March 1, 2011
March 1, 2011
Below is a letter from Jonathan Schlueter, Executive Director of the Westside Economic Alliance, to the Oregon Land Conservation and Development Department regarding the Metro 2030 plan:
West Side Economic Alliance
Re: Objections to Metro 2030 Capacity Ordinance for Housing and Employment
Last month, Metro presented your agency with their forecasts and decisions to provide enough capacity for housing and employment in their tri-county jurisdiction through the year 2030. The adopted ordinance identified actions to be taken by Metro and local jurisdictions to supply at least half of the forecast housing needs identified in the region’s 2009 Urban Growth Report; declared the agency’s intent to add large-lot industrial capacity in 2011; amend the Regional Framework Plan which outlines Metro Council policies; and amend the Metro Code (Urban Growth Management Functional Plan) to implement regional policies.
As a party of record in these proceedings, with active participation in all phases of the capacity ordinance, members and staff of Westside Economic Alliance wish to assert our legal standing in these proceedings for the important implications these decisions hold for our members, constituents and communities.
Westside Economic Alliance is also affiliated with the Coalition for a Prosperous Region (CPR) and in that capacity, submitted additional written comments and oral testimony to Metro in these proceedings. Under separate cover to your agency, CPR will also be submitting comments and objections to these proceedings, with more specific attention to housing capacity, than time or space will allow here.
The objections and concerns offered by Westside Economic Alliance are prompted by two underlying considerations:
First, the Portland metropolitan region is the center of population growth, housing and employment opportunities, and economic development activity in the state of Oregon. As shown by the attached profile, over half of the personal income tax revenue collected by our state to finance public services throughout our state, is generated by jobs and payrolls concentrated in Oregon’s three largest counties.
The policy decisions outlined by Metro in the 2030 Capacity Ordinance will, there-fore, have widespread and significant implications for future growth opportunities and economic prosperity of our entire state. Before granting approval to Metro’s decisions and actions, Westside Economic Alliance asks LCDC to please give careful consideration to the assumptions and decisions contained in Metro’s ordinance, and have full confidence in these methodologies and assumptions.
Second, there have been substantial changes on the Metro Council since the capacity ordinance was compiled and approved last December. Metro President Tom Hughes, Councilors Shirley Craddick and Barbara Roberts will have to live and work in the shadows of the assumptions and decisions made by their predecessors, and deserve an opportunity to accept or amend these assumptions. A remand order from LCDC, based on any or all of the objections WEA lists below, will give the new Metro Council an opportunity to correct and improve their report.
Summary of Objections and Concerns
After more than a year of meetings, public hearings, and correspondence on the trends and projected capacity needs of their jurisdiction, Westside Economic Alliance and CPR continue to believe Metro has significantly misjudged future employment opportunities in the tri-county region, and has invited at least five objections from Westside Economic Alliance and CPR.
1. Metro assumes a continued decline of manufacturing employment in Oregon, to justify changes and reductions in the amount and location of employment land that will be needed in the tri-county metropolitan region.
2. Metro offers a bare bones response to address a long-standing and recognized need for large lot industrial development for future employment growth opportunities.
3. Metro relies on inconsistent and inflated inventories of developable land inside the UGB and existing communities to meet the region’s need for housing and jobs.
4. Metro assumes future housing and employment growth will be concentrated near existing urban centers and infrastructure services, to limit needs for future UGB expansion.
5. Metro’s ordinance encumbers Goal 9 compliance requirements imposed on local jurisdictions
A Different Perspective Presented By Westside Economic Alliance
1. Metro assumes a continued decline of manufacturing employment through 2030.
Metro’s urban growth report and capacity ordinance assumed a troubling decline in manufacturing employment during the next 20 years, with a gradual shift to health care jobs, finance and professional services. If these projections prove true, the Portland region would need less land for manufacturing facilities, as future employment opportunities concentrate in the urban centers and along urban transit corridors.
WEA finds at least three serious errors with these assumptions:
First, Metro has apparently relied on national and statewide manufacturing data to base their 2030 forecasts for employment in this region, when local experience tell a very different story.
Second, Metro equated employment trends with productivity and profitability, and assumed (incorrectly) that gradual declines in manufacturing employment signaled a continuous decline in the manufacturing sector, and less demand for large, industrial sites and facilities.
Third, Metro has overlooked or ignored recent findings by national and local research firms, which challenge and dispel these first two assumptions.
Oregon has always led the nation with a larger dependence on manufacturing than other parts of our country, and continues to expand and diversify this manufacturing base to serve eager consumers in evolving markets around the world. Metro and LCDC must both recognize that Oregon ranked 5th among the 50 states in terms of manufacturing output in 2008, with an estimated $30.2 billion (18.7%) of our state’s gross domestic output currently tied to manufacturing, with well over half of this output coming from Metro’s tri-county jurisdiction.
In their most recent (2010) Prosperity Index, Greenlight Greater Portland, an economic development consortium serving 7 counties in the PMSA region, forecast our region will lead 10 competing western metropolitan areas in creating manufacturing employment opportunities in the next five years, adding 11.2% new jobs primarily in semiconductors and electronics, renewable energy and transportation equipment, sportswear and apparel.
Since Metro adopted the 2030 Growth Ordinance, President Barack Obama has called for a doubling of American exports in the next five years, and Oregon Governor John Kitzhaber called on Oregon companies and Oregon ports to take advantage of our proximity to emerging foreign markets and lead the way to economic recovery. But will Metro’s restrictive growth ordinance allow our state to meet these challenges, and contribute to our nation’s recovery?
Members of Westside Economic Alliance have been meeting these challenges with record production, record earnings, and sizable expansion and private sector investments being reported by Intel, Nike, IBM, Columbia Sportswear, TriQuint, SolarWorld and SoloPower, Genentech, Boeing, to name just a few. The continued success of these companies offer a welcome opportunity to expand and diversify Oregon’s manufacturing base for years to come, and challenge Metro’s assumptions about manufacturing employment in our region.
2) Supplying Large Lot Industrial Sites For Future Employment
Metro deserves recognition and praise for at least acknowledging the long-standing shortage of large lot industrial areas for future employment opportunities in the tri-county region. Westside Economic Alliance has been calling attention to this serious shortage for many years, and remains concerned our region is missing out on significant new employment opportunities, because of a chronic shortage of developable space.
Metro’s urban growth report identified a need for 200-1500 acres of developable industrial land during the next 20 years, but the agency has recommended only 310 acres be designated for large lot development as part of their 2030 capacity ordinance. WEA believes these projections are unrealistically low, and unreasonably limit economic growth opportunities for our region and state at a time when we cannot afford to be timid.
3) Metro relies on inconsistent and inflated inventories of developable land and facilities
To support the 2030 Capacity Ordinance, Metro’s regional map depicts West Hayden Island, Portland International Airport, Colwood Golf Course, and the Columbia River slough in North Portland as “regional significant industrial areas.” But six months earlier, when Metro was crafting the “urban and rural reserves” and “Making The Greatest Place,” many of these same areas were being depicted as future park space and wildlife habitat.
Metro also assumes future growth for housing and jobs can be accommodated through infill, refill, and rehabilitation of brown fields or other problems sites. Yet the capacity ordinance offers little explanation or reassurance about the types of housing or jobs that will be created in these areas, how they should be financed, or if there is market demand for these heroic ambitions. If these assumptions are wrong, WEA worries future growth will merely “leap over the donut” created by our UGB, as homeowners, employers and their workers migrate to more realistic opportunities in neighboring counties and states outside Metro’s jurisdiction, taking their tax contributions with them.
In oral and written testimony submitted to the Metro Council on December 2, 2010, WEA challenged Metro’s assumptions and questioned whether the current regional inventory of developable industrial employment sites inside the UGB was even available or realistic for future development.
In the two months since WEA presented that testimony, SoloPower has committed to occupy one of only three vacant industrial buildings in the Portland region offering >200,000 sq. ft. under one roof; the Beaverton School District has been actively searching for any suitable site for a new high school to serve its rapidly increasing enrollment; and a landmark LUBA decision rejected the City of Portland’s controversial River Plan, citing concerns the city’s efforts to restore environmental resources and wildlife habitat in the Portland harbor would further restrict industrial growth and Port activities. The LUBA decision requires Portland and other jurisdictions to give equal consideration to economic growth and development opportunities, by their actions.
4) Metro assumes future job growth will occur near existing urban centers.
Here, Metro offers little explanation or reassurance about how this region will reverse long-standing national industry trends that have shifted jobs away from major urban centers.
A December 2010 report, commissioned by four prominent business organizations—and released the day before Metro’s capacity ordinance was approved last December—challenged the assumptions that future employment growth will conveniently occur in the center of the Portland metropolitan region. The revealing “2010 Checkup on the Portland Region’s Economic Health,” ranked Multnomah County second to last—198th among 199 western counties—in terms of private sector jobs growth between 1997-2009.
A 2009 study by The Brookings Institute, ranked Portland #47 among America’s 98 largest cities for the percentage of jobs in a 3-mile radius of our urban center and 38th nationally for the percentage of jobs in a 35-mile radius of our urban center. Despite Oregon’s iconic land use planning policies, The Brookings report found 17 of 18 private sector industry sectors had decreased employment in the urban centers of 95 cities between 1998-2006, and identified only three metro regions of the country that managed to increase employment near their urban core. Metro offers little explanation—and no incentives—or ways to reverse these national trends.
LCDC should determine whether Metro’s vision for “vibrant communities” extends equally to all cities in this tri-county region, and whether Metro’s decisions and assumptions for future housing and employment will contribute to the viability of all communities in their jurisdiction.
5) Metro’s ordinance encumbers Goal 9 compliance requirements imposed on local jurisdictions.
As the regional planning agency for the Portland metropolitan region, Metro has maintained it is not bound by the economic development provisions embodied in Goal 9. But in light of the recent LUBA decision challenging the City of Portland’s River Plan, we question whether your Commission still accepts this claim.
To the extent that Metro controls the regional land supply, and allocates future growth opportunities by assigning expansion areas for local jurisdictions to expand and develop, adherence with Goal 9 seems appropriate.
To the extent Metro also controls the regional purse strings and allocates regional funding for transportation projects, and from a regional construction excise tax to pay for local concept planning, Metro directly influences local community’s compliance with Goal 9.
And because Metro has permanently “protected” an estimated 12,000 acres from urban development, using regional funding approved by voters in 1996 and 2006 to acquire regional park space, open space, wildlife habitat, and water resource protection areas, Metro is directly competing with local jurisdictions for developable inventory and tax base, further limiting the ability of these communities to comply with Goal 9.
At a time when our region can least afford to be cautious or timid, Westside Economic Alliance believes Metro’s 2030 Growth Plan and Capacity Ordinance will further restrict job growth and economic opportunities in the Portland region for generations to come. As the economic engine of the state of Oregon, the actions and decisions taken in this region have a direct and significant influence on the entire State of Oregon. Metro can no longer be allowed to restrict and reduce the economic opportunities of our state by adopting this capacity ordinance, without first addressing and correcting the deficiencies and omissions listed above.
For additional information about the objections outlined in this filing, or the supportive materials attached and enclosed herein, WEA invites you to contact:
Westside Economic Alliance
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