Consider appeals of the Design Commission’s approval of a voluntary Central City Master Plan Review and Adjustment Review for the Lloyd Center Central City Master Plan (LU 25-091308 CCMS AD)

TO THE COUNCIL:

The purpose of this memorandum is to provide a brief description of the land use review decision that was appealed, and which will be presented to you in a public hearing on June 24, 2026, at 9:45am.

• Applicant: Allison Rouse, ZGF Architects LLP
• Appellant #1: Save Lloyd Ice Coalition and Jennifer Gilmore-Robinson, c/o Jeffrey Kleinman, Attorney
• Appellant #2: Save Lloyd Campaign / Matthew Henderson

This is a de novo / evidentiary hearing. New evidence and testimony may be presented to the City Council as part of this appeal hearing.

Purpose of Central City Master Plans

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;
• 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.

The Zoning Code requires a Central City Master Plan only for redevelopment on six sites in the Central City, as shown on Map 510-19 in the Zoning Code (see Attachment #1).

Redevelopment at the Lloyd Center site does not require a Central City Master Plan, but the Zoning Code allows for the development of a voluntary master plan at Lloyd Center since the total site area exceeds 160,000 square feet.

Flexibility Allowed

• An approved Central City Master Plan review allows additional flexibility in the following situations: Floor area may be transferred among sites within the master plan boundary without having to meet the prioritization requirements in 33.510.205.B;
• The minimum floor area ratio standard in 33.510.200.C.2 may be met for the master plan area as a whole rather than on a site-by-site basis;
• The bonus height limits shown on Map 510-4 may be achieved without having to provide the bonuses or transfers required by 33.510.210.D.3;
• Affords opportunities for phasing and development of the transportation network and underground infrastructure in ways that may vary from standard requirements in Title 17; and
• Affords opportunities for development of a network of open spaces for public use around which new development can occur.

Components of a Central City Master Plan

The zoning code requires Central City Master Plans to include a number of components, such as:

• A proposed urban design and development framework that provides clear visual information about the proposal, including:
  • The internal pedestrian, bicycle, and vehicle circulation system, including where each part of the proposed system connects to public rights-of-way adjacent to the master plan boundary;
  • The location, size and shape of all open areas such as parks, plazas, landscaped and hardscaped areas and outdoor recreation amenities including those that are required in 33.510.255.K.
    • Note that a minimum of 20% of the master plan area must be devoted to open areas, which may include parks, outdoor recreation amenities, plazas, public fountains, or landscaped areas. Areas used for parking, loading, and driveways do not count toward the 20 percent minimum open area requirement.
  • Three-dimensional massing diagrams that show maximum proposed building envelopes; and
  • Sections, sectional elevations, and perspectives that illustrate the relationship of site redevelopment to the surrounding urban form in terms of building height and massing.
• A narrative that describes the project, identifies how the Central City Master Plan is consistent with the applicable design guidelines. Specific information about the proposed range and density of land uses and the proposed phasing of development must also be included. If the proposed Central City Master Plan involves the transfer of floor area, information about the location of the receiving and sending sites, the ownership of the sites, and amount of floor area to be transferred and retained at each site must be included.
• Infrastructure capability. The adequacy of infrastructure must be addressed. The master plan must identify and link the development of each phase of the project to the provision of services necessary to meet the infrastructure needs of the development associated with that phase.

Site and Zoning Basics

• Site Size: 27.1 acres
• Neighborhood: Lloyd District Community, contact at info@necoalition.org
• District Coalition: District 2 NECN, contact at info@necoalition.org
• Base Zone: CX – Central Commercial
• Overlay Zones: d – Design Overlay
• Plan District: Lloyd Subdistrict of the Central City Plan District

See Attachment #2 for the zoning map for the Lloyd Center master plan site.

Land Use Proposal

Central City Master Plan Review

• A voluntary Central City Master Plan Review for the future redevelopment of the Lloyd Center Mall site, which is a 27.1 acre site in the Lloyd Subdistrict of the Central City Plan.
  • The site consists of the current Lloyd Center Mall site and the Regal Cinemas lot.
  • The proposed master plan divides these parcels into 14 development areas with approximately 7.0 million gross square feet of allowed development, building envelopes up to 225 feet in height, and approximately 6.18 acres of publicly accessible open spaces and new public rights-of-way.
  • Redevelopment will occur in phases.
  • The master plan is intended to function as a flexible and inclusive design framework for the buildings, streets, open spaces, and infrastructure necessary for the redevelopment of this large site.

Adjustment Review

• Two Adjustments to zoning code standards are also requested:
  • 33.510.215.B.1, Required Building Lines – General Standards. The applicant requests an Adjustment to remove the general Required Building Lines standards from the southern frontage of Development Area 9, the rounded
    northeast corner of Development Area 5 and the rounded northwest corner of Development Area 13.
  • 33.510.215.B.2, Required Building Lines – Standards for sites with frontage on a street shown on Map 510-7. The applicant requests an Adjustment to remove this requirement from all affected frontages in the master plan area except for the eastern frontages of Development Areas 1 and 14 and the western frontage of Development Area 13. The applicant proposes that the general Required Building Lines standard will apply to all other frontages except for those listed in Adjustment request 1.

[The first Adjustment request provides for additional flexibility for the design of future buildings at the northeast and northwest corners of the master plan area. The second Adjustment request resolves a technicality with the zoning code and will result in typical urban buildings with strong sidewalk presence while maintaining the desired landscaped character along the NE 9th Ave and NE 15th/16th Ave frontages.]

A Central City Master Plan Review is required for new development on areas shown on Map 510-19 in the zoning code. The Lloyd Center Mall site is not one of the required areas. This particular Central City Master Plan Review is a voluntary master plan, which is allowed by zoning code section 33.510.255.C, since the master plan area is larger than 160,000 square feet in area.

Adjustment Review is required for proposed development that will not meet zoning code development standards.

Relevant Approval Criteria

In order to be approved, this proposal must comply with the approval criteria of Title 33, The Portland Zoning Code. The applicable approval criteria are:

• Portland Zoning Code Section 33.510.255.H, [Central City Master Plans] Approval Criteria
• Portland Zoning Code Section 33.805.040, [Adjustment] Approval Criteria

A Central City Master Plan review will be approved if the review body finds that the following approval criteria have been met. The approval criteria in Zoning Code Paragraphs 33.510.255.H.1 through H.11 apply to all Central City Master Plan reviews. An Adjustment Review will be approved if the review body finds that the approval criteria in Zoning Code Paragraphs 33.805.040.A through F are met. (See Attachment #3 for a list of the approval criteria.)

Both appeals focus their arguments on Criteria H.1 and H.2. (See Attachments #4 and #5 for a comparison of Appellant rebuttals to the Design Commission's findings regarding approval criteria 33.510.255.H.1 & H.2.)

Design Commission decision and case file

A public hearing was held before the Design Commission on February 5, 2026. At the hearing, staff and the applicants gave their respective presentations, and the Design Commission heard testimony from approximately forty-four (44) testifiers, and written testimony from 86 testifiers was also considered. The Commission asked questions of the applicant team and testifiers but did not begin deliberations. Before the Commission could call for a continued hearing with a closed record, the applicant asked that the record be held open for 7 days to submit additional evidence. The Design Commission announced they would reconvene to deliberate on a closed record on March 5, 2026.

In the intervening period, while the record was held open, an additional 252 pieces of written testimony were received and provided to the Design Commission. Two responses to new evidence were also received. The applicant submitted proposed edits to conditions of approval and a written rebuttal to testimony that was received.

On March 5, 2026, the Design Commission reconvened the hearing and deliberated on a closed record. The Commission voted 5-0 to approve the staff report (and, therefore, the proposal), including recommended conditions of approval.

The full case file may be reviewed here: https://efiles.portlandoregon.gov/record/17773327/.

Timeline

• The development team applied for a voluntary Design Advice Request meeting with the Design Commission (case number EA 23-087508 DA) on September 26, 2023. The meeting with the Design Commission was held on December 21, 2023.
• A pre-application conference for the proposed Central City Master Plan (case number EA 24-019472 PC) was applied for on March 5, 2024. The pre-application conference was held on April 2, 2024.
• The development team applied for a voluntary Central City Master Plan (this case) on November 6, 2025.
  • The applicants waived their right to a decision within 120 days and extended the review period by 245 days in order to have a de novo / evidentiary hearing upon appeal. Consequently, the City Council must make a decision on this appeal by December 22, 2026.
  • The application was determined to be incomplete on November 27, 2025.
  • The development team made the application complete on December 22, 2025.
  • A Request for Response notice was sent to recognized neighborhood organizations within 1,000 feet of the site and to city service bureaus on December 29, 2025.
  • The development team posted the Notice of a Public Hearing on the site on January 5, 2026.
  • The Proposal Notice was sent to property owners and all available addresses within 400 feet of the site and to recognized neighborhood organizations within 1,000 feet of the site on January 15, 2026.
  • The first draft of the staff report was posted on January 26, 2026.
  • The second draft of the staff report was posted on January 29, 2026.
  • The third draft of the staff report was posted on February 4, 2026.

Appeal Summary

(See Attachment #8 for the full appeal statements for each appellant.)

Appeal Intake

The PP&D Type III Decision Appeal Form states: "To be valid, the City must receive the appeal by 4:30 p.m. on the deadline listed in the decision." The decision states: "Appeals must be filed by 4:30 p.m. on April 2, 2026. Appellant Number 1 filed a complete and timely appeal on April 1, 2026. Appellant Number Two submitted appeal-related documents for their appeal submittal in 3 different emails on April 2, 2026 – an email with a Fee Reduction Request Form, which was received at 4:29 p.m. an email with the actual Appeal Form, which was received at 4:31 p.m. and an email with a narrative addressing approval criteria, which was received at 4:37 p.m. Appeal Number Two was accepted as timely filed and time-stamped at 4:29 p.m.

Appellant Number One

According to Appellant Number One's statement, the appeal is based on arguments that include:

• The Design Commission failed to give consideration to preservation of the ice rink at Lloyd
  Center with regard to the following Central City 2035 policies: Policy 1.LD-3 Tourism, Retail
  and Entertainment; Policy 2.LD-3 Community Building; Policy 3.LD-2 Rose Quarter and
  Regional Attractions; Policy 5.LD-1 Diverse and Distinctive Urban Places; Policy 5.LD-5
  Open Space Network; and,
• With regard to the following Central City Fundamental Design Guidelines: A2 Emphasize
  Portland Themes; A5 Enhance, Embellish, and Identify Areas; A6
  Reuse/Rehabilitate/Restore Buildings; B4 Provide Stopping and Viewing Places; and
• With regard to Lloyd District Design Guideline A5-1 Develop Identifying Features.

Appellant Number Two

According to Appellant Number Two's statement, the appeal is based on arguments that include:

• The Design Commission decision failed to uphold the spirit of the master plan approval
  criteria, specifically:
  • The following Central City 2035 Policies: Policy 2.LD-3 Community Building; Policy
    1.LD-1 Employment Core; Policy 1.LD-2 Sustainability Innovation Center; Policy
    1.LD-3 Tourism, Retail, and Entertainment;
  • The following Central City Fundamental Design Guidelines: A2 Emphasize Portland
    Themes; B1 Reinforce and Enhance the Pedestrian System; A5 Enhance, Embellish,
    and Identify Areas; A6 Reuse/Rehabilitate/Restore Buildings; and,
  • The following Lloyd District Design Guidelines: A5-1 Develop Identifying Features;
    A5-3 Incorporate Works of Art; A5-8 Integrate the Lloyd Shopping Center into the
    Lloyd District; and A9-1 Provide a Distinct Sense of Entry and Exit.
• The Design Commission failed to meaningfully respond to abundant public testimony to hold
  the developer accountable to the spirit of the approval criteria, which is to uphold the public
  interest, and the interests of the City.

These arguments for both appellants are related to the following approval criteria:

• Portland Zoning Code 33.510.255.H.1. The Central City Master Plan is consistent with applicable subdistrict goals and policies of the Central City 2035 Plan.
• Portland Zoning Code 33.510.255.H.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.

Although the appeal statements relate to a narrow set of the approval criteria for the Central City Master Plan Review, public testifiers can bring up any topic and introduce any new information because this is a de novo / evidentiary hearing. All appeal comments should be specifically related to the relevant approval criteria.

Response to Appeal

Both appellants structure their arguments around preservation of existing facilities—the ice rink for Appellant Number One and the overall mall for Appellant Number Two.

The appellants' statements and extensive testimony from the community show the importance of both the existing mall—serving as a large and generally free space for community gatherings and, in its most recent incarnation, providing affordable and centralized retail space for small businesses—and the existing ice rink to the greater community.

Neither the Lloyd Center Mall nor the ice rink, despite their age and importance to many members of the community, have any historic designations that would facilitate their preservation through the Zoning Code (Title 33). The demolition of a structure that is not within the Historic Resource Overlay (Zoning Code Chapter 33.445) and designated as either a Historic Landmark, Conservation Landmark, or National Register Landmark, or as a contributing resource in a Historic District, Conservation District, or National Register District is not subject to a discretionary land use review process. Demolition permits for the Lloyd Center mall and its associated structures can be applied for by the development team at any time, regardless of the outcome of this voluntary Central City Master Plan Review. These permits are subject only to the requirements in Title 24 "Building Regulations." There are no criteria in the approval criteria for a Central City Master Plan Review that require consideration of the benefits of retaining, reusing, rehabilitating, or restoring a structure versus the benefits of its demolition.

Even if the City Council were to vote to uphold one or both appeals and overturn the Design Commission's decision to approve the Central City Master Plan for the Lloyd Center, the development team could still apply for demolition permits for both the ice rink and mall building with no discretionary review or input from the community.
 

(See Attachments #4 and #5 for a comparison of Appellant rebuttals to the Design Commission's findings regarding approval criteria 33.510.255.H.1 & H.2.)

Alternatives Facing City Council

• Deny both appeals and uphold the Design Commission's decision and conditions of approval with revised findings.
• Deny both appeals and uphold the Design Commission's decision, but with revised conditions and findings.
• Grant one or both of the appeals and overturn the Design Commission's decision to approve the application, with revised findings.

Should the Council deny the appeals, staff will likely introduce a request for minor technical amendments to the Findings and Conditions of Approval. Details are still forthcoming.

Ex Parte Contacts
The Council President will provide an opportunity for Councilors to disclose ex parte contacts, site visits or conflicts of interest near the beginning of the hearing. If you have any questions about the requirements for disclosure, please contact Lauren King or Linly Rees in the City Attorney's Office.

Materials Provided as Attachments

1. Zoning Code Map 510-19
2. Zoning Map for the Lloyd Center site
3. Approval Criteria for LU 25-091308 CCMS AD
4. Comparison Matrix for Approval Criterion 33.510.255.H.1
5. Comparison Matrix for Approval Criterion 33.510.255.H.2
6. Proposed Site Plans (excerpted from the master plan)
7. Design Commission Final Findings & Decision
8. Appeal Statements
9. Hearing Notice