S2HC Frequently Asked Questions (FAQs)

Two tiny homes with colorful paint and pallets for front porches
The Shelter to Housing Continuum (S2HC) projects address the urgent need to provide more options for those who are homeless or could potentially experience homelessness, and facilitate transitions to permanent housing for housing-vulnerable Portlanders.
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The original S2HC project was adopted in April 2021. S2HC proposed amendments to City code to allow needed emergency shelters, day storage and hygiene facilities, transitional living facilities, and stable housing for individuals and households with extremely low incomes. S2HC also improved how the regulatory environment affects for-profit, nonprofit, and public sector shelter and housing providers.

The S2HC changes included four elements:

  1. Code changes to make it easier to site homeless shelters and associated services in various zones.
  2. A new community service use in the Zoning Code called “outdoor shelter.” This adds to the types of shelters already addressed in the Zoning Code and allows public agencies and community-based nonprofits to open more shelters like the Kenton Women's Village or St Johns Village. Until the S2HC amendments were adopted, outdoor shelters required code exemptions from City Council one at a time. The adopted code provides a more routine path to permit these kinds of facilities based on emerging alternative shelter models around the city.
  3. Increased housing flexibility by allowing group living configurations more broadly. The project further legalized single-room occupancy (SRO) units in some zoning districts and removed the conditional use requirement, streamlining the review process for many regulated affordable housing projects that incorporate SROs. This means that alternative types of housing such as dormitories, senior care facilities, co-housing, and single-room occupancy apartments will be easier to build.
  4. Allows occupancy of a recreational vehicle or a tiny house on wheels on residential property.

The Shelter to Housing Continuum – Part 2 (S2HC2) is a follow-on project to the original S2HC project that proposes several refinements based on the initially implemented code language adopted in 2021.

These FAQs address important topics about the adopted project and proposed refinements.


What is this project about?

The project changes a variety of City codes to help partner agencies (the City-County Joint Office of Homeless Services, Housing Bureau, Bureau of Development Services) and nonprofits (e.g., Central City Concern) provide safe and decent shelter and more affordable housing for those in need during this crisis of homelessness.

What is the difference between “shelter” and “housing”?

Shelter is a community service provided by government agencies or nonprofit corporations to help people experiencing homelessness. A “host” provides shelter and services to a “guest” or “client,” who is supported as they transition to housing.

Housing is residency established under landlord-to-tenant relationship or by ownership. The zoning code categorizes housing as a residential use and shelters as a community service use.

What is considered a “dwelling unit”?

A dwelling unit is a building or a portion of a building that has independent living facilities, including provisions for sleeping, cooking, and sanitation (a bedroom, kitchen and bathroom).

What are “allowed uses” and “conditional uses”?

The zoning code categorizes land uses as allowed, conditional and prohibited. Allowed means a permit can be issued for the use without any public process or hearing. Conditional means that there must be public notice and an opportunity for a hearing. Prohibited means a permit cannot be issued.

Why did the S2HC project eliminate the regulation about the number of people allowed to live in a dwelling unit?

  • The existing definition of Household was outdated and did not reflect the range of living arrangements today.
  • The definition was also unenforceable because, in some cases, it relied on proving a blood relationship between household members.
  • Other City codes already have limits on the number of people in a building based on bedrooms and square feet. It was not necessary to also regulate the number of occupants in the zoning code.

How does this project relate to the City’s inclusionary housing rules that require a percentage of affordable units in new apartments and condominiums?

Inclusionary housing (IH) requirements require a percentage of affordable units in new development with more than 19 units. While adjusting group living housing regulations, the S2HC project was careful to neither expand nor contract IH requirements. Inclusionary housing requirements do not apply to shelters.

Are shelters allowed in parks and open space zones? Why or why not?

Neither project allows for shelters to be permanently located in open space zones because:

  • Open space (OS) zones often include environmental resources that should not be disturbed.
  • Parks and open space have often been purchased with bond money limited to specific purposes or were given to the City with deed restrictions, often stipulating they must be used for parks, recreation or open space purposes, which doesn’t include housing, shelters or other types of development.
  • Shelters are allowed to temporarily locate in parks and open space for no more than 180 days.


The adopted S2HC regulations:

  • Expand where shelters are allowed without conditional use.
  • Increase the allowed number of shelter beds in the CM2 (commercial/mixed use) and CI2 (campus/institutional) zones.
  • Clarify that clients may stay longer than 30 days in short-term shelters.
  • Add a new path for permitting outdoor village-style shelters so they do not have to be authorized one at a time by Council code waivers.
  • Facilitate more rapid opening of seasonal or weather-related temporary facilities.
  • Allow day storage and hygiene facilities.
  • Allow institutions (such as churches and schools) to provide meal programs, shelter and related services.

The proposed S2HC2 regulations:

  • Streamline the outdoor shelter rules to make it easier for shelters to be permitted.
  • Clarify the rules for shelters operated as temporary activities.

What are the three shelter types and how do they differ?

No single shelter type or shelter model can solve this crisis alone. These different types of facilities serve different types of clients.

  • Outdoor shelters (new to the Zoning Code with S2HC1) are organized groups of tents or other accommodations that do not qualify as buildings. Supportive hygiene, storage and kitchen facilities could be in accompanying buildings. Shelters must be operated by a public agency or a nonprofit. The state of emergency helped us develop alternative outdoor shelter models like the Kenton Women’s Village and the St Johns Village. These village-style shelters appeal to people who are more comfortable with smaller and more intimate settings. These communities empower participants to help and care for one another.
  • Mass shelters are in buildings but do not provide individual bedrooms. Examples: Laurelwood Center, Harbor of Hope, Willamette Center and Bybee Lakes Hope Center.
  • Short-term shelters provide individual bedrooms. Bathrooms or kitchens may be shared or private. Examples: Multnomah County Behavioral Resources Center.

Where are the new outdoor shelters allowed?

  • Smaller shelters are allowed by right in commercial, multi-dwelling, and employment zones and in higher-density residential zones on institutional sites.
  • Larger shelters are permitted as conditional uses.
  • There is a limited allowance with a conditional use review in industrial zones.
  • Shelters can also be allowed temporarily or seasonally anywhere – with permission of the landowner – but for no more than 180 days.
  • The City also retains flexibility to site temporary shelters anywhere without a conditional use for longer periods of time in response to disasters, such as the COVID-19 emergency or in the aftermath of an earthquake.

Does this project allow people to continue to camp in parks and on sidewalks and along streets?

No. Informal camping remains prohibited, but this prohibition has not been strictly enforced during the COVID-19 emergency. It is unkind to direct campers to leave parks, sidewalks and roadsides unless there is another place they can safely shelter. This project provides more sanctioned alternatives to informal camping.

Why not allow vacant lots or empty buildings to be used for shelter?

Many vacant lots and buildings will qualify as shelter sites. But sheltering on any site requires the permission of the landowner, including public landowners like the City of Portland.

Instead of increasing allowances for shelters, why doesn’t the City build more affordable housing?

The City is doing both. Shelter is a “front door” to services that help transition people to housing. This continuum strategy allows more options for the City to meet people experiencing homelessness or housing insecurity where they are at and begin a transition to stable housing. In the meantime, City and Metro bond money is being used to build more affordable housing.

Location and staffing of new shelters

Where are existing encampments in the city now?

The dots on this map represent reports received from the community by the City’s Homelessness and Urban Camping Impact Reduction Program over the past three months. These are not “official” City counts; the dots represent “reports of campsites received.” Also, a dot could mean one tent, or it could mean 75 structures.

How are decisions being made about where new shelters will be located?

For shelters funded with public dollars, the City of Portland/Multnomah County Joint Office of Homeless Services (JOHS) would make that decision. These decisions are made based on available resources to support any new shelter program for adults, families, youth, and domestic violence survivors, including rental assistance, support services, workforce training and street outreach.

The Joint Office begins with the need it’s trying to fill, e.g., 80 to 120 beds for adults or more space for families seeking shelter. It then looks at the parts of the County where there is an unmet need for shelter. And within those areas, it looks for suitable land use zones.

The Joint Office looks for properties that offer the best combination of size, layout, and condition for use as a shelter. Also important are nearby features, such as regular public transit, community amenities, educational resources, recreational opportunities, and social services. Just like people in permanent housing, shelter participants rely on, and want to live near libraries, transit lines, medical offices, and grocery stores.

Participants also benefit from being close to affordable housing opportunities, as well as educational, employment and social services. Ease of access to those connections is especially important for the growing number of people in shelter who are 55 and older or who have disabling conditions or mobility challenges. Those community connections simply wouldn't be possible if people are sheltered in remote locations far from community.

This thorough process yields very few viable sites. And once one is found, the Joint Office must determine whether the property is actually available, for how long, on what financial terms and, ultimately, if it is a feasible site for a shelter. Once a shelter site is obtained, the Joint Office then works with an expert shelter operator to run the shelter.

The JOHS continues to add shelter facilities, from the Pearl District, St Johns, and Kenton to Lents and Mill Park. View a map of all shelter facilities in the City of Portland and Multnomah County.

Did the Bureau of Planning and Sustainability do any sort of ranking or analysis that indicates the relative value of any specific plot of land?

No. Our analysis was simply to determine how much land was zoned to allow shelters.

What does a typical shelter look like?

The Joint Office operates different shelter systems for families, unaccompanied youths, domestic violence survivors and adults, with more than 1,300 year-round beds. All the shelters are open 24 hours and reservation-based, with people offered beds as long as they need them. That means no one has to line up for a bed at night or leave in the morning. All Joint Office shelters are staffed and supported by experienced nonprofit agencies, which provide services on site. Many offer full kitchens and clinic space as well as classrooms, computer labs, office space, laundry, showers and bathrooms.

Adult shelters in traditional facilities provide bunkbeds, with beds divided into sleeping bays by walls instead of mats on the ground in large rooms. Alternative shelters offer individual sleeping pods with electricity and heat as well as common spaces such as bathrooms, kitchens, and offices on site. Guests can bring their pets and store their belongings. Couples can sleep next to one another. Secure outdoor space is provided for people to gather and breathe fresh air. In family and domestic violence shelters, families receive their own rooms.

People in all shelters are required to abide by codes of conduct. Shelter providers are expected to attend neighborhood meetings and provide 24-hour points of contact for the community.

Is there any guarantee with this project about the amount and size of shelters allowed within a neighborhood, to ensure that shelters are spread out within a neighborhood?

No, not in the proposed code. The purpose of the project is to remove regulatory barriers to shelter siting. The Joint City/County Office policy is to place shelters where there is a need, and that need is currently citywide. The financial resources to build new shelters are limited (as written above), so that is much more of a limiting factor than zoning. Year-round shelters managed by the Joint Office top out at 120 beds each, a size that makes a space cost-effective to operate while still being small enough to staff and manage successfully.

Are there any guarantees that shelters will be geographically balanced across town?

The track record over the past seven years shows that new public shelters have been spread out across the city. That’s because the Joint Office has been working to fill gaps and expand a shelter system that for years was concentrated only downtown and in the central eastside. When asked how shelters could be easier to access, people with lived experience said having to leave their neighborhood and communities to travel across town was a barrier.

By adding shelters in areas where there is unmet need, instead of concentrating shelters in any one part of town, whether that’s outer east Portland or downtown, the Joint Office can better meet the community’s needs overall. Four of the eight most recently opened non-COVID-emergency shelters, for example, have been in North, inner Northeast, Northwest Portland – areas with unmet need and fewer existing services.

Is there any guarantee that particular neighborhoods will not have a disproportionate number of shelters?

The intent of the project was to reduce regulatory barriers. See the answers above for how the Joint Office approaches shelter siting.

Who runs these facilities? Is there onsite supervision? What kinds of services/facilities are included at each site?

Like any other business or program, shelters must be well run to succeed, not just for their neighbors but for their participants. The Joint Office holds its shelter operators to high standards and supports them to ensure their success, resulting in a track record of opening shelters across the community.

There have not been significant issues with crime or other concerns because of these shelters. Some shelters sit on commercial strips. Some are next to residences, near schools and parks. After these shelters have opened, community members have come together to celebrate and support their new neighbors through activities, volunteering, and donations.

Group living

The regulations adopted with S2HC:

  • Provide parity between household and group living by allowing group living arrangements by right in the same places that household living is allowed by right.
  • Remove code complexity and barriers to the production or retention of group living arrangements.
  • Simplify definitions to clarify the difference between housing and shelter, group living and household living.
  • Eliminate the definition of “household” but continue to regulate residential use as either household living or group living.

What is group living and how is it different from houses or apartments that are rented?

  • Most resident uses are classified as household living.
  • Group living includes single room occupancy buildings, dorms, retirement care facilities or co-housing complexes where a larger group of residents share kitchens or bathrooms.
  • The S2HC code changes allow group living by right in residential zones in parity with household living, without a conditional use.
  • This increases the range of housing types that can be built. Group living buildings can be more affordable than traditional houses or apartments because kitchens are often the most expensive rooms to build.

What is the difference between group living and single room occupancy living?

The code no longer employs the term “single room occupancy” – or SRO – because it is just a subset or form of group living. Group living is also allowed in buildings that function as apartment buildings, but residents have their own bedrooms and may share bathrooms or kitchens.

Why is there a cap of 3,500 square feet of floor area that applies only to group living?

The cap is a backstop to ensure group living facilities will be similar in size to allowed household living structures on large lots. This cap does not apply to existing buildings, and its application is limited to new group living facilities on oversized, single dwelling, residential lots. It does not apply to normal sized lots or to group living in multi-dwelling residential, mixed use or employment zones. Aside from this cap, all size, height, coverage and bulk regulations for group and household living are exactly the same. This cap is not applied to household living uses because the scale of household living is limited in other ways by density regulations and the number of bedrooms.

Recreational vehicles and tiny houses on wheels

What are recreational vehicles and tiny houses on wheels?

They are vehicles, not buildings. The term is used to refer to campers, motor homes, vacation trailers and fifth-wheel trailers. Tiny homes on wheels and park model recreational vehicles are also included. These are small homes built on a trailer, using a campsite style hook up for water, electricity and sewer. Vehicles are regulated by the Oregon Department of Transportation’s Motor Vehicles Division and are not subject to state and city building codes.

Where are recreational vehicles and tiny houses on wheels allowed?

One recreational vehicle or tiny house on wheels is allowed on a residential lot as a replacement of an allowed accessory dwelling unit, provided it meets certain industry construction standards. This allowance:

  • Acknowledges that many people already live in a recreational vehicle or a tiny house.
  • Provides a lower cost option for people who might not be able to afford to rent an accessory dwelling unit, apartment or house.

Recreational vehicles and tiny houses on wheels are also allowed in outdoor shelters, church parking lots, manufactured home parks and commercial campgrounds.

Why only one recreational vehicle or tiny house on wheels per residential lot?

  • Under state law, two or more on any one lot is considered a campground, requiring a state license.
  • In Portland, campgrounds or recreational vehicle parks are already allowed in commercial zones.

This one per lot limit does not apply to recreational vehicles and tiny houses on wheels in manufactured home parks.

How will utilities be provided to RVs and tiny houses on wheels?

The proposed code requires that a campground-style utility hookup be installed, with a plug for electricity and connections to City water and sewer.

Outreach and engagement

Who are the project partner agencies?

  • Bureau of Development Services
  • Joint Office of Homeless Services
  • Office of Management and Finance
  • Portland Bureau of Transportation
  • Portland Fire and Rescue
  • Police Bureau
  • City Attorney’s Office
  • Mayor Wheeler’s Office
  • Commissioner Ryan’s Office
  • Commissioner Hardesty’s Office

How was the public engaged before public hearings for S2HC began?

  • Community engagement for S2HC was guided by input from the Community Involvement Committee and the work of a consultant (Angelo Planning).
  • Project staff presented the S2HC proposals through video conferencing during a dozen virtual community meetings from May to November, which included people with experience being homeless or living in homeless shelters. More than 90 community members participated.
  • Members of a standing inter-agency Housing Continuum Committee participated in these community meetings, answering questions and providing assistance.
  • A technical advisory committee drafted the proposals and also participated in community meetings.
  • Thirty-one comments were received in response to the Discussion Draft in October. These comments were considered while formulating the Proposed Draft.
  • The project attracted a great deal of attention during the legislative process, with 177 pieces of testimony received by the PSC on the Proposed Draft and 2,240 pieces of testimony submitted to the City Council on the Recommended Draft.