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Chapter 8: Periodic Review—A review of State requirements for updating Portland's planning program

Keeping Portland's Comprehensive Plan Up to Date


The Planning Bureau's Mission is to, "assist the people of Portland in achieving a quality urban environment through comprehensive planning that responds to the changing needs and values of the community."


Community needs and values change, so plans should change along with them. The attributes of a "quality urban environment" are best informed by current community values. Portland's Comprehensive Plan was never meant to be static.


Portland's Comprehensive Plan was informed by the values of the 1970s. The plan was adopted by the City Council in 1980, and it was approved by the state in 1981. The plan has been updated many times, in small and large ways; but never as a whole.


The term "comprehensive plan" has a particular meaning in Oregon law.  The City is free to include more in its plan than the state requires, but not less. At a minimum, Portland's plan must:

  1. Address the requirements of Oregon's statewide planning goals;

  2. Apply to the whole of the City limits, plus an adjoining Urban Services Boundary; and

  3. Meet anticipated employment and housing needs for the next 20 years.

Comprehensive Plan Components


Portland's plan is made up of three types of components:

  1. Statements;

  2. Maps; and

  3. Projects.


Plan statements are further divided into "goals, policies, and objectives." Some of these statements apply city-wide, while others apply to only the parts of the city benefiting from a neighborhood, community, or other special area plan. Some parts of the city have no supplemental plan.


[Click on map to enlarge or download]



The Plan Map depicts permitted land uses in five broadcategories:

  1. Open Space;

  2. Residential;

  3. Commercial;

  4. Employment; and

  5. Industrial.

All but the Open Space category are further divided into levels of intensity. The type of use allowed plus its intensity form a map "designation." The City's official zoning map must be derived from these designations. A zone may allow less than a designation, but not more. When a zone allows less, this means that infrastructure is not yet available to support the type or intensity of use desired at the end of the 20-year planning period.


Plan maps also depict street classifications and design types. Portland's plan tightly integrates transportation classifications and land use designations.



Road, water, and sewer projects needed to support the development pattern depicted on the Comprehensive Plan Map must be included on a "significant Projects List" within the Comprehensive Plan. The transportation project list has been updated regularly; other project lists have not been updated since 1989.


Minor Changes and Major Revisions


Portland's Comprehensive Plan has been changed many times. Most of the changes have been small, involving redesignation of particular parcels on the plan map, or the addition or amendment of plan statements. Minor changes occur regularly and have had the character of plan maintenance rather than update.


The purpose of planning—to be intentional about policy choices and their underlying assumptions—can be undermined by too frequent change. Travel is an analogy. To reach a stated destination, progress must be monitored and course corrections applied; but only as needed. Minor plan changes are the equivalent of major course corrections. In 1980 it was envisioned that minor comprehensive plan changes would be made no more frequently than once per year.


Major revisions involve revisiting underlying assumptions and revalidating or adjusting policy choices. To return to the travel analogy, newer or better information may allow the plotting of a safer or quicker course. In 1980 it was envisioned that major comprehensive plan updates would happen about every five years; the plan would be accomplished by the year 2000; and then it would be time to do a new plan.


The concept of major revisions and minor changes is described in the Statewide Planning Goal 2 guidelines. Whether major or minor, plan changes never happened as originally intended.


History of Plan Changes


Annual Review and Periodic Revisions

City policy in 1980 called for the Planning Bureau to prepare an annual report on plan implementation. This report was to be presented to Planning Commission during an annual hearing on the Comprehensive Plan. The report and the hearing were to inform the commission's decision of what minor changes to recommend to City Council. During the recession of the early 80s, planning staff and workload was reduced. Council deleted the annual report policy from the comprehensive plan as a cost savings measure; but retained the hearing policy. This is the action, along with the emerging practice of amending the plan more often than once a year, that is the cause of the present confusion of what the annual Planning Commission hearing is for.


In 1980, major revisions were expected every five years. This changed because the 1981 and 1983 legislatures made new law on how a city could change its plan after it was approved or "acknowledged" by the Oregon Land Conservation and Development Commission. The concepts in Statewide Planning Goal 2 were loosely followed with minor transforming to "Post Acknowledgement Plan Amendments," and major to "Periodic Review Work Tasks." A plan amendment did not require prior state approval to become effective, but a city plan amendment could be reversed or remanded later by petitioning the Oregon Land Use Board of Appeals for review. Periodic review work tasks required the prior approval of the Oregon Land Conservation and Development Commission to become effective.


Two things were lost in the transition of plan update provisions from goal to statute - limits on frequency of change, and process distinctions between major and minor. The legislature considered, but did not adopt, restrictions on the number of times a local government could enact a "Post Acknowledgement Plan Amendment" within any given year. There were also no restrictions on processing a major comprehensive plan revision as a "Post Acknowledgement Plan Amendment" or adopting a minor change as a "Periodic Review Work Task."


Portland's practice has been to follow the statutory method of plan amendment; while retaining some aspects of the displaced Statewide Planning Goal 2 method as plan policy within the administrative section of its comprehensive plan. This has proved confusing to careful readers of our plan.


Early Follow-up Work

The first changes to Portland's plan were required by conditions of the Oregon Land Conservation and Development Commission's May 1981 acknowledgement order. Portland had adopted a plan that easily met the development requirements of the Statewide Planning Goals, but one that was arguably week on conservation. The state commission had the choice of delaying approval of Portland's plan pending improvement, or conditioning approval of subsequent changes. The commission chose the latter approach, and the City responded by adding environmental policies to its plan as Post Acknowledgement Plan Amendments.


Community Planning

By the mid 1980s it was obvious that the large state and federal grant programs that supported the development of Portland's plan in the 1970s were vanishing. A complete update of the entire city-wide plan was not feasible with City resources alone. The successful completion of the Central City plan became the model for would become know as "community plan areas." The central city was posthumously anointed as the first of these areas, and seven others were identified. At any given time, the Planning Bureau was to be just beginning, in the midst of, and just completing a community plan. In 20 years, all eight areas comprising the entire city would be planned; and then it would be time to start the rotation again.


Community plans were to have companion neighborhood plans, and strong design elements. A new design goal and new policies were added to the Comprehensive Plan to herald this approach. The Albina Community Plan followed this outline closely. But the 1990s brought the opposite problem of the 1980s, the economy was booming and development activity was at a 75-year peak. There was constant pressure to reassign planning staff to development review to keep up with a burgeoning case load. Reassignments meant the Outer Southeast Community Plan solved fewer design problems than its predecessor. The Inner Southeast Community Plan was terminated before completion, and the Southwest Community Plan became limited to a general policy framework and revised land use map, with no adopted neighborhood plans. Dissatisfaction in southwest Portland led to the termination of the entire community planning program. The policy calling for community planning does, however, remain in the comprehensive plan.


The River Renaissance shares some approaches and methods with community planning: detailed background assessments; development of a coherent policy framework; and area specific planning to be completed in phases.


Regional Design Type Implementation

The most significant planning event in the 1990s was that our regional elected government, METRO, received a voter-approved home rule charter authorizing regional planning. Metro used this authority to adopt the "Region 2040 Growth Concept" comprised of a hierarchy of nodes intersected by corridors. The nodes became "centers" with the central city being the largest, and "station communities" the smallest. Many of the corridors were to become "main streets" with a mixed-use development pattern and aesthetic inspired by the streetcar era of the 1920s.


In many ways the regional growth concept map supplemented Portland's comprehensive plan map, and in some cases actually superceded it. Before its demise, the community planning program was adjusted to respond to the obligation to conform Portland's plan to regional requirements. These efforts continue throughout the city. Sometimes this planning may focus on a single main street or center. The largest of these efforts is the central city assessment.


Functional Updates

There have been several updates of entire policy areas within Portland's plan through combined or stand-alone projects. A new design element was added in conjunction with the Albina Community Plan, and the following elements have been either completely revised or significantly expanded: housing, economy, environment, energy, and transportation. Since it is required for state and federal public works funding, the transportation element is revised most often.


Quasi-Judicial Map Changes

Portland allows changes to its comprehensive plan through an application process, but this process only applies to the plan map. Changes are usually initiated by a property owner for a particular parcel. Because of the narrow focus and incremental nature, it is difficult to assess the cumulative effects and reasonable alternatives to changes proposed by application. Although there is no limit to the number of quasi-judicial changes that may be considered in a year, a steep application fee and strong plan policies requiring "no net loss" in housing potential and no intrusion into industrial sanctuaries, tend to minimize the number applications received.


State Periodic Review

As outlined above, the Oregon Legislature enacted periodic review requirements in 1981 and Portland has been through them once, beginning in 1987 and ending in the year 2000. This was a long time for a process that was only supposed to take two years. The state purportedly "reformed" and "streamlined" periodic review three times while we were in it.


Periodic review is problematic because it is largely an "unfunded mandate." The Oregon Legislature appropriates only a fraction of the funds needed to update city and county plans. The other big problem is the need; there are almost 300 cities and counties in Oregon that are required to have and maintain a comprehensive plan. Even though local governments are allowed to band together and "share" a common plan, none have chosen this course. So, even if periodic review were fully funded, the Oregon Land Conversation and Development Commission would never have enough staff to review all the resulting changes.


The history of period review has been repeated efforts to limit its scope. The Oregon legislature has excused small cities from periodic review; and the Oregon Land Conservation and Development Commission has adopted a rule establishing three thresholds factors:

  1. Work identified, but deferred, when the state first approved a local plan;

  2. Work required by mandates that did not exist when the state first approved a local plan; and

  3. Work required because an important assumption or fact upon which a plan is based has proven wrong or become obsolete.

Portland's 1987–2000 periodic review was based on the second threshold factor. The City had already completed its deferred work, and the recession meant that then seven-year-old capacity assumptions still held true. The new mandates were state administrative rules requiring a protected system of open spaces, natural areas, scenery and views; and public facilities plans and project list. While the city already had adopted plan policies calling for this work to be done, putting it in place took longer than either the City or state first imagined.


Portland's Next Periodic Review


After the year 2000, the Oregon Legislature placed a temporary moratorium on periodic review, and stretched the time frame from five years since the last review was completed to seven. The moratorium expires July 1, 2007; and Portland is among the first group of jurisdictions required to go through the re-start of periodic review. The legislature also made comprehensive planning less comprehensive by limiting periodic review to matters concerning economy, housing, public facilities, and urbanization. Portland's first periodic review addressed both conservation and development; the second will be limited to development issues.


The period review threshold factors stay the same, as do the three phases of periodic review:

  1. Self evaluation;

  2. Work program development; and

  3. Completion of approved work tasks.

The Planning Bureau will review and identify the fresh and stale components of our plan. Updates will be proposed in a draft work program presented to the City Planning Commission and must be approved and transmitted to the state by Council ordinance. The state may reject, approve, or modify and approve the work program. The City will have three years to complete the work program. The City will be eligible for a grant to cover a fraction of the work involved.


The work is likely to be driven by threshold factor three: important assumptions or facts have proven wrong or become obsolete. Our official plan assumptions are now 26 years old, and were only designed to serve for 20 years. While we do have better information on most of the required periodic review subjects, we have yet to adopt it as part of our comprehensive plan or as the other permitted alternative, an official comprehensive plan "supporting document." Likely work products will be an economic opportunity analysis, residential buildable lands inventory, housing needs analysis, updated public facilities plans and project lists, and a demonstration that Portland can accommodate the jobs and housing growth allocated by Metro. This work may require adjustments to the plan map or policies.


Our first step will be to identify a public involvement process both sufficient and suitable for this large undertaking.




  1. Do our three plan components—statements, maps, and projects—comprise language adequate to describe our desired "quality urban environment" 20 years hence?

  2. If not, what is missing?

  3. Are existing plan components misused, overused, or underutilized?

  4. Should the City self-impose limits on plan amendment frequency?

  5. How can we be sure that small and incremental plan amendments stay on course and add-up to a larger coherent whole?

  6. Should we continue to amend and update our current plan, or start all over again with a new plan?

  7. Should the City's plan be more explicit about the parts of the city that are likely to remain comparatively unchanged, and those where significant redevelopment is a real possibility?

  8. Since continuity and change both play important parts in a "quality urban environment," what is the right mix?

  9. Whatever we decide in the questions above, is our next periodic review likely to advance or hinder our objectives?




Chapter 1: Overview | Chapter 2: People | Chapter 3: Place | Chapter 4: Economy


Chapter 5: Civics | Chapter 6: Planning | Chapter 7: Questions | Chapter 8: Review


Respond to the Questions from the Comp Plan Context Chapters