FINAL FINDINGS and DECISION by the DESIGN COMMISSION RENDERED on August 20, 2020

FINAL FINDINGS AND DECISION BY THE DESIGN COMMISSION RENDERED ON August 20, 2020

FINAL DECISION BY THE DESIGN COMMISSION

The Design Commission has approved a proposal in your neighborhood. This document is only a summary of the decision. The reasons for the decision, including the written response to the approval criteria and to public comments received on this application, are included in the version located on the BDS website http://www.portlandonline.com/bds/index.cfm?c=46429. Click on the District Coalition then scroll to the relevant Neighborhood, and case number. If you disagree with the decision, you can appeal. Information on how to do so is included at the end of this decision.

CASE FILE NUMBER: LU 19-246279 CCMP AD PC # 19-147103 USPS Broadway Corridor Master Plan

BUREAU OF DEVELOPMENT SERVICES STAFF: Hillary Adam 503-823-3581 / [email protected]

GENERAL INFORMATION

Applicant/Owner: Sarah Harpole 503-823-3337 Prosper Portland Portland Development Commission 222 NW 5th Ave Portland, OR 97209 Owner’s Representative: Julie Bronder 503-863-2289 ZGF Architects LLP 1223 SW Washington St, Suite 200 Portland, OR 97205

Site Address: 715 NW HOYT ST

Legal Description: BLOCK 113&114&129-132&147&148&192&193&T&Z TL 100, COUCHS ADD; BLOCK 114&129&132&147 TL 200, COUCHS ADD Tax Account No.: R180210240, R180210300 State ID No.: 1N1E34BC 00100, 1N1E34BC 00200 Quarter Section: 2929

Neighborhood: Pearl District, contact Reza Farhoodi or David Dysert at [email protected]. Business District: Pearl District Business Association, contact at [email protected] District Coalition: Neighbors West/Northwest, contact Mark Sieber at 503-823-4212.

Plan District: Central City - Pearl District

Final Findings and Decision for USPS Broadway Corridor Master Plan Page 2 Case Number LU 19-246279 CCMP AD

Other Designations: Master Plan Site

Zoning: EXd – Cenral Employment with Design overlay Case Type: CCMP AD – Central City Master Plan with Adjustment Request Procedure: Type III, with a public hearing before the Design Commission. The decision of the Design Commission can be appealed to City Council.

Proposal: The applicant requests Central City Master Plan Review for the 14-acre former site of the United States Postal Service. The Central City Master Plan will establish the framework for future development proposals within the Master Plan boundary (NW Hoyt, NW 9th, NW Lovejoy, NW Broadway). The site will ultimately be home to approximately 4 million square feet of new commercial, employment, and residential development, as well as open space. The Green Loop will run through the center of the site alongside public open space, which includes an extension of the North Park Blocks.

The following Adjustments are requested: 1. 33.510.225 Ground Floor Active Uses – to relocate the Ground Floor active Use Requirement from NW Lovejoy and NW Hoyt Streets to NW Johnson and to NW 8th and NW Park between NW Hoyt and NW Johnson.

A Central City Master Plan Review is required because this site was identified in Map 510-19 of the Portland Zoning Code as requiring a Central City Master Plan Review prior to development of the site.

Relevant Approval Criteria: In order to be approved, this proposal must comply with the approval criteria of Title 33. The relevant approval criteria are:

. 33.510.255.H [Central City Master Plans] Approval Criteria . Oregon Statewide Planning Goals

ANALYSIS

Site and Vicinity: The subject property is a 14-acre site, formerly owned by the United States Postal Service (USPS) and is bound by NW Hoyt Street at the south, NW 9th Avenue on the west, NW Lovejoy Street and bridge ramp on the north, and NW Broadway bridge ramp and NW Station Way on the east. The USPS Broadway Corridor Master Plan area consists of half the area encompassing the larger 28-acre “Broadway Corridor” redevelopment area which includes Union Station, the old Greyhound bus Terminal, PNCA, and other contiguous sites. The USPS site is currently occupied by the former USPS mail distribution facility as well as a multi-level parking garage, surface parking and vehicle storage areas. A portion of the existing building is still used for USPS retail services while all mail distribution functions have been relocated off- site.

The site is located within the Pearl subdistrict of the Central City Plan District and is surrounded by condominium, apartment, and other mixed-use buildings to the south, west, and north. At the north end of the site, the Lovejoy Bridge ramp rises from grade at NW 9th to an ultimate height of approximately 30’ above grade. Below the Lovejoy ramp is a private surface parking lot and immediately beyond the ramp is a multi-level parking garage. There is no access to the site from NW Lovejoy. At the east end of the site, the Broadway Bridge ramp connects to the Lovejoy ramp, approximately 30’ above grade, down to grade at NW Hoyt Street. Below the Broadway ramp, NW Station Way runs north-south before angling southeast in front of the landmark Union Station, the City’s main regional rail station for passenger trains. One

Final Findings and Decision for USPS Broadway Corridor Master Plan Page 3 Case Number LU 19-246279 CCMP AD block further east of the Broadway ramp is the former Greyhound bus station, anticipated for future redevelopment as part of the larger Broadway Corridor Framework Plan. To the south, across NW Hoyt Street is the landmark United States Post Office building, constructed in 1915 and currently serving as the home for the Pacific Northwest College of Art and the landmark Honeyman Hardware Lofts; between these buildings is a surface parking lot intended to be redeveloped as an extension of the North Park Blocks which run south between NW 8th and Park Avenues. West of NW 9th are mid- to and high-rise buildings, including the Ecotrust Building; NW Kearney Street, from NW 9th Avenue to NW 12th Avenue, is a pedestrian street. Jamison Square, a public park, is located one block west, between NW 10th and 11th Avenues and NW Johnson and Kearney Streets.

While not yet constructed, the City’s Transportation System Plan has considered the future extension of NW Johnson between NW 9th Avenue and Station Way, the future extension of NW Park between NW Hoyt and NW Johnson, as well as the extension of the Green Loop trough the site. The site is located within a Bicycle District and a Pedestrian District. The City’s Transportation System Plan has identified the surrounding and proposed extended streets as follows: • NW 9th Avenue – Major City Bikeway, City Walkway • NW Lovejoy Street – Major City Bikeway, Major Emergency Response Street, Central City Transit/Pedestrian Street, Traffic Access Street, Major Transit Priority Street • NW Broadway – Major City Bikeway, Major Emergency Response Street, City Walkway, Traffic Access Street, Transit Access Street • NW Station Way – City Bikeway, City Walkway, Transit Access Street • NW Hoyt Street – City Bikeway, City Walkway • NW Park Avenue – Major City Bikeway, Central City Transit/Pedestrian Street • NW Johnson Street – City Bikeway, Central City Transit/Pedestrian Street • Green Loop – Major City Bikeway, Central City Transit/Pedestrian Street

Beyond the site, the Willamette River is located two blocks beyond the northeast corner of the site and is accessible via a pedestrian bridge that crosses the railroad tracks at Union Station as well as an at-grade crossing three blocks north at the north end of NW 9th Avenue. Broadway Bridge at the northeast corner of the site connects the master plan area to the east side of the Willamette River, landing near the Rose Quarter. Streetcar lines run north and south on NW 10th and 11th, respectively, connecting the site to Northwest Portland, South Waterfront, and the Central Eastside. MAX lines run north and south on NW 6th and 5th avenues, respectively, and connect the site south to Downtown Portland, north to the Expo Center in North Portland, NE to the airport, east to Gresham, SE to Sunnyside, S to Milwaukie, and west to Beaverton and Hillsboro. Bus lines run west on NW Glisan (one block south), east on Everett (three blocks south), south on Broadway and NW 5th, north on NW 6th (terminating at Union Station), and north/south on NW Naito Parkway beyond the railroad tracks.

Zoning: The Central Employment (EX) zone allows mixed-uses and is intended for areas in the center of the City that have predominantly industrial type development. The intent of the zone is to allow industrial and commercial uses which need a central location. Residential uses are allowed, but are not intended to predominate or set development standards for other uses in the area. The development standards are intended to allow new development which is similar in character to existing development.

The Design Overlay Zone [d] promotes the conservation, enhancement, and continued vitality of areas of the City with special scenic, architectural, or cultural value. This is achieved through the creation of design districts and applying the Design Overlay Zone as part of community planning projects, development of design guidelines for each district, and by requiring design review. In addition, design review ensures that certain types of infill development will be compatible with the neighborhood and enhance the area.

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Land Use History: City records indicate that relevant prior land use reviews include: • EA 19-147103 PC – Pre-Application Conference for the current proposal; and • EA 19-147114 DA – Design Advice Request for the current proposal.

Agency Review: A Request for Response was sent on December 27, 2019. The following Bureaus have responded with the following comments:

The Site Development Section of BDS responded, referencing comments submitted for EA 19-147103, and included in the record, which noted: “In order to evaluate whether the foundation design of the proposed structures comply with the Oregon Structural Specialty Code, at the time that each building permit application is submitted the applicant must submit a geotechnical report. A site-specific seismic hazard study is also required for buildings that are more than 6 stories in height with an aggregate floor area of over 60,000 square feet and every building over 10 stories in height. Be advised that historic geotechnical investigation logs in the area indicate the presence of deep undocumented fill, high groundwater, and potentially liquefiable soils underlying the proposed development area.” Please see Exhibit E-1 for additional details.

The Life Safety Division of BDS responded on January 14, 2020, noting “a complete Life Safety plan review will be provided at the time of Building Permit submittal.” Please see Exhibit E-2 for additional details.

The Fire Bureau responded on January 28, 2020 with the following comment, noting no concerns at this time but noted that all applicable Fire code requirements shall apply at the time of permit review and development. The Fire Bureau also noted indicated they would like to provide feedback for the proposed fire hydrant layout and the public street design, noting that the current street layout does not provide adequate aerial fire department access and that they will work with PBOT on any modifications to the plans. Please see Exhibit E-3 for additional details.

The Bureau of Transportation Engineering responded on January 27, 2020 noting additional information and study was needed for PBOT to support the proposal (see Exhibit E-4). PBOT responded again on July 30, 2020, this time indicating support with conditions (see Exhibit E- 7). PBOT also noted that the final Transportation Demand Management Plan was not yet final but will be submitted to PBOT for approval prior to a final land use decision. Final agreed-upon conditions requested by PBOT are as noted: 1. The new public streets shall be in substantial conformance with the approved preliminary engineering plans (20-116312 WT).

2. At a minimum, the mitigation measure listed on Page 47 of the TIA in Table 13, Recommended Intersection Mitigation Measures (By Infrastructure Zone) shall be required with two additional mitigation measures added to the table in this report above. The two additional measures are included below for clarity:

th o NW 9 Ave/NW Lovejoy: dedicate approximately what is required per the City Engineer along the eastern single block frontage of NW 9th Ave between NW Kearney and NW Lovejoy to accommodate right-turn only lane. including utilization of current on-street parking, up to a maximum of 12-ft to accommodate a right-turn only lane. Current estimated dedication based on survey is 3’; final dedication amount to be determined during the engineering phase of the LID. th o NW 9 Ave/NW Hoyt St: Reconstruct NE corner, tighten curb radius and realign crosswalks (this is identified as a developer-financed project in draft MOU);

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o How the City rights-of-way function within and bordering the master plan site is at the sole discretion of the City Engineer. Title 33 has no authority over the function of public streets.

3. Any existing street frontages not covered by the Local Improvement District, the developer shall provide any required dedications and reconstruction to River District Standards under a separate public works permit.

4. The site shall implement the required TDM plan as approved by PBOT Active Transportation and attached to the BDS staff report as an exhibit.

5. Prior to issuance of the first building permit, a Local Improvement District (LID) will be formed for NW Johnson, NW Kearney, and NW Park and required traffic mitigation improvements at the intersections of NW 9th Avenue and Everett, Glisan, Johnson, Kearney, and Lovejoy Streets. The timing for the provision and construction of adequate transportation facilities for each phase shall be per the LID and any associated IGAs.

6. The locations of vehicle access to loading and parking shall be in substantial conformance with the adopted USPS Master Plan. Any significant changes must be approved through a master plan amendment.

The Bureau of Environmental Services responded on January 30, 2020 with a preliminary response indicating they did not yet support the proposal “due to required corrections to the public improvement plans, needed tightening up of the plan’s language around infrastructure and development phasing (as previously raised in the Request for Completeness), and concern that the MOU that will memorialize agreements related to public investment infrastructure improvements is not far enough along in negotiation.” Please see Exhibit E-5 for additional details. On July 31, 2020, BES provided a new response indicating support with conditions (see Exhibit E-8). The conditions requested by BES are as noted: 1. Prior to issuance of the first vertical development building permit, 60% engineering plans for off-site sewer and stormwater system improvements must be complete to the satisfaction of BES. 2. Prior to certificate of occupancy for any vertical development that connects to sewer or stormwater systems impacted by the Off-Site Utilities Phase 1 Streets projects described in the plan, those infrastructure projects must be finished to the satisfaction of BES.

The Water Bureau responded on February 3, 2020, noting they did not yet support the proposal due to an insufficient phasing plan and signed MOU between the Portland Water Bureau and Prosper Portland for the necessary infrastructure to be built. Please see Exhibit E- 6 for additional details. On August 5, 2020, the Water Bureau provided a revised response indicating support with conditions (see Exhibit E-9). The conditions requested by PWB are as noted: 1. New structures that do not have access to existing water mains, or propose services to a future main, will need to have established funding for the new mains to the satisfaction of the Water Bureau prior to building permit approval.

2. The proposed water mains in NW Kearney and NW Johnson cannot be partially constructed. Each main will need to be completed to the eastern and western extents to complete the identified and required looping.

Neighborhood Review: A Notice of Proposal in Your Neighborhood was mailed on January 24, 2020. A second Notice of Proposal was mailed on July 24, 2020, notably noting that the return hearing would be held virtually. Following issuance of the initial Notice of Proposal, six letters have been received.

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1. Joe and Liz Lawlor, on February 4, 2020 with concerns regarding heights and blocked views. ([email protected]) 2. Kent & Lillian Brown, on February 5, 2020, with concerns that tall buildings will excessively shade the park and with traffic impacts. (937 NW Glisan #1030 Portland, OR 97209) 3. Linda Berry, including signatures of 50 residents of the Metropolitan Condominiums at 1001 NW Lovejoy, on February 6, 2020, with concerns that tall buildings will excessively shade the park and with traffic impacts. (1001 NW Lovejoy St Unit 806 Portland, OR 97209) 4. Reza Michael Farhoodi, representing the Pearl District Neighborhood Association, on February 13, 2020, indicating preference for: a podium between 7 & 8, a Block 1 configuration that maximizes solar access, a maximum footprint a Block 2 while preserving open space, activation of 9th Avenue, an iconic design at Block 7, language requiring sculpting of northern blocks to allow for penetration of light and air; and concerns with: the street plan and its relationship with bicycle facilities, the amount of proposed parking, and the potential for the open space to be delivered late in the overall development. ([email protected]) 5. Brendan Doyle, on July 29, 2020, with concerns regarding blocked views. ([email protected]) 6. Brendan Doyle, on August 1, 2020, wrote with concerns about lost views and questions about the design and review process. 7. Glenn Traeger, on August 7, 2020, wrote with concerns about traffic impacts. ([email protected]) 8. Reza Farhoodi, representing Pearl District Neighborhood Association, on August 13, 2020 wrote with appreciation for changes made since February 2020 but still with concerns about traffic impacts, noting shortcomings in the proposed TDM.

Procedural History: This application was submitted on October 28, 2019, and was determined to be complete on December 20, 2019. The first hearing was held on February 13, 2020 and continued to August 6, 2020. The applicant requested the 2nd hearing be rescheduled to August 13, 2020 to account for re-adoption of Central City 2035 Code. On August 13, the Design Commission expressed support for the staff report and the drafted conditions and requested the applicant return on August 20, 2020 with a revised master plan document addressing minor drawing changes related to the west Irving open space and to include the conditions in the final master plan document.

ZONING CODE APPROVAL CRITERIA

(1) CENTRAL CITY MASTER PLANS (33.510.255)

33.510.255 Purpose A Central City Master Plan establishes a clear development strategy for significant redevelopment sites in the Central City. Central City Master Plan review is intended to ensure that development on the site will positively contribute to the existing and desired surrounding urban form. The review will result in an urban design framework and layout for the site as a whole, allowing subsequent reviews for individual buildings and other development to focus on materials and façade treatment. A Central City Master Plan is intended to result in the following urban design outcomes: • A development site that has a strong orientation towards transit and multimodal transportation alternatives; • A safe and vibrant public realm, supported by active ground floor uses, open space areas and an internal circulation system that provides access to adjacent public rights- of‐way and multimodal transportation options;

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• A development site that has adequate urban services such as water, stormwater, sewers, and fire‐hydrants; and • Building bulk, height, orientation, and programming that protects public views and preserves light and air within the public realm, and is oriented to active and passive public gathering spaces, including public open spaces, transit stations, and the Willamette River.

33.510.255 Central City Master Plan Review Approval Criteria A Central City Master Plan review will be approved if the review body finds that the following approval criteria have been met. Criteria H.1 through H.11 apply to all Central City Master Plan reviews. Criteria H.12 through H.15 also apply to proposals within the area identified on Map 510-6 as requiring a Central City Master Plan review for residential uses.

Findings: The site is identified on Map 510-19 as a required Central City Master Plan Area, therefore a Central City Master Plan review is required prior to development of the site. Because the site is subject to a Central City Master Plan review, the approval criteria are listed in 33.510.255.H Approval Criteria.

1. The Central City Master Plan is consistent with applicable subdistrict goals and policies of the Central City 2035 Plan;

Findings: Findings to each of the applicable subdistrict goals and policies of the Central City 2035 Plan are provided in the attached matrix. All goals and policies were found to be either “met” or “met with conditions”. Those suggested conditions are copied here.

2. The master plan demonstrates how development will comply with the Central City Fundamental Design Guidelines, as well as any applicable design guidelines specific to the subdistrict the master plan site is located within;

Findings: Findings to each of the applicable Central City Fundamental Design Guidelines and River District Design Guidelines are provided in the attached matrix. All goals and policies were found to be either “met” or “met with conditions”. Those suggested conditions are copied here.

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This criterion is met with the conditions of approval that: • The building frontages at the Park Avenue Alley shall be designed in such a manner that fosters activity, creates a sense of human scale, and draws people to the open space; this can be accomplished by such means including, but not limited to: provision of leasable active space or small incubator spaces, provision of space for public art mural(s), installation of permanent interactive public art, or other means of activating the frontages facing the Park Avenue Alley; • If Blocks 9a and 9b are built with a shared podium, the building frontage located at the terminus of the Park Avenue Alley shall be programmed with either a prominent main entry to the buildings, active retail, or a significant art piece; • In order to meet criterion #11, if Blocks 7 & 8 and Blocks 9a & 9b & 9c are developed with shared podiums, reasonable efforts should be made to reduce the number of vehicle entry/exit points for each podium, unless PBOT determines that additional entry/exit access points are necessary; one additional loading access point is allowed for Block 9 to accommodate for USPS truck loading; also, if USPS ceases operation at Block 9, the loading bay(s) shall be converted to a more active use; and • Structured elements of the Green Loop shall be subject to a Type III Design Review in order to ensure their compliance with 33.510.255.K, the approved master plan, and the applicable Central City Plan District design guidelines.

3. Development on lots with river frontage incorporates elements that activate the riverfront, such as open areas, trails, accessways, and active land uses that encourage public use and enjoyment of the riverfront;

Findings: The master plan boundary does not have any river frontage. This criterion is not applicable.

4. The proposed uses will not have significant adverse effects on industrial firms or result in conflicts with industrial activities located within the plan boundary or within 500 feet of the plan boundary;

Findings: No industrial firms were identified within 500 feet of the master plan boundary. Union Station is located within 500 feet of the master plan boundary; however, Union Station is a passenger rail station and is considered a Service Passenger Terminal which is included under “Other Categories”, rather than under Industrial Categories. This criterion is not applicable.

5. The master plan demonstrates that development within the plan boundary will establish an overall building orientation through massing, the location of entrances, and the location of ground floor uses that result in an edge that embraces adjacent public park rather than creating an abrupt edge between the plan area and parks, and ensures that development within the plan boundary will not excessively shade the adjacent park;

Findings: In general, by orienting the development around a central park that is intended to be an extension of the North Park Blocks, the proposal ensures that the primary open space, the central park, will not be excessively shaded by the proposed development. In addition, because the entire master plan boundary is located north of the North Park Blocks, the proposed development will not excessively shade the adjacent parks to the south. See page 84 of the packet. Lastly, ground floor active uses and primary building entrances are shown to be located on frontages facing the central park which will help support activity in and around the park and the North Park Blocks to the south. This approval criterion is met.

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6. The master plan demonstrates that easy and safe access will be provided to transit stations located within or immediately adjacent to the master plan boundary, and any buildings located immediately adjacent to a transit station include ground floor uses that create an active and safe pedestrian environment throughout the day, evening, and week;

Findings: No transit stations are located within or immediately adjacent to the master plan area. The nearest transit stations are one and two blocks away on NW 6th and 5th Avenues. This criterion is not applicable.

7. Internal open areas are accessible within, and distributed throughout, the master plan area and have connections to the surrounding neighborhood and to any adjacent open space. Internal open areas enhance visual permeability through the site, especially on sites near the Willamette River. The size and location of each open area must be adequate to accommodate the intended use of the space.

Findings: The proposed master plan will provide internal connections that will allow direct connections from the surrounding neighborhood through the site in the north- south and east-west direction. These connections link external and internal open spaces including extending the North Park Blocks into the site for two blocks and connecting this pedestrian zone with the NW Johnson enhanced retail street which also includes a cycle track leading to Jamison Square and the other parks in the Pearl. The Green Loop will traverse from the northeast corner of the site to the park and will be developed to be accessible to all users. NW Kearney, Johnson and Park between Hoyt and Johnson will all be public rights-of-way and other streets such as Irving and the NW Park and 8th Avenue pedestrian extensions will have public easements so that the public has access to all “streets” within the master plan area.

Noted in the attached matrix under subdistrict policy 5.PL-4 and guidelines A3, C10, and B1-1, specific means to ensure that the proposal meets this criterion. They are copied verbatim below from those sections in Exhibit G-3: • The provided open space just meets the minimum requirement while the ped path calculations indicate these are approaching the maximum allowed. In order to allow the greatest flexibility in the design of the Green Loop, additional open space should be provided at the Irving Street open areas. Because Irving Street is to be designed as private driveways with publicly accessible sidewalks, the vehicular portion of these driveways should only be as long as they need to be to access parking garage entrances. A condition of approval has been added that the open space at the western Irving private street shall be expanded to 50’ x 50’; vehicle access at the east end of Irving shall be extended only as far as is necessary to ensure safe ingress and egress of vehicles in order to maximize open space at the west end of this private street; this shall be demonstrated during the land use review for Blocks 3 & 5. Any less than 50’ x 50’ would require a Modification.

• Staff previously suggested that the Park be delivered within a certain number of years from the approval of the Master Plan and that the Park should be subject to a Design Advice Request (DAR) and a Type II Design Review. Portland Parks and Recreation (PP&R), however, has indicated a desire for flexibility with regard to delivery of the Park, recognizing that the Park is integral to the success of the community, but is also dependent on completion of surrounding streets including Johnson and Park Avenue. PP&R has also indicated a willingness to present to the Design Commission and Prosper Portland indicated the intent was to provide a DAR that would include the Park, the Green Loop, and the PNCA Park Block.

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As such, the condition has been revised to require a PP&R Design Advice Request on the Park, Green Loop, and PNCA Park Block with the Design Commission, and that the Park shall meet the requirements of 33.510.255.K.

• The Green Loop is proposed to be elevated north of Johnson and requires bridging of block 9, NW Kearney and NW Johnson Streets, as well as elevated at the north end of the Park. The applicant indicates that “design of the Green Loop will be a future city-led process, which will determine the specific Green Loop location and improvements.” The general location of the Green Loop is established in this plan; however, the design is yet to be determined, particularly the route through the central park. While portions of the Green Loop will be subject to the Pearl District ROW Standards, this does not include the vertical elements of the Green Loop. Therefore, a condition of approval has been added requiring the structured elements of the Green Loop shall be subject to a Type III Design Review in order to ensure their compliance with 33.510.255.K, the approved master plan, and the applicable Central City Plan District design guidelines.

• Development of designated open areas should be integrated with development on adjacent parcels and should present a unified character. The master plan does not clearly establish which property owners (or agencies) will be responsible for delivery of the Green Loop or other open spaces between buildings; this is defined in Memorandums of Agreement between the applicant and other City agencies for the Green Loop and the Park. However other open areas, located on private property will presumably be split down the centerlines of those open spaces. Such an approach has created significant challenges in areas like the South Waterfront and the Con-way Master Plan Area. As such, a condition of approval has been added that open areas shall be designed for the length and width of the designated open space up to the opposite building footprint line as part of the first land use review for a parcel adjacent to that open space in order to ensure the open area is designed in a comprehensive and coherent manner. This would apply to the open areas between Blocks 6 & 7, between Blocks 7 & 8, between Blocks 1 & 4, and between Blocks 3 & 5. The open areas shall be constructed to the centerline, at a minimum, between each block with the construction of the immediately adjacent block, except at Blocks 7 & 8 which shall be constructed for the full width and length of that open space if that open space is to be built on a podium.

• Lastly, staff and the Commission had previously noted serious concerns about the proposed 40’ width between blocks 6 and 7 without any required stepbacks, as each of these buildings have a maximum height of 400’. Precedent images are shown on pages 74-75 indicating the desired character of this pedestrian street however, the buildings in the images shown are of a substantially different scale. At the first hearing, the Commission suggested 15’ stepbacks on Block 6 & 7 to ensure this alley will have a sense of human scale. The applicant has not shown any stepbacks or widening of the Park Avenue Alley but has proposed other methods to encourage activity and provide a human scale to this Alley; these include a specified location for public art within the Alley and a restriction against parking for a depth of 15’ from the Alley on Block 6. However, a 15’ restriction on parking could still allow less-active areas such as trash rooms and

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service rooms which would not ensure activation of the alley. Section 5 of the document repeatedly refers to the Park Avenue Alley as an opportunity for maker spaces (see pages 85 and 118). To ensure this vision and to mitigate for the deviation from the typical Portland Block Structure, a condition of approval has been added that the building frontages at the Park Avenue Alley shall be designed in such a manner that fosters activity, creates a sense of human scale, and draws people to the open space; this can be accomplished by such means including, but not limited to: provision of leasable active space or small incubator spaces, provision of space for public art mural(s), installation of permanent interactive public art, or other means of activating the frontages facing the Park Avenue Alley.

• The previously proposed minimum distance of 15’ between the structure on block 2 and the western edge of block 5 has been increased to 25’ as was suggested by the Commission. This revision alleviates prior concerns at this location.

This criterion is met with the conditions of approval that: • The open space at the western Irving private street shall be expanded to 50’ x 50’. Vehicle access at the east end of Irving shall be extended only as far as is necessary to ensure safe ingress and egress of vehicles in order to maximize open space at the west end of this private street; this shall be demonstrated during the land use review for Blocks 3 & 5. Any less than50’ x 50’ would require a Modification. • Portland Parks & Recreation shall hold a Design Advice Request on the Park, Green Loop, and PNCA Park Block with the Design Commission. The Park shall meet the requirements of 33.510.255.K; • Structured elements of the Green Loop shall be subject to a Type III Design Review in order to ensure their compliance with 33.510.255.K, the approved master plan, and the applicable Central City Plan District design guidelines; • Open areas shall be designed for the length and width of the designated open space up to the opposite building footprint line as part of the first land use review for a parcel adjacent to that open space in order to ensure the open area is designed in a comprehensive and coherent manner. This would apply to the open areas between Blocks 6 & 7, between Blocks 7 & 8, between Blocks 1 & 4, and between Blocks 3 & 5. The open areas shall be constructed to the centerline, at a minimum, between each block with the construction of the immediately adjacent block, except at Blocks 7 & 8 which shall be constructed for the full width and length of that open space if that open space is to be built on a podium; and • The building frontages at the Park Avenue Alley shall be designed in such a manner that fosters activity, creates a sense of human scale, and draws people to the open space; this can be accomplished by such means including, but not limited to: provision of leasable active space or small incubator spaces, provision of space for public art mural(s), installation of permanent interactive public art, or other means of activating the frontages facing the Park Avenue Alley.

8. The transportation system is capable of supporting the proposed uses in addition to the existing uses in the plan area. Evaluation factors include street capacity, level of service, connectivity, transit availability, availability of pedestrian and bicycle networks, on‐street parking impacts, access restrictions, neighborhood impacts, impacts on pedestrian, bicycle, and transit circulation, and safety. Evaluation factors may be balanced; a finding of failure in one or more factors may be acceptable if the failure is not a result of the proposed development, and any additional impacts on the system from the proposed development are mitigated;

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Findings: The Portland Bureau of Transportation (PBOT) has provided a revised response indicating that they now support the proposal with requested conditions. PBOT has worked extensively with the applicant to define the location and character, and design of streets, adjusted parking expectations, and incorporated multi-modal facilities into the general design of the Master Plan area. With the PBOT conditions noted on pages 4-5, this criterion is met.

9. The proposed street plan must provide multi‐modal street connections to support the surrounding street grid pattern;

Findings: Proposed streets are aligned with the existing street grid and will provide new east-west and north-south connections through the site for pedestrians, bicycles, vehicles, and other modes as well. Two-way vehicular travel will be allowed on Kearney, Johnson, and Park between Hoyt and Johnson. Bicycles will be prioritized via the cycle track on Johnson as well as the Green Loop which travels through the site from the elevated platform at the northeast corner down to the Park and along Park Avenue. Pedestrians will be prioritized along the Green Loop, NW Johnson Street, throughout the park, along NW 8th Avenue, and the pedestrian extension of NW Park Avenue. This criterion is met.

10. The plan ensures that there will be adequate and timely infrastructure capacity for the proposed development; and

Findings: Several infrastructure bureaus (PBOT, BES, PWB) which did not initially support the proposal, have now indicated support for the proposal, provided conditions are added. Those conditions have been incorporated into the final recommendation near the end of this document. Service bureau support is largely based on the phasing plan on page 60, the Phasing and Development Triggers identified on page 63, and other supportive documents included in the file, as outlined in the bureau responses. Please see responses from PBOT (Exhibit E-7), BES (Exhibit E-8), and PWB (Exhibit E-9). With the PBOT, BES, and PWB conditions noted on pages 4-6, this criterion is met.

11. The master plan demonstrates that, to the extent practical and feasible, inactive uses such as, but not limited to, parking and access, loading, and trash and recycling are shared or consolidated, with the goal of activating the pedestrian environment.

Findings: The master plan shows parking garage and loading access points limited to NW Kearney Street and the NW Irving private driveways. Because trash and recycling areas rely on large vehicles to haul waste, trash and recycling areas will also be located along or accessible via Kearney and Irving. Parking garage and loading access points are concentrated on Kearney and Irving to limit conflicts with larger trucks. However, Page 54 shows the location and number of vehicular entries and indicates 4 separate entries on Block 9 and one each on Blocks 7 and 8. Because Block 9 may be built with a single parking podium and because Blocks 7 & 8 may be built with a shared podium, vehicular entries could be further limited. As such, a condition of approval has been added that in order to meet criterion #11, if Blocks 7 & 8 and Blocks 9a & 9b & 9c are developed with shared podiums, reasonable efforts should be made to reduce the number of vehicle entry/exit points for each podium, unless PBOT determines that additional entry/exit access points are necessary; one additional loading access point is allowed for Block 9 to accommodate for USPS truck loading; also, if USPS ceases operation at Block 9, the loading bay(s) shall be converted to a more active use.

Additionally, because Blocks 7 & 8 and Blocks 9a, 9b, and 9c could be developed with shared podiums, it is prudent to construct the podiums under a single land use review

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and building permit even if each tower above the podium is to be developed separately. Sharing parking podiums better enables the master plan to meet this criterion as well as other criteria such as Central City Fundamental Design Guidelines. Shared podiums are not without challenges though. Specifically, designing a shared podium for two separate towers, one of which may be designed and permitted later means that the podium will likely exceed the Growth Parking Maximums listed in 33.510 until the time that the second tower is delivered. Ensuring design coherency is also a challenge, though not impossible. Some design work will be required to ensure the parking podium has a coherent design across the façades, and with the first tower, and is done in a way to limit negative impacts to the pedestrian realm. The second tower will have the burden of ensuring design compatibility with the parking podium and the initial tower. In order to approve a parking podium that may exceed the maximums, the land use review for the parking podium and initial tower will have to be conditioned with a minimum amount of floor area for the second tower to ensure that the maximums are ultimately not exceeded. In addition, because the second tower may come potentially years after the initial tower, the top (roof) of the podium should be designed with semi-permanent active uses as an interim design in the initial land use review. In order to allow the development of shared parking podiums, a condition of approval has been added: If Blocks 7 & 8 and Blocks 9a & 9b & 9c are designed with shared podiums, the podiums can be completed with the first towers with the second (and third) towers to be delivered at a later date. The total number of parking spaces within the shared podiums may exceed the Growth Parking maximums noted in 33.510, provided minimum floor areas are established for the second (and third) towers so that the total number of parking spaces for all towers will not exceed the maximums in 33.510 upon completion of all towers above each podium. Without a specific detailed design for the second tower, the top (roof) of the podium shall be designed with semi-permanent active uses as an interim design in the initial land use review.

This criterion is met with the conditions of approval that: • In order to meet criterion #11, if Blocks 7 & 8 and Blocks 9a & 9b & 9c are developed with shared podiums, reasonable efforts should be made to reduce the number of vehicle entry/exit points for each podium, unless PBOT determines that additional entry/exit access points are necessary; one additional loading access point is allowed for Block 9 to accommodate for USPS truck loading; also, if USPS ceases operation at Block 9, the loading bay(s) shall be converted to a more active use; and • If Blocks 7 & 8 and Blocks 9a & 9b & 9c are designed with shared podiums, the podiums can be completed with the first towers with the second (and third) towers to be delivered at a later date. The total number of parking spaces within the shared podiums may exceed the Growth Parking maximums noted in 33.510, provided minimum floor areas are established for the second (and third) towers so that the total number of parking spaces for all towers will not exceed the maximums in 33.510 upon completion of all towers above each podium. Without a specific detailed design for the second tower, the top (roof) of the podium shall be designed with semi-permanent active uses as an interim design in the initial land use review.

(2) ADJUSTMENT REQUESTS (33.805)

33.805.010 Purpose The regulations of the zoning code are designed to implement the goals and policies of the Comprehensive Plan. These regulations apply city-wide, but because of the city's diversity, some sites are difficult to develop in compliance with the regulations. The adjustment review process provides a mechanism by which the regulations in the zoning code may be modified if

Final Findings and Decision for USPS Broadway Corridor Master Plan Page 14 Case Number LU 19-246279 CCMP AD the proposed development continues to meet the intended purpose of those regulations. Adjustments may also be used when strict application of the zoning code's regulations would preclude all use of a site. Adjustment reviews provide flexibility for unusual situations and allow for alternative ways to meet the purposes of the code, while allowing the zoning code to continue to provide certainty and rapid processing for land use applications.

33.805.040 Approval Criteria The approval criteria for signs are stated in Title 32. All other adjustment requests will be approved if the review body finds that the applicant has shown that either approval criteria A. through F. or approval criteria G. through I., below, have been met.

The following Adjustment is requested:

1. 33.510.225 Ground Floor Active Uses – to relocate the Ground Floor Active Use requirement from NW Lovejoy and NW Hoyt Streets to NW Johnson and to NW 8th and NW Park between NW Hoyt and NW Johnson.

A. Granting the adjustment will equally or better meet the purpose of the regulation to be modified; and

Findings: Per 33.510.225.A, the purpose of the regulation is as follows: “The ground floor active use standards are intended to reinforce the continuity of pedestrian-active ground-level building uses. The standards help maintain a healthy urban district through the interrelationship of ground-floor building occupancy and street level accessible public uses and activities, and they encourage a transit supportive, pedestrian-oriented environment that is safe, active with uses, and comfortable for residents, visitors, and others. Active uses include but are not limited to: lobbies, retail. Commercial, and office uses, but do not include storage, vehicle parking, garbage, recycling, mechanical, or utility uses.”

Because NW Lovejoy is an elevated bridge ramp with a private surface parking lot below, requiring the ground level of the northern frontage of the site to have active uses at the ground floor is impractical as this level of the building faces inactive uses and this portion of the site is unlikely to have pedestrian activity. Providing active uses that front on the bridge ramp is also infeasible due to a required maintenance clearance for the bridge ramp which disallows buildings to be constructed to the edge of the ramp. NW Hoyt is also not the most desirable location for required active uses as the buildings south of Hoyt – the old United States Post Office (now PNCA) and the Honeyman Hardware Lofts – are each historic landmarks with substantial portions of their north facades dedicated to garage, loading, and back of house uses.

By relocating the Ground Floor Active Use standard from Lovejoy and Hoyt to the NW Johnson and the park-facing frontages, this will ensure that Johnson will be the successful enhanced retail street it is envisioned to be and that the park will be surrounded with active uses ensuring a higher level of use and safety to the park. Relocating the Active Use requirement away from Lovejoy better meets the purpose of the standard as Lovejoy is inaccessible and therefore not supportive of a transit- and pedestrian oriented environment, whereas Johnson is supportive of transit and pedestrians due to its direct connection to Union Station and the streetcar stop at NW 10th. Relocating the Active Use requirement away from NW Hoyt to the park frontages is also better supportive of the pedestrian environment as it will remove this requirement from a street that does not complement active uses on the south side and will better ensure comfort and safety of pedestrians within the park.

This approval criterion is met.

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B. If in a residential zone, the proposal will not significantly detract from the livability or appearance of the residential area, or if in a C, E, or I zone, the proposal will be consistent with the desired character of the area; and

Findings: Per 33.140.030.B the characteristics of the Central Employment zone is as follows: “This zone implements the Central Employment map designation of the Comprehensive Plan. The zone allows mixed-uses and is intended for areas in the center of the City that have predominantly industrial type development. The intent of the zone is to allow industrial and commercial uses which need a central location. Residential uses are allowed, but are not intended to predominate or set development standards for other uses in the area. The development standards are intended to allow new development which is similar in character to existing development.”

The majority of the Pearl subdistrict is zoned EXd while the Old Town/Chinatown subdistrict, which immediately abuts the master plan areas on the east is zoned CXd (Central Commercial with Design overlay); this CXd zoning extends to the south of the master plan area from NW Hoyt and continuing into Downtown. The Pearl subdistrict contains a diverse mix of uses, with residential and commercial uses predominating. The master plan does not propose to limit or expand allowable uses beyond what is described in the EX zone. The Pearl subdistrict has buildings of all vintages and design and has seen more growth than many other areas of the City over the past two decades. The proposed master plan will establish the general location and character of new private and public streets as well as establish the general footprints of proposed developable blocks, though actual parcels will be created through separate processes. The proposed master plan will also establish general floor area ratios (FAR) and height minimum and maximums for each of those developable blocks.

This approval criterion is met.

C. If more than one adjustment is being requested, the cumulative effect of the adjustments results in a project which is still consistent with the overall purpose of the zone; and

Findings: Only one Adjustment is requested. This approval criterion is not applicable.

D. City-designated scenic resources and historic resources are preserved; and

Findings: There are no city-designated scenic or historic resources on this site. This criterion does not apply.

E. Any impacts resulting from the adjustment are mitigated to the extent practical; and

Findings: The requested Adjustment will better meet the intent of the standard, thus the Adjustment to relocate the Ground Floor Active Use standard, particularly from Lovejoy where it would be essentially useless to Johnson, where it will help provide a distinct identity to the master plan area, serves as the mitigation for the request. Relocation of the Active Use standard from Hoyt, a relatively inactive street, to the park frontages will also ensure that the park is activated which will increase the safety and comfort of the park. This criterion is met.

F. If in an environmental zone, the proposal has a few significant detrimental environmental impacts on the resource and resource values as is practicable;

Findings: This site is not within an environmental zone. This criterion does not apply.

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(3) Oregon Statewide Planning Goals

Goal 1: Citizen Involvement Goal 1 calls for “the opportunity for citizens to be involved in all phases of the planning process.” It requires each city and county to have a citizen involvement program containing six components specified in the goal. It also requires local governments to have a Committee for Citizen Involvement (CCI) to monitor and encourage public participation in planning.

Findings: The City has a citizen involvement program that complies with all Goal 1 requirements, including requirements for public notice of land use applications and an opportunity for public comment on proposals. The CCMP (Central City Master Plan) process in this case complied with all procedural requirements related to notice and citizen involvement and the applicant conducted voluntary neighborhood outreach. Specifically, this CCMP process included the following: • Public notice of the land use review application to seek public comment on the proposal, consistent with requirements in Chapter 33.730 of the Portland Zoning Code. Notice was mailed to all property owners and tenants within 400 feet of the site, and recognized organizations within 1,000 feet of the site. • The site was posted with a notice sign that described the proposal and announced the public hearing date and time. Posting of the site occurred at least 20 days prior to the hearing, consistent with Chapter 33.730 requirements. • Opportunity to testify at the public hearings before the Design Commission.

All public notice requirements for this proposal have been met and will continue to be met. Nothing about this proposal will impact the City’s continued compliance with Goal 1. Therefore, this proposal is consistent with this goal.

Goal 2: Land Use Planning Goal 2 outlines the basic procedures of Oregon’s statewide planning program. It states that land use decisions are to be made in accordance with a comprehensive plan, and that suitable “implementation ordinances” to put the plan’s policies into effect must be adopted. It requires that plans be based on “factual information”; that local plans and ordinances be coordinated with those of other jurisdictions and agencies; and that plans be reviewed periodically and amended as needed. Goal 2 also contains standards for taking exceptions to statewide goals. An exception may be taken when a statewide goal cannot or should not be applied to a particular area or situation.

Findings: Compliance with Goal 2 is achieved, in part, through the City’s comprehensive plan and land use regulations. Goal 2 requires that quasi-judicial decisions, such as this one, be supported by an adequate factual base. In this case, consistency with Goal 2 is not yet achieved because the master plan is not yet found to be met the approval criteria including the subdistrict goals and policies or the applicable design guidelines. For these reasons, the proposal is not yet found to be consistent with Goal 2.

Goal 3: Agricultural Lands Goal 3 defines “agricultural lands,” and requires counties to inventory such lands and to “preserve and maintain” them through farm zoning. Details on the uses allowed in farm zones are found in ORS Chapter 215 and in Oregon Administrative Rules, Chapter 660, Division 33.

Goal 4: Forest Lands This goal defines forest lands and requires counties to inventory them and adopt policies and ordinances that will “conserve forest lands for forest uses.”

Findings for Goals 3 and 4: In 1991, as part of Ordinance No. 164517, the City of Portland took an exception to the agriculture and forestry goals in the manner authorized

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by state law and Goal 2. Since this review does not change any of the facts or analyses upon which the exception was based, the exception is still valid and Goal 3 and Goal 4 do not apply.

Goal 5: Open Spaces, Scenic and Historic Areas and Natural Resources Goal 5 relates to the protection of natural and cultural resources. It establishes a process for inventorying the quality, quantity, and location of 12 categories of natural resources. Additionally, Goal 5 encourages but does not require local governments to maintain inventories of historic resources, open spaces, and scenic views and sites.

Findings: The City complies with Goal 5 by maintaining an inventory of natural, scenic and historic resources and protecting them through zoning regulations. Natural and scenic resources are identified and protected through the application of the Environmental Protection (“p”), Environmental Conservation (“c”), and Scenic (“s”) overlay zones on the Portland zoning Map. Development in the scenic and environmental overlay zones can be restricted in order to protect identified resources. Historic resources are identified and protected separately through either individual or district historic designations that are identified on the Portland Zoning Map. The subject site is not within an environmental or scenic overlay zone, nor is it located within a designated historic district. Therefore, Goal 5 does not apply to this decision.

Goal 6: Air, Water and Land Resources Quality Goal 6 requires local comprehensive plans and implementing measures to be consistent with state and federal regulations on matters such as groundwater pollution.

Findings: The City complies with Goal 6 by implementing development regulations such as the City’s Stormwater Management Manual at the time of building permit review, and through compliance with DEQ requirements for cities. In this case, the Bureau of Environmental Services (BES) reviewed the application for compliance with applicable sewer and stormwater requirements and has found that the project complies. The City also maintains continued compliance with state DEQ requirements for cities through a variety of programs, regulations and management tools that are not affected by this CCMP decision. For these reasons, the proposal has been found to be consistent with Goal 6.

Goal 7: Areas Subject to Natural Disasters and Hazards Goal 7 requires that jurisdictions adopt development restrictions or safeguards to protect people and property from natural hazards. Under Goal 7, natural hazards include floods, landslides, earthquakes, tsunamis, coastal erosion, and wildfires. Goal 7 requires that local governments adopt inventories, policies, and implementing measures to reduce risks from natural hazards to people and property.

Findings: The City maintains a map of natural hazard areas, including floodplains, landslide areas, and earthquake hazard areas, and implements additional requirements or restrictions for development in those areas. The regulations that apply in the mapped areas impose additional development and land division requirements and limitations in the mapped areas. The subject site is located within the Cascadia Subduction Zone and is mapped with a moderate to very high probability of perceived shaking and damage, peak ground acceleration, permanent ground deformation, and probability of liquefaction for a potential 9.0 earthquake as well as high probability in those same categories for a potential 6.8 Portland Hills Fault earthquake. Compliance with regulations related to this designation will be verified during future building permit reviews and inspections. Therefore, the proposal is consistent with Goal 7.

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Goal 8: Recreation Needs Goal 8 calls for each community to evaluate its areas and facilities for recreation and develop plans to deal with the projected demand for them. It also sets forth detailed standards for expediting siting of destination resorts.

Findings: The City complies with Goal 8 through its comprehensive planning process, which includes long-range planning for parks and recreational facilities. The City maintains a series of parks master plans that inventory parks conditions, anticipate demands and identify improvement projects. Development projects in the City are required to pay system development fees to support identified city-wide parks and recreation projects. The future buildings will not be located within existing parks or recreations areas, nor will it preclude the City from implementing planned parks and recreation projects. Parks systems development charges for this project will be assessed at the time of building permits and will help fund the projects identified by the City. For these reasons, this proposal is consistent with Goal 8.

Goal 9: Economy of the State Goal 9 calls for diversification and improvement of the economy. Goal 9 requires communities to inventory commercial and industrial lands, project future needs for such lands, and plan and zone enough land to meet those needs.

Findings: The City identified land needs for industrial and commercial uses in the adopted and acknowledged Economic Opportunities Analysis (EOA) (Ordinance 187831). The EOA analyzed growth capacity for a diverse range of uses by identifying serval geographic areas within the City, including the Central City, and conducting a buildable land inventory and capacity analysis in each. In response to the analysis, the City adopted policies and regulations that are intended to preserve a supply of sites that have the appropriate combination of zoning, size, location and public services to facilitate employment growth. A large portion of the Central City, including the subject site, is zoned Central Employment (EX) and was identified in the EOA as an area of future employment growth and economic opportunities. The proposed development is allowed use in the EX zone, that will create new employment opportunities and contribute to the City’s tourism industry, further supporting and improving the overall economy of the Central City and the City as a whole. For these reasons, the CCMP decision for this master plan is consistent with Goal 9.

Goal 10: Housing Goal 10 requires local governments to plan for and accommodate needed housing types. The Goal also requires cities to inventory its buildable residential lands, project future needs for such lands, and plan and zone enough buildable land to meet those needs. It also prohibits local plans from discriminating against needed housing types.

Findings: The City complied with the Goal 10 inventory requirements by developing an inventory of residential land as part of its Buildable Lands Inventory (BLI) adopted through Ordinance 187831 which USPS Master Plan Page 4 of 6 was acknowledged on April 25, 2017. The City Council identified the documents, reports and maps adopted by City Council through acknowledged Ordinance 187831, including the inventory of residential lands as official 2035 Comprehensive Plan supporting documents and found that those acknowledged documents, reports and maps constitute an adequate factual base for all components of the 2035 Comprehensive Plan. The BLI found that the zoning in the Central City could provide capacity to meet the housing projections for the year 2035. Analysis demonstrated that the zoning and proposed amendments would be sufficient to allow approximately 39,500 units to be developed in the Central City through 2035. However, the BLI also acknowledged that not all development within the Central City’s mixed-use zone

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would provide housing. The master plan includes housing as part of the development and is therefore consistent with Goal 10 to the extent it applies.

Goal 11: Public Facilities and Services Goal 11 calls for efficient planning of public services such as sewers, water, law enforcement, and fire protection. The goal’s central concept is that public services should be planned in accordance with a community’s needs and capacities rather than be forced to respond to development as it occurs.

Findings: The City Council elected to satisfy Goal 11 through the adoption of a Citywide Systems Plan (CSP) to serve as the City’s public facilities plan for water, sewage and drainage facilities. The City Council adopted the CSP, with the exception of Chapters 9 and 10 and Appendices A, B, and C, as a Comprehensive Plan supporting document through Ordinance 187831. Ordinance 187831 was acknowledged on April 25, 2017. The City Council identified the documents, reports and maps adopted by City Council through acknowledged Ordinance 187831, including the CSP as official 2035 Comprehensive Plan supporting documents and found that those acknowledged documents, reports and maps constitute an adequate factual base for all components of the 2035 Comprehensive Plan. As an acknowledged support document for the 2035 Comprehensive Plan, the CSP guides infrastructure investments by the City to meet the needs of current and future Portlanders. The CSP is a 20-year coordinated municipal infrastructure plan for all areas with the City of Portland’s urban service boundary, including the Central City. Portland’s municipal infrastructure assets are physical systems that provide services and are maintained by the City. If existing public services are not adequate for a specific development, the applicant is generally required to extend public services at their own expense in a way that conforms to the CSP. In this case, the city and the applicant have identified an upgrade to the storm and sanitary sewer system, as well as other utility upgrades that will be required to support the development in the master plan. The Bureau of Environmental Services and the Water Bureau have both indicated support for the proposal with conditions of approval. Therefore, the proposal is found to be consistent with Goal 11.

Goal 12: Transportation Goal 12 seeks to provide and encourage “safe, convenient and economic transportation system.” Among other things, Goal 12 requires that transportation plans consider all modes of transportation and be based on inventory of transportation needs.

Findings: The TSP is the 20-year guide to transportation investments in Portland. The Transportation Element of Portland’s Comprehensive Plan was first adopted by Ordinance No. 165851 in September of 1992 and was later modified and expanded through a series of later City ordinances. Further updates to the TSP were carried out as part of the Portland periodic review process that culminated in the adoption USPS Master Plan Page 5 of 6 of the 2035 Comprehensive Plan and the implementing land use regulations that are effective within the Central City Plan District and citywide. The update was carried out in three stages as part of the 2035 Comprehensive Plan and was adopted through Ordinances 187832, 188177, and 188957.

The City adopted further TSP amendments as part of the Central City 2035 Plan and related amendments to Portland City Code Title 33 through Ordinance 189000. The City adopted Volume 2B, Transportation System Plan Amendments which included amendments to policies, project and studies lists, and street classifications maps. The document also includes the Portland Central City Multimodal Mixed Use Area Agreement between the City and the Oregon Department of Transportation, and a letter from the Oregon Department of Transportation providing written concurrence with the designation of the Central City as a Multi-Modal Mixed-Use Area (MMA). The Volume 2B Transportation

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System Plan Amendments are incorporated herein by reference. The subject development is located within the identified MMA in an area that is convenient for people to walk, bicycle and use transit in addition to vehicles to travel to and from the site. PBOT evaluates the development in relation to the surrounding transportation system and goals of the TSP. In this case, PBOT has found that, with added conditions of approval, the development complies. For these reasons, the proposal is found to be consistent with Goal 12.

Goal 13: Energy Goal 13 seeks to conserve energy and declares that “land and uses developed on the land shall be managed and controlled so as to maximize the conservation of all forms of energy, based upon sound economic principles.”

Findings: In support of Goal 13 objectives, the City’s TSP contains policies intended to create more efficient transportation networks, reduce reliance on vehicles and promote walking, biking and other forms of non-automobile travel. Further, the City also established standards and regulations to increase energy efficiency in site and building design as part of Central City 2035. Future buildings will have to comply with all zoning and building code regulations related to energy consumption. The proposed infrastructure – streets, stormwater, sanitary, and water – including off-site improvements are proposed to accommodate the proposed potential development. Therefore, the project is found to be consistent with Goal 13.

Goal 14: Urbanization This goal requires cities to estimate future growth and needs for land and then plan and zone enough land to meet those needs. It calls for each city to establish an “urban growth boundary” (UGB) to “identify and separate urbanizable land from rural land.” It specifies seven factors that must be considered in drawing up a UGB. It also lists four criteria to be applied when undeveloped land within a UGB is to be converted to urban uses.

Findings: The regional government for the Portland metropolitan area, Metro, is primarily responsible for regulating and administering Goal 14 functions. Metro’s 2040 Growth Concept establishes the long range land use plan for the region and is implemented by the Urban Growth Management Functional Plan. All Metro cities, including Portland, must ensure that their land use policies and zoning regulations are consistent with the Functional Plan. The subject site is located in the City’s established UGB. The development does not alter the Metro UGB and does not affect the Portland Zoning Code’s compliance with Metro’s Urban Growth Management Functional Plan. Therefore, Goal 14 is not applicable.

Goal 15: Willamette Greenway Goal 15 sets forth procedures for administering the 300 miles of greenway that protects the Willamette River.

Findings: The City complies with Goal 15 by applying Greenway overlay zones which impose special requirements on development activities near the Willamette River. The subject site is not within a Greenway overlay zone near the Willamette River. Therefore, Goal 15 does not apply.

Goal 16: Estuarine Resources This goal requires local governments to classify Oregon’s 22 major estuaries in four categories: natural, conservation, shallow-draft development, and deep-draft development. It then describes types of land uses and activities that are permissible in those “management units.”

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Goal 17: Coastal Shorelands This goal defines a planning area bounded by the ocean beaches on the west and the coast highway (State Route 101) on the east. It specifies how certain types of land and resources there are to be managed: major marshes, for example, are to be protected. Sites best suited for unique coastal land uses (port facilities, for example) are reserved for “water-dependent” or “water-related” uses.

Goal 18: Beaches and Dunes Goal 18 sets planning standards for development on various types of dunes. It prohibits residential development on beaches and active foredunes, but allows some other types of development if they meet key criteria. The goal also deals with dune grading, groundwater drawdown in dunal aquifers, and the breaching of foredunes.

Goal 19: Ocean Resources Goal 19 aims “to conserve the long-term values, benefits, and natural resources of the nearshore ocean and the continental shelf.” It deals with matters such as dumping of dredge spoils and discharging of waste products into the open sea. Goal 19’s main requirements are for state agencies rather than cities and counties.

Findings: Since Portland is not within Oregon’s coastal zone, Goals 16-19 do not apply.

DEVELOPMENT STANDARDS

Unless specifically required in the approval criteria listed above, this proposal does not have to meet the development standards in order to be approved during this review process. The plans submitted for a building or zoning permit must demonstrate that all development standards of Title 33 can be met, or have received an Adjustment or Modification via a land use review prior to the approval of a building or zoning permit.

CONCLUSIONS

Following months and years of coordination across multiple city bureau’s, the proposed USPS Broadway Corridor Master Plan is found to meet the applicable Master Plan approval criteria, with the additional conditions noted. The proposed master plan will provide the framework for development of approximately 4 million square feet of commercial and residential uses, as well as public open space including a public park, publicly-accessible plaza areas, and a segment of the Green Loop. Over time, development of the open space and buildings envisioned in this master plan will transform an area long severed from public use into a hub of activity and a place for people. Therefore, the proposed master plan, with the added conditions, meets the applicable Master Plan approval criteria and applicable Adjustment approval criteria and therefore warrants approval.

DESIGN COMMISSION DECISION

It is the decision of the Design Commission to approve a Central City Master Plan Review for the 14-acre former site of the United States Postal Service. The Central City Master Plan will establish the framework for future development proposals within the Master Plan boundary (NW Hoyt, NW 9th, NW Lovejoy, NW Broadway). The site will ultimately be home to approximately 4 million square feet of new commercial, employment, and residential development, as well as open space. The Green Loop will run through the center of the site alongside public open space, which includes an extension of the North Park Blocks.

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Approval of the following Adjustment: 1. 33.510.225 Ground Floor Active Uses – to relocate the Ground Floor active Use Requirement from NW Lovejoy and NW Hoyt Streets to NW Johnson and to NW 8th and NW Park between NW Hoyt and NW Johnson.

Approvals per Exhibits C-1 through C-122, signed, stamped, and dated August 20, 2020, subject to the following conditions:

A. As part of the final Master Plan document, the following conditions (B through L) must be noted within the document.

B. The following PBOT conditions: 1. The new public streets shall be in substantial conformance with the approved preliminary engineering plans (20-116312 WT).

4. The site shall implement the required TDM plan as approved by PBOT Active Transportation and attached to the BDS staff report as an exhibit.

C. The following BES conditions: 1. Prior to issuance of the first vertical development building permit, 60% engineering plans for off-site sewer and stormwater system improvements must be complete to the satisfaction of BES.

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2. Prior to certificate of occupancy for any vertical development that connects to sewer or stormwater systems impacted by the Off-Site Utilities Phase 1 Streets projects described in the plan, those infrastructure projects must be finished to the satisfaction of BES.

D. The following PWB conditions: 1. New structures that do not have access to existing water mains, or propose services to a future main, will need to have established funding for the new mains to the satisfaction of the Water Bureau prior to building permit approval.

E. The open space at the western Irving private street shall be expanded to 50’ x 50’. Vehicle access at the east end of Irving shall be extended only as far as is necessary to ensure safe ingress and egress of vehicles in order to maximize open space at the west end of this private street; this shall be demonstrated during the land use review for Blocks 3 & 5. Any less than 50’ x 50’ would require a Modification.

F. Portland Parks & Recreation shall hold a Design Advice Request on the Park, Green Loop, and PNCA Park Block with the Design Commission. The Park shall meet the requirements of 33.510.255.K.

G. Structured elements of the Green Loop shall be subject to a Type III Design Review in order to ensure their compliance with 33.510.255.K, the approved master plan, and the applicable Central City Plan District design guidelines.

H. Open areas shall be designed for the length and width of the designated open space up to the opposite building footprint line as part of the first land use review for a parcel adjacent to that open space in order to ensure the open area is designed in a comprehensive and coherent manner. This would apply to the open areas between Blocks 6 & 7, between Blocks 7 & 8, between Blocks 1 & 4, and between Blocks 3 & 5. The open areas shall be constructed to the centerline, at a minimum, between each block with the construction of the immediately adjacent block, except at Blocks 7 & 8 which shall be constructed for the full width and length of that open space if that open space is to be built on a podium.

I. The building frontages at the Park Avenue Alley shall be designed in such a manner that fosters activity, creates a sense of human scale, and draws people to the open space; this can be accomplished by such means including, but not limited to: provision of leasable active space or small incubator spaces, provision of space for public art mural(s), installation of permanent interactive public art, or other means of activating the frontages facing the Park Avenue Alley.

J. If Blocks 9a and 9b are built with a shared podium, the building frontage located at the terminus of the Park Avenue Alley shall be programmed with either a prominent main entry to the buildings, active retail, or a significant art piece.

K. In order to meet criterion #11, if Blocks 7 & 8 and Blocks 9a & 9b & 9c are developed with shared podiums, reasonable efforts should be made to reduce the number of vehicle entry/exit points for each podium, unless PBOT determines that additional entry/exit access points are necessary; one additional loading access point is allowed for Block 9 to accommodate for USPS truck loading; also, if USPS ceases operation at Block 9, the loading bay(s) shall be converted to a more active use.

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G. If Blocks 7 & 8 and Blocks 9a & 9b & 9c are designed with shared podiums, the podiums can be completed with the first towers with the second (and third) towers to be delivered at a later date. The total number of parking spaces within the shared podiums may exceed the Growth Parking maximums noted in 33.510, provided minimum floor areas are established for the second (and third) towers so that the total number of parking spaces for all towers will not exceed the maximums in 33.510 upon completion of all towers above each podium. Without a specific detailed design for the second tower, the top (roof) of the podium shall be designed with semi-permanent active uses as an interim design in the initial land use review.

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By: ______Sam Rodriguez, Design Commission Vice Chair

Application Filed: October 28, 2019 Decision Rendered: August 20, 2020 Decision Filed: August 21, 2020 Decision Mailed: September 8, 2020

About this Decision. This land use decision is not a permit for development. Permits may be required prior to any work. Contact the Development Services Center at 503-823-7310 for information about permits.

Procedural Information. The application for this land use review was submitted on October 28, 2019, and was determined to be complete on December 20, 2019.

Zoning Code Section 33.700.080 states that Land Use Review applications are reviewed under the regulations in effect at the time the application was submitted, provided that the application is complete at the time of submittal, or complete within 180 days. Therefore this application was reviewed against the Zoning Code in effect on October 28, 2019.

ORS 227.178 states the City must issue a final decision on Land Use Review applications within 120-days of the application being deemed complete. The 120-day review period may be waived or extended at the request of the applicant. In this case, the applicant waived the 120- day review period, as stated with Exhibit A-6. The 120 days expire on: December 19, 2020.

Some of the information contained in this report was provided by the applicant. As required by Section 33.800.060 of the Portland Zoning Code, the burden of proof is on the applicant to show that the approval criteria are met. This report is the final decision of the Design Commission with input from other City and public agencies.

Conditions of Approval. This approval may be subject to a number of specific conditions, listed above. Compliance with the applicable conditions of approval must be documented in all related permit applications. Plans and drawings submitted during the permitting process must illustrate how applicable conditions of approval are met. Any project elements that are specifically required by conditions of approval must be shown on the plans, and labeled as such.

These conditions of approval run with the land, unless modified by future land use reviews. As used in the conditions, the term “applicant” includes the applicant for this land use review, any person undertaking development pursuant to this land use review, the proprietor of the use or development approved by this land use review, and the current owner and future owners of the property subject to this land use review.

Final Findings and Decision for USPS Broadway Corridor Master Plan Page 25 Case Number LU 19-246279 CCMP AD

Appeal of this decision. This decision is final unless appealed to City Council, who will hold a public hearing. Appeals must be filed by 4:30 pm on September 22, 2020. The appeal application form can be accessed at https://www.portlandoregon.gov/bds/45477. Towards promoting social distancing during the COVID-19 pandemic, the completed appeal application form must be e-mailed to [email protected] and to the planner listed on the first page of this decision. If you do not have access to e-mail, please telephone the planner listed on the front page of this notice about submitting the appeal application.

If you are interested in viewing information in the file, please contact the planner listed on the front of this decision. The planner can provide some information over the phone. Please note that due to COVID-19 and limited accessibility to files, only digital copies of material in the file are available for viewing. Additional information about the City of Portland, city bureaus, and a digital copy of the Portland Zoning Code is available on the internet at https://www.portlandoregon.gov/citycode/28197.

If this decision is appealed, a hearing will be scheduled and you will be notified of the date and time of the hearing. The decision of City Council is final; any further appeal is to the Oregon Land Use Board of Appeals (LUBA).

Upon submission of their application, the applicant for this land use review chose to waive the 120-day time frame in which the City must render a decision. This additional time allows for any appeal of this proposal to be held as an evidentiary hearing, one in which new evidence can be submitted to City Council.

Who can appeal: You may appeal the decision only if you have written a letter which was received before the close of the record at the hearing or if you testified at the hearing, or if you are the property owner or applicant. Appeals must be filed within 14 days of the decision. An appeal fee of $5,000.00 will be charged. Last date to appeal: September 22, 2020.

Neighborhood associations may qualify for a waiver of the appeal fee. Additional information on how to file and the deadline for filing an appeal will be included with the decision. Assistance in filing the appeal and information on fee waivers are available from the Bureau of Development Services in the Development Services Center, 1900 SW Fourth Ave., First Floor. Fee waivers for neighborhood associations require a vote of the authorized body of your association. Please see appeal form for additional information.

Recording the final decision. If this Land Use Review is approved the final decision will be recorded with the Multnomah County Recorder. • Unless appealed, the final decision will be recorded on or after September 23, 2020 by the Bureau of Development Services.

The applicant, builder, or a representative does not need to record the final decision with the Multnomah County Recorder.

For further information on your recording documents please call the Bureau of Development Services Land Use Services Division at 503-823-0625.

Expiration of this approval. An approved Central City Master Plan remains in effect until development allowed by the plan has been completed, except that a Central City Master Plan expires 10 years from the date of the final decision if none of the development or activity allowed by the plan has commenced.

Final Findings and Decision for USPS Broadway Corridor Master Plan Page 26 Case Number LU 19-246279 CCMP AD

Hillary Adam August 24, 2020

The Bureau of Development Services is committed to providing equal access to information and hearings. Please notify us no less than five business days prior to the event if you need special accommodations. Call 503-823-7300 (TTY 503- 823-6868).

EXHIBITS – NOT ATTACHED UNLESS INICATED

A. Applicant’s Statement 1. Drawing Packet 2. List of site and adjacent also-owned parcels 3. Street Section Details 4. Utility Plans 5. Additional Technical Documents 6. 120-Day Waiver 7. Completeness Response Letter 8. Completeness Response packet 9. Street Section Details 10. Easements and ROWs 11. Sidewalks 12. Street Descriptions 13. Transportation Study 14. Response to Statewide Planning Goals 15. Transportation study support documents 16. Soil Studies B. Zoning Map (attached) C. Plan & Drawings 1. Title Page 2. Contents 3. Contents 4. Preface 5. Title 33.510.255 Response Index 6. Title 33.510.255 Response Index 7. Design Team 8. Vision 9. Vision continued 10. Figure 1.1 USPS Master Plan Vision Diagram 11. The Big Moves 12. Location 13. Aerial View of Site 14. Figure 2.1 Site Boundary, Existing Views, and Access 15. Existing Site & Figure 2.2 Existing Zoning 16. Figure 2.3 USPS Master Plan Site location & Figure 2.4 Broadway and Lovejoy Ramps 17. Transportation 18. Overview 19. Figure 4.1 – Illustrative USPS Site Concept 20. Figure 4.2 – Maximum Building Footprints (attached) 21. Maximum Building Footprints 22. Figures 4.3, 4.4, 4.5, 4.6, 4.7, 4.8, 4.9. 4.10, 4.11, 4.12, 4.13, and 4.14 23. Alternative Maximum Building Footprints 24. Figure 4.15 – Building Envelope – Southwest View (attached) 25. Building Envelopes

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26. Figure 4.16 – Minimum and Maximum FAR Table 27. Minimum and Maximum Table 28. Figure 4.17 – Maximum Building Footprints 29. Building Envelopes 30. Figures 4.18, 4.19, 4.20, and 4.21 – Blocks 1A and 1B 31. Figures 4.22, 4.23, 4.24, and 4.25 – Blocks 2 and 3 32. Figures 4.26, 4.27, 4.28, and 4.29 – Blocks 4 and 5 33. Figures 4.30 and 4.31 – Block 6 34. Figures 4.32, 4.33, 4.34, and 4.35 – Blocks 7 and 8 35. Figures 4.36 and 4.37 – Blocks 7 and 8 36. Figures 4.38 and 4.39 – Block 9 37. Figure 4.40 & Development Footprint 9 Regulations 38. Figures 4.41 and 4.42 – Maintenance Easement Conditions 39. Broadway and Lovejoy Ramps 40. Figures 4.43 and 4.44 – Maintenance Easement Conditions 41. Broadway and Lovejoy Ramps 42. Figures 4.45 & 4.46 – Site Sections 43. Surrounding Context 44. Figure 4.47 – Active Use 45. Entrances and Activation 46. Figure 4.49 – Circulation Map 47. Proposed Streets 48. Figure 4.50 – Existing Pedestrian Circulation 49. Figure 4.51 – Proposed Pedestrian Circulation 50. Figure 4.52 – Existing Bike Circulation 51. Figure 4.53 – Proposed Bike Circulation 52. Figure 4.54 – Existing Vehicular Circulation 53. Figure 4.55 – Proposed Vehicular Circulation 54. Figure 4.56 – Parking and loading at grade to elevation 20’ 55. Figure 4.57 – Parking and loading above elevation 20’ 56. Figure 4.58 – On street Bike and Vehicular Parking 57. On Street Bike and Vehicular Parking 58. Figure 4.59 – Open Areas 59. Open Area Requirements 60. Figures 4.61, 4.62, 4.63, 4.64, 4.65, and 4.66 – Infrastructure Zones 61. Phasing – Infrastructure Zones 62. Infrastructure Zones 63. Figure 4.67 – Summary of Phasing/Development Triggers 64. Supportive Master Plan Materials – Overview 65. Figure 5.1 – Park 66. Figure 5.2 – Public Realm Axon 67. Open Areas – Surrounding Context 68. Figure 5.3 – Connected Open Space Axon 69. Connected Open Space 70. Figures 5.4 and 5.5 – Bridge Landing 71. Bridge Landing 72. Figures 5.6 and 5.7 – Elevated Alley 73. Elevated Alleyway 74. Figures 5.8 and 5.9 – Park Avenue Alley 75. Park Avenue Alley 76. Figures 5.10 and 5.11 – Park 77. Park 78. Figure 5.12 – Connected open spaces strengthen connection to the river 79. Surrounding Context: River 80. Figure 5.13 – Green Loop

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81. Building Massing: Green Loop Connection 82. Figure 5.16 – Response to Park 83. Figures 5.17 and 5.18 – Building Massing: Response to Park 84. Figure 5.19 – Open Areas 85. Figure 5.20 – Open Area Requirements 86. Figure 5.21 – Scenario 1b Shadow Study 87. Figure 5.22: Scenario 1a Shadow Study 88. Figure 5.23 Proposed Streets 89. Circulation – Proposed Streets 90. Figures 5.24 – Circulation 91. Circulation 92. Figure 5.25 and 5.26 – Johnson Street Section and Plan 93. NW Johnson Street 94. Figures 5.27 and 5.28 – Kearney Street Section and Plan 95. NW Kearney Street 96. Figures 5.29 and 5.30 – Park Avenue Street Section and Plan 97. NW Park Avenue 98. Figures 5.31 and 5.32 – Irving Street Section and Plan 99. NW Irving Street 100. Figure 5.33 101. Building Orientation & Massing – Inactive Uses and the Public Realm 102. Figure 5.34 – View of Union Station from Johnson Main Street 103. Building Massing – Johnson Main Street 104. Blank 105. Approval Criteria 106. Local and Regional approval criteria 107. Local and Regional approval criteria response 108. Housing Resources approval criteria 109. Housing Resources approval criteria response 110. Transportation and Infrastructure approval criteria 111. Transportation and Infrastructure approval criteria response 112. Transportation and Infrastructure approval criteria response 113. Transportation and Infrastructure approval criteria response 114. The Willamette River approval criteria 115. The Willamette River approval criteria response 116. Massing and Open Space approval criteria 117. Massing and Open Space approval criteria response 118. Massing and Open Space approval criteria response 119. Massing and Open Space approval criteria response 120. Resources approval criteria 121. Resources approval criteria response 122. Back page D. Notification information: 1. Request for response 2. Posting letter sent to applicant 3. Notice to be posted 4. Applicant’s statement certifying posting 5. Mailed notice 6. Mailing list 7. Revised Posting letter 8. Revised Posting Notice 9. 2nd Applicant Certification 10. Revised Mailed Notice E. Agency Responses: 1. Site Development Review Section of BDS

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2. Life Safety Division of BDS 3. Fire Bureau 4. Bureau of Transportation Engineering and Development Review 5. Bureau of Environmental Services 6. Water Bureau 7. Revised PBOT response a. Revised Transportation Study b. Adopted Community Equity and Inclusion Plan c. Transportations Demand Management Plan 8. Revised BES response 9. Revised Water Bureau Response 10. DRAFT MOU between City infrastructure bureaus and Prosper Portland F. Letters 1. Joe and Liz Lawlor, on February 4, 2020 with concerns regarding heights and blocked views. ([email protected]) 2. Kent & Lillian Brown, on February 5, 2020, with concerns that tall buildings will excessively shade the park and with traffic impacts. (937 NW Glisan #1030 Portland, OR 97209) 3. Linda Berry, including signatures of 50 residents of the Metropolitan Condominiums at 1001 NW Lovejoy, on February 6, 2020, with concerns that tall buildings will excessively shade the park and with traffic impacts. (1001 NW Lovejoy St Unit 806 Portland, OR 97209) 4. Reza Michael Farhoodi, representing the Pearl District Neighborhood Association, on February 13, 2020, indicating preference for: a podium between 7 & 8, a Block 1 configuration that maximizes solar access, a maximum footprint a Block 2 while preserving open space, activation of 9th Avenue, an iconic design at Block 7, language requiring sculpting of northern blocks to allow for penetration of light and air; and concerns with: the street plan and its relationship with bicycle facilities, the amount of proposed parking, and the potential for the open space to be delivered late in the overall development. ([email protected]) 5. Brendan Doyle, on July 29, 2020, with concerns regarding blocked views. ([email protected]) 6. Brendan Doyle, on August 1, 2020, wrote with concerns about lost views and questions about the design and review process. 7. Glenn Traeger, on August 7, 2020, wrote with concerns about traffic impacts. ([email protected]) 8. Reza Farhoodi, representing Pearl District Neighborhood Association, on August 13, 2020 wrote with appreciation for changes made since February 2020 but still with concerns about traffic impacts, noting shortcomings in the proposed TDM. G. Other 1. Original LUR Application 2. Staff Report for February 13, 2020 3. Additional Findings 4. February 13, 2020 Master Plan Drawing Set 5. USPS Broadway Corridor Master Plan Issues & Suggestions, February 13, 2020 H. Hearing 1. Staff Presentation, dated February 13, 2020 2. Applicant Presentation, dated February 13, 2020 3. Revised Staff Report and Additional Findings, dated August 6, 2020 4. Staff Memo, dated August 6, 2020 5. August 13, 2020 Drawing Set 6. Staff Presentation, August 13, 2020 7. Applicant Presentation, August 13, 2020 8. 2nd Revised Staff Report and Additional Findings, dated August 18, 2020 9. Testifier Sign-In Sheet