffic studies is.
The rule, TRN-10.27 – Traffic Capacity Analysis for Land Use Review Cases, describes minimum levels of service for vehicles at intersections that have either signals or stop signs, but it does not mention anything about people walking or biking.
The purpose of the rule is to determine if the local transportation system is capable of supporting the additional trips generated by new occupancy, but its car-centric bias is glaringly out-of-step with government policies, including city and state decisions in recent years to end parking mandates.
That active transportation omission makes it impossible to analyze transportation impacts in a location like Marquam Hill, where the city began capping and regulating parking twenty years ago. As a consequence of that city policy, OHSU has only enough parking for one in every three employees. This has successfully resulted in many employees and students traveling to the Hill via public transportation, or by biking and walking.
And it has spurred “walk-to-work” development throughout the area, especially on Gibbs Street. But Gibbs does not have continuous sidewalk coverage, and sidewalks are completely missing near the new development.
Nevertheless, PBOT’s Development Review office determined that
… based on the evidence included in the record, the applicant has demonstrated to PBOT’s satisfaction that the transportation system is capable of supporting the proposed use in addition to the existing uses in the area.
This did not sit well with Fischer, himself a retired transportation engineer, who told BikePortland “the city is trying to make walkable neighborhoods.”
To further that goal, he suggested the following five changes to the traffic study administrative rule and the way PBOT reviews traffic studies:
- Require trip generation estimates to include pedestrian and bicycle traffic. (These volumes could affect typical mitigation measures beyond just sidewalks, including crosswalk warrants, signal warrants, bicycle signal warrants, etc.),
- Require PBOT reviewers to visit the proposed site on the ground and to examine, first-hand, facilities and access issues within a reasonable area of interest around the site, looking at likely destinations to and from the proposed development site,
- Require documentation of actual traffic volume and speeds, not make assumptions based on posted speed,
- Require review of recent, planned or proposed system improvements within a reasonable impact area around project site, and
- Require (within the TIS) consideration of the use of System Development Charges to address local needs.
It is difficult to understand why the fate of transportation infrastructure near this economic engine depends on conversations between a PBOT middle-manager and a neighborhood volunteer.
Fischer said that the Homestead Neighborhood Association does not plan to appeal the Hearings Officer decision to city council, but that they are “keeping the momentum up to see if we can get the city to follow through on some of our recommendations.”
“Keeping the momentum up” has involved ongoing conversation with PBOT’s Development Review office about the neighborhood’s new, watered-down goal of prohibiting on-street parking on the road’s shoulder and increasing shoulder width downhill from the new apartments, the direct route to OHSU. (See photo at top.)
Their ultimate goal is a two-block long cement sidewalk, but the city told them that it would come with a price tag of $1.6 million, due to water pipes having to be relocated to avoid being under the sidewalk.
OHSU is the city’s largest employer. In 2021 its researchers brought in over $405 million in federal grants to the Portland area. It is planning a $650 million hospital expansion. Alongside this growth, private developers are filling in Gibbs Street with dense walk-to-work residential projects.
It is difficult to understand why the fate of transportation infrastructure near this economic engine depends on conversations between a PBOT middle-manager and a neighborhood volunteer.
If the city is really committed to its visions of supporting walking, biking and the densification which allows for better public transit, it should follow the Hearings Officer’s recommendation to use its “executive and legislative” powers to build the pedestrian and bicycle infrastructure needed to provide safe passage for OHSU employees, students and neighbors. Infrastructure conversations need to rise a few pay grades.