MPNA LETTER TO THE HEARING OFFICER:
The letter below was reviewed and approved unanimously at the Marshall Park NA meeting on 10-Sep-2009. The letter will be FAX'ed to the Hearing Officer in charge of reviewing Lewis & Clarks' application.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
September 10th, 2009
Mr. Gregory J. Frank
City of Portland, Oregon Hearings Officer
1900 SW 4thAvenue, Room 3100
Portland, Oregon 97201
Re: OPPOSITION to Lewis and Clark College Boundary Expansion
Case File: LU 08-180498 CU MS PC# 07-113603 Lewis & Clark College Master Plan Update
Dear Mr. Frank,
The Marshall Park Neighborhood Association opposes Lewis and Clark College's current request to expand their college boundary across SW Terwilliger and SW Boones Ferry to include properties at the eastern end of SW Maplecrest Dr. We believe that 200 new residents would overwhelm the local transportation system, and that the proposed design and scale of the new development would significantly detract from the residential appearance of this gateway to our neighborhood.
Our specific concerns regarding approval criteria are as follows:
33.815.105 Institutional and Other Uses in R Zones
A. Proportion of Household Living uses. The overall residential appearance and function of the area will not be significantly lessened due to the increased proportion of uses not in the Household Living category in the residential area. Consideration includes the proposal by itself and in combination with other uses in the area not in the Household Living category and is specifically based on:
1. The number, size, and location of other uses not in the Household Living category in the residential area; and
2. The intensity and scale of the proposed use and of existing Household Living uses and other uses.
The number of parking spaces, the institutional size and appearance of a three level parking structure and the location of parking along both sides of SW Maplecrest will significantly lessen the appearance of our neighborhood gateway.
· The eastern end of SW Maplecrest Dr. has been a gateway to Collins View and Marshall Park neighborhoods for decades. The Lewis and Clark boundary expansion proposes a three tier parking structure and surface parking lot at this gateway, replacing the existing single family dwellings on both sides of SW Maplecrest Dr. While the student apartments themselves may be “household living” uses, this is an institutional approach to parking, not a household living approach. Concentrating vehicle storage areas on both sides of the road is of an intensity and scale that does not match the existing homes, and would significantly detract from the appearance and atmosphere of the residential neighborhood.
· Neither Mt. Carmel Church, Riverdale High School, nor St. Mark Presbyterian Church, the three non-residential uses near by, present the intensity of parking along both sides of a local street which Lewis and Clark is proposing for the law and graduate student housing. In fact, the proportion of non-household uses which these institutions make up in the area is currently buffered by the small scale household living dwellings which the proposed boundary expansion would remove from our neighborhood
The scale of the proposed four story apartment buildings would conflict with the current residential appearance.
· There is nothing of this scale in the area.
· Since only a general design has been offered, the four story limit is not binding on Lewis and Clark. The College mentions that their Design Standards' contain a 30 foot limit for buildings within 50 feet of the campus boundary. However most of the proposed law/graduate student housing footprint is 50 feet away from the requested campus boundary. Once the expansion is granted, the College would be able to build to the maximum height of 75 feet.
The proposed boundary expansion's “preliminary design” is out of character and scale for the local neighborhood's residential atmosphere. We believe that Lewis and Clark should look closer to their current main campus for student housing development sites.
33.815.105 Institutional and Other Uses in R Zones
D. Public services.
1. The proposal is supportive of the street designations of the Transportation Element of the Comprehensive Plan;
2. The transportation system is capable of supporting the proposal in addition to the existing uses in the area. Evaluation factors include street capacity, level of service, and other performance measures; access to arterials; connectivity; transit availability; on-street parking impacts; access restrictions; neighborhood impacts; impacts on pedestrian, bicycle, and transit circulation; safety for all modes; and adequate transportation demand management strategies
The evidence that SW Terwilliger and SW Boones Ferry can support traffic generated by the proposal is not convincing.
· The CUMP's relative “new trip generation” data (2-3% evening peak increase) for SW Terwilliger and SW Boones Ferry may indeed support that Lewis and Clark should not bear the responsibility to pay for required intersection improvements, but it does not prove that the intersection can support the increased traffic burden.
· The CUMP has not considered whatsoever the transportation impact of an additional 200 student pedestrians and bicyclists stopping traffic in all directions to cross at SW Terwilliger and SW Boones Ferry. The need for improvements to “pedestrian and bicycle facilities” is noted, but not the effect of traffic stoppages on the peak morning and evening traffic flow.
· While Kittelson & PBOT were doing a site visit of the intersection “several near collisions” were observed.
· In 2007 for a similar size “green” development, the Headwaters (with 156 apartments and 14 town homes), the City installed a traffic signal at the intersection of Barbur Blvd and SW 30th Avenue, to mitigate extra traffic from the new housing. Note that this was felt to be necessary along a straight stretch of Barbur Boulevard with unimpeded sight lines. We feel a well thought out solution is even more necessary at a curved and hazardous section of road such as exists at Terwilliger and Boones Ferry.
There is no evidence that SW Maplecrest Dr., a local service street and city walkway (without sidewalks), is capable of supporting the additional traffic that will be generated by the proposal.
· We agree with the Bureau of Development Services (BDS) statement that “SW Maplecrest Dr will be critical to the proposed new Law School student housing component of the Master Plan Amendment “.
· Kittelson and Associates, in a study done “in support of the Lewis and Clark CUMP” estimated an additional 400 to 700 daily vehicle trips from the new housing (CUMP Exhibit J). We do not believe that this takes into account that while the new residents may walk to classes, there will still be extra traffic from family members and from the resident's own activities (jobs, internships, shopping, recreation) which Lewis and Clark's flexible classroom hours may allow.
· In any case, there is no mention in the Lewis and Clark application about what percentage increase in trips this represents for SW Maplecrest's intersection with SW Terwilliger, for travel westward along SW Maplecrest, or for travel north on Terwilliger. There is a SW Maplecrest traffic count mentioned in Kittelson and Associates “Proposed Scope of Work”, but no results of any such count are described in the CUMP.
· SW Maplecrest Drive is not designed to handle additional traffic. It is directed and restricted by the topography of the area which creates specific hazards including blind corners, sharp turns, narrow roadways and no sidewalks or shoulders for pedestrians and bicyclists to avoid traffic. One particular blind corner has been the scene of numerous serious accidents.
· At peak hours on week days and week ends, getting in and out of SW Maplecrest is already difficult. Due to high speed traffic and limited sight lines the SW Maplecrest and Terwilliger intersection can be dangerous at any time of the day. Even the projected “low percentage increase” of vehicle trips at the SW Terwilliger and SW Boones Ferry intersection, when combined with a high increase in pedestrian/bicycle trips will be an unacceptable stress to an already overloaded transportation system.
· The CUMP and BDS Staff Report state that the preferred solution is to relocate SW Maplecrest so that it exits further north on SW Terwilliger. This may give a little more room for cars leaving SW Maplecrest to line up at the light going south on SW Terwilliger, but it also puts exiting vehicles 180 feet closer to high speed traffic from the north which rounds a blind curve as it comes down SW Terwilliger. We are also concerned that relocating the exit will reduce the visibility of traffic from the east.
· We were hoping to hear the Portland Bureau of Transportation (PBOT) explain their thoughts on the intersection relocation at the Aug. 19th hearing, but they did not testify.
Parks, Recreation and Open Space, Objective #8a: Protect Tryon Creek State Park as a regionally significant natural and recreational resource.
The Marshall Park Neighborhood Association opposes Lewis & Clark’s proposal to increase the hours of use, proposed lighting and PA system at Huston Field. The Tryon Creek State Park Natural Area and Marshall Park Natural Area provide a valuable wildlife habitat corridor that is getting increasingly stressed by development in the neighborhood and along Boones Ferry Road. Additional night noise, lighting, and traffic will adversely impact wildlife in the area. The MPNA strongly values this natural area component as part of the neighborhood livability.
No campus boundary expansion should be approved in this area until the traffic issues and environmental impact can be studied and resolved.
Thank you for your consideration of these issues.
Mike Charles, Chair, Marshall Park Neighborhood Association.
MPNA mailing address:
Marshall Park NA, c/o SW Neighborhoods, Inc. 7688 SW Capitol Hwy Portland, OR 97219.