Portsmouth's draft Housing Action Plan is nineteen actions of real work, and most of it should be adopted. But run every action past one question — does this produce a home still affordable in twenty years? — and two survive. Meanwhile the City's own best housing work, roughly 170 permanently affordable homes already committed, is not in the plan at all.
Multi-family in more districts, smaller lots, commercial buildings converted to homes, cottage clusters, added height. Portsmouth's rules have blocked the housing the city already has, and this plan goes at that directly. That work is overdue and it should pass.
Capacity and affordability are different products. In a small, land-capped city that absorbs regional demand, new supply is worth building and will not by itself bring prices within reach of the people who staff the schools, the hospital, and the restaurants.
Each action below is scored on whether it, by itself, creates or protects a home that stays affordable long-term. Not whether it is useful — most are — but whether anything in it holds the price.
| Action | Holds the price? | Why |
|---|---|---|
| Expand RSA 79-E tax reliefPriority 1 · 0–9 mo | No | Time-limited relief with no affordability condition attached. Metric: "Projects." Milestone: "Program used." |
| Comprehensive zoning reviewPriority 2 · 1–2 yr | No | Barrier removal. Necessary groundwork; produces no home directly. |
| Commercial-to-residential conversionsPriority 3 · 0–6 mo | No | Capacity, and now largely required by state law rather than chosen locally. |
| Cottage and clustered small-lot housingPriority 4 · 6–12 mo | No | Smaller homes are cheaper homes, but nothing holds the price at resale. |
| In-lieu fee programPriority 5 · 0–6 mo | Could | Routes money to the Housing Trust Fund, which can. But the plan does not say what obligation the fee is paid in lieu of. |
| Waive fees for nonprofit projectsPriority 6 · ongoing | No | Worth continuing, but municipal fees are a small share of an affordable project's costs. |
| Rezone Office Research and General BusinessPriority 7 · 0–6 mo | No | Opens land to housing. Nothing attaches a condition to what gets built there. |
| Expand multi-family zoningAdditional · 1–2 yr | No | The plan's most consequential capacity move, and entirely Portsmouth's own call. Still capacity. |
| Review dimensional standardsAdditional · 1–2 yr | No | Lot sizes, frontage, setbacks. Metric: "Conforming lots." |
| Single-family to multi-unit conversionAdditional · 1–2 yr | No | A strong capacity tool on a slow clock. |
| Deploy and expand the Housing Trust FundAdditional · ongoing | Yes — if funded | The plan's primary instrument for lasting affordability — and it holds about $480,000, with no dollar target and no recurring revenue source. |
| Homebuyer assistance programsAdditional · 1–3 yr | Could | Turns entirely on resale covenant terms. None are named. |
| Plan outlying areas for growthAdditional · 1–2 yr | No | Future growth areas, dependent on the Master Plan. |
| Simplify the Form-Based CodeAdditional · 1–2 yr | No | Its milestone reads "More below market rate housing," but the action is a usability rewrite with no affordability mechanism. |
| Adjust building height requirementsAdditional · 1–2 yr | No | More density where appropriate. Metric: "Units." |
| Allow live/work unitsAdditional · 1–2 yr | No | A housing type. Currently ranked above preservation. |
| Preserve existing below market-rate housingAdditional · ongoing | Yes | Extending covenants on homes that already exist is the cheapest lasting affordability available. Milestone: "No loss." Sits in the additional list. |
| Create more senior housingAdditional · 2–5 yr | Could | Described as a programs review. Whether any resulting homes are income-restricted is not stated. |
| Strengthen the workforce housing ordinanceAdditional · 1 yr | No | RSA 674:58–61 is a duty not to exclude, not a production program. Its own metric says so: "Adopted amendments to be consistent with RSA." |
The plan can be adopted with all nineteen actions intact and still contain no mechanism that guarantees a single lasting affordable home. That is not hidden. It is visible in the City's own table.
Portsmouth did something most New Hampshire cities have not: it built a dedicated vehicle for below market-rate housing. The Council established the Below Market Rate Housing Trust Fund in 2025 on the joint recommendation of the Housing Blue Ribbon Committee and the Trustees of the Trust Funds, with the Legal Department drafting terms deliberately flexible enough to partner with public, nonprofit, and private developers. That is real work by people who took the problem seriously, and the structure they built is sound.
Where the money came from matters, though. The inaugural $500,000 — $250,000 from the City, $250,000 from The Kane Company — was a term of the February 2025 settlement of the McIntyre lawsuits, an agreement the City announced as resolving the litigation with no monetary damages for either party. The fund was capitalised by the resolution of a lawsuit. That is not a revenue model anyone can repeat on purpose.
The issue is scale, and it is not close.
The whole fund is roughly half the price of one house.
The real question is not the balance — it is the pipe. A fund of this size with a recurring annual revenue stream becomes a serious instrument within a decade. A fund of any size without one gets spent once and is gone. The plan proposes to "expand" the fund without saying where the money comes from.
The nineteen actions contain no commitment to put city land toward housing. That reads as though Portsmouth has not done this work. It has — twice, in the last eighteen months, and at real scale. Neither appears anywhere in the Housing Action Plan.
The City issued a request for qualifications explicitly for the "creation of permanent below market rate housing" on the five-acre, city-owned former school at 35 Sherburne Road, and the Council awarded the redevelopment to the Portsmouth Housing Authority. The project is described by the NH Community Development Finance Authority as ninety permanently affordable homes serving more than two hundred residents.
Under the February 2025 McIntyre settlement, The Kane Company committed to donate land within the Gateway Neighborhood Overlay District to the City for the development of at least eighty permanent, below-market-rate homes, co-located in a broader mixed-use development. The same settlement amended the Zoning Ordinance and Map to create an overlay that requires permanent below market-rate housing.
Roughly 170 permanently affordable homes are already committed. Portsmouth's plan for housing does not name them, does not track them, and contains nothing that would produce a third one.
This cuts two ways, and both are worth saying at a hearing. The plan understates what the City has accomplished — staff and Council deserve credit for two land-based deals that most New Hampshire cities never attempt. And it means the mechanism that produced Portsmouth's only permanently affordable housing exists nowhere in the document meant to be Portsmouth's housing roadmap. Sherburne came from city-owned land and a nonprofit partner. The Kane units came from a settlement. Neither came from the nineteen actions, and nothing in the nineteen actions would produce another.
None of these commits the City to a dollar. Each can be made in September, and together they would move three of the "could" actions into the "yes" column.
A share of homes, an income level, and a covenant term. Requiring that a number exist is separable from agreeing on the number.
Ask that the authority question go to the City Attorney before drafting. This is the plan's only new revenue for the Trust Fund.
Protecting existing below market-rate homes is the cheapest lasting affordability the City can buy. It currently ranks below live/work units.
The column already exists and contains no figures. Adoption without them means no way to assess the plan in two years.
Both are city commitments to permanently affordable housing and neither appears in the document. Adding them gives the plan a track record to point to — and adding a standing action to identify and convey further city-controlled sites gives it a way to produce the next ninety homes rather than waiting for another lawsuit to settle.
After the hearings the plan goes to Council for adoption. Councillors and committee members read what residents send them, and a plan that no one comments on gets adopted as written. Three places to send a message:
The message is not opposition. It is this is good work, and one gap has to close before you adopt it. Pick whichever angle below fits you — they make different arguments on purpose.
Thank the Council for ordering the plan and the staff for producing it. Ask that Priority 1 be amended so the 79-E ordinance must state an affordability share, an income level, and a covenant term. Tax relief is public money; it should buy something specific.
Note that the Below Market Rate Housing Trust Fund holds about $480,000 — roughly half of one Seacoast house — and was capitalised by a lawsuit settlement, not a revenue stream. Ask the Council to identify a recurring source before adopting a plan that relies on the fund.
The plan's Metrics column contains no figures and no baseline. Ask that every action carry a number and a starting point, so that in two years anyone can tell whether the plan worked.
Protecting below market-rate homes the city already has is cheaper than building new ones. Ask that preservation be moved from the additional list into the priority tier.
Sherburne School and the Kane land gift together represent roughly 170 permanently affordable homes, and neither is named in the plan. Ask that both be added, and that the plan include a standing action to identify further city-controlled sites.
The evidence layer: where the plan stands, the five requirements Progress Portsmouth put to the Housing Committee scored against the published text, what the metrics columns actually contain, and the limits of this analysis.
Everything below is drawn from two documents the City has published: the July 2026 draft narrative and the Housing Action Plan Table. No figure appears here that is not in one of them.
The Housing Committee presented its recommendations to the City Council on July 13. Council referred the matter to the Planning Board. The September hearings are the main opportunity for residents to shape the text before it returns to Council.
The City's web page carries the nineteen actions in narrative form. The companion Housing Action Plan Table carries four columns the web page omits: Key Implementation Steps, Lead, Metrics, and Milestone. Almost everything below turns on the Metrics column, because that is where a plan either commits to an outcome or declines to.
The Metrics and Milestone columns exist — the structure is right. What they contain are units of measurement rather than targets. "Units" is not a metric; a number of homes by a date is a metric. There is no baseline anywhere in the plan, so even a filled-in metric could not show change.
Six of the nineteen milestones read as some version of "Amended Zoning Ordinance" or "Amended Zoning Map" — the milestone for amending the ordinance is an amended ordinance.
The phrase appears throughout the narrative and the table. No income band, no share of homes, no covenant term is named anywhere. The consequence for Priority 1 is specific: the City's largest discretionary housing subsidy would be adopted without stating what, if anything, a recipient must deliver in return.
This is a live choice rather than an oversight. The 2026 amendments to RSA 79-E broaden municipal discretion over the terms on which relief is granted. Portsmouth's own recent projects — West End Yards and Sage — were built at roughly 100–110% of area median income, not the 80% often assumed. Which standard applies is Portsmouth's decision, and declining to write it down is itself a decision.
Priority 5 establishes a fee paid "in place of on-site unit provision." A payment in lieu presupposes an obligation to be in lieu of — and the plan does not say what that obligation is or what authorises it. Three possibilities, with very different revenue consequences:
This matters because Priority 5 is the plan's only new revenue mechanism for the Housing Trust Fund, and the Trust Fund is one of only two actions that can produce lasting affordability. It is raised here as a question, not asserted as a defect.
In July, Progress Portsmouth put five requirements to the Housing Committee co-chairs and Planning staff. Here is where each sits in the published text. Tap any row for detail.
Tax relief lowers the cost of a project the zoning already permits. It does nothing for a project the zoning forbids. The ask was a narrow companion change on the same clock as the 79-E ordinance.
Priority 1 runs 0–9 months. The one discretionary residential change that would give it something to attach to — converting large single-family homes into multiple units — sits in the additional list at 1–2 years, with no dimensional relief and no use of the phrase "by right." The commercial conversion action moves fast, but that is now largely state-mandated.
The ADU experience is the relevant evidence and is not addressed anywhere in the draft: the rule change tripled applications and produced few homes, because permitting a use is not the same as making it pencil.
Across all nineteen actions, all Key Implementation Steps, and the full narrative, there is no action to inventory, dispose of, ground-lease, or contribute city-owned land, and no commitment to initiate any project on any site.
The verbs across the matrix are review, recommend, amend, identify, continue, track, launch. The single instance of "Allocate funds" appears under the Housing Trust Fund action, with no amount and no source.
Important correction to how this reads. The absence is in the plan, not in the City's record. Portsmouth has done land-based affordable housing twice in eighteen months — the Sherburne School award to the Portsmouth Housing Authority on city-owned land, and the Kane land gift in the Gateway Neighborhood Overlay District under the McIntyre settlement. Together those are roughly 170 permanently affordable homes. The finding is not that the City has failed to act; it is that the City's most effective housing work sits outside its housing plan, unnamed and unrepeatable.
Land cost is the binding constraint on permanently affordable housing everywhere, and especially in a small, land-capped city. Worth noting that these are largely Council and City Manager decisions rather than Planning Department ones.
The columns are there. This is the easiest of the five to close, because nothing needs to be added to the table's shape — only filled in.
Without a baseline and a number, there is no way to tell whether the plan is working, and no way to defend it to Council or the public in two years.
"Below market rate" is used throughout and defined nowhere. Priority 1 carries no affordability condition; Priority 5 has no formula; the workforce housing action names a statutory compliance floor rather than a local standard.
The single most consequential text change available before adoption is one sentence in Priority 1 requiring the enabling ordinance to state a share, an income level, and a covenant term.
No engagement action appears in the matrix. Most of the plan's desired outcomes concern rental housing, and renters are roughly half of Portsmouth's households.
The participation section of the plan's own page reads, live as of August 10, 2026:
The comment mechanism has not yet been built. Stated as an observation, not a complaint — it is straightforward to fix before September.
An analysis that lists only gaps is not usable. Four things deserve to survive to adoption intact.
The workforce housing action is a compliance item, not a production item. RSA 674:58–61 establishes a duty not to exclude workforce housing; satisfying it produces no homes. If the plan is adopted without saying so, the workforce housing question can be treated as handled when it has not been addressed.