This process typically occurs largely behind closed doors with industrial landowners, developers, and a small cadre of consultants who move back and forth between representing the City and representing business interests. Historically, outside of Portland Audubon, the community at large has paid little attention. That needs to end because the EOA has huge implications for the health of our environment and our communities, and how our landscape develops over time. We are calling on the Bureau of Planning and Sustainability and Portland City Council to ensure that this EOA update is inclusive, transparent, and responsive to impacted communities from start to finish.
Why should we care about the EOA? Under Statewide Land Use Planning Goal 9 (Economic Development), municipalities must maintain a twenty-year supply of industrial land. They demonstrate compliance through an EOA in which a forecast of industrial land demand is compared to an inventory of developable industrial land. If demand exceeds supply, a municipality must demonstrate how it is going to find land to fill the deficit. In a city like Portland that has no room to expand, that is a big deal.
For the past three decades, industrial interests have insisted that the city lacks an adequate industrial land supply, especially along the Willamette River and Columbia Slough. They have been able to get this alleged deficit validated through the secretive EOA Process. They have then leveraged this deficit to effectively oppose new environmental regulations on industrial land and demand the open space be converted to industrial use. While the EOA is a wonky and esoteric process, its implications are very real.
In 2008, after nearly a decade of work, Portland City Council adopted the North Reach River Plan—a long-term plan for environmental restoration, river access, recreation, and jobs in Portland Harbor. Industrial interests proceeded to challenge the plan on the basis of the EOA and the plan was thrown out. The City has never attempted to bring it back. In 2011, under threat from industrial interests to challenge the plan on the basis of the EOA, the City made a last-minute decision to exempt industrial lands from the City’s tree code. In August of 2020, City staff recommended continuing this exemption, again on the basis of the EOA. In 2016, when the City last updated the EOA, it changed the City’s comprehensive plan to allow designated open space on portions of golf courses to be converted to industrial use in order to fill the industrial land deficit. The public is just becoming aware of the implications of this decision now; in August 2020, Broadmoor Golf Course along the Columbia Slough was sold to an industrial developer who will convert the front third to industrial use. To add insult to injury, because the tree code does not apply on industrial land, the developer will be able to cut hundreds of large trees with absolutely no accountability or mitigation.
The City’s approach to the EOA is deeply flawed. First, the industrial land deficit, to the degree it exists at all, is largely the result of land conversion by the very interests that then claim there is a deficit. Industrial developers should not be able to upzone land for commercial and residential development in order to increase profits and then turn around and oppose environmental protection on the basis of an inadequate industrial land supply. Second, the facts simply do not support the assertion that there is a deficit of industrial land currently in Portland—the Port of Portland has been unable to fill shovel-ready industrial land at Terminal 2 and Terminal 6 for years and is now proposing to convert Terminal 2 for a baseball stadium and commercial and residential development. Third, the argument that converting acres of natural area and openspace to industrial use will enable the City to meet job targets is false. The fact is that river industrial jobs have been declining for years due to automation, transference of jobs overseas, and the impracticality of Portland functioning as a Port, 100 miles from the ocean. It is notable that even when the City converts openspace for industrial use, it places no expectation on those acres in terms of job creation.
Portland Audubon has fought a long and lonely battle over the EOA. We have had some significant success. In 2015 we successfully advocated for the City to shift the focus of meeting industrial land demand from openspace conversion to cleaning up more than 900 acres of contaminated brownfield within city limits, intensifying use of the existing industrial land base and limiting conversion of existing industrial land for other uses. We also got West Hayden Island, the City’s largest unprotected greenspace, removed from the industrial land inventory. However, we must go further.
It is long past time for an open, transparent, and inclusive EOA process: one in which the public is engaged right from the start, where historic assumptions can be challenged, a broader set of community-driven questions explored, and a more holistic analysis developed that meets the needs of the whole community. Jobs are absolutely critical, especially blue-collar jobs, but for far too long the EOA has been wielded not as a vehicle to create jobs, but rather as a weapon for industrial interests to effectively oppose environmental protection and other community priorities and to grab openspace for their own economic benefit. It is time for the EOA to emerge from back rooms and into the full light of a community-based process.