Progress Portsmouth · response to the draft

What the Housing Action Plan still needs to be complete

To Housing Committee co-chairs & members; Planning & Sustainability staff
From Gerry Duffy, Progress Portsmouth
Re The July 9 draft plan & June 30 implementation matrix
The short version — five requirements

The draft has the right spine. Five things still stand between it and a plan Council can adopt.

79-E is correctly at the top, with coherent zoning under it and a matrix that assigns leads and timeframes. What’s missing isn’t on the list — it’s the pieces the list leaves implicit.

1

Pair the tax relief with by-right zoning.

79-E only works on projects the zoning already allows. Give the incentive something to attach to.

2

Put city land — and 2–3 initiated projects — on the page.

Land is the binding constraint on affordable housing. Studying is not initiating.

3

Set measurable targets — ranges and percent increases.

A plan you can’t measure is a plan you can’t defend. Numbers are not optional.

4

Name the affordability standard.

“Below market” left undefined is a promise no one can keep. The 79-E expansion makes this your choice to make.

5

Bring renters to the table.

Half the city rents, and the plan is largely written for them. They are not yet in the room.

Worth stating in the plan itself

This plan did not start inside City Hall. It exists because residents and civic advocates spent years making the case that housing is Portsmouth’s defining challenge — and the Council directed a plan in response. That civic origin is the plan’s mandate, and its accountability. The clearest way to honor it is to finish the plan for the people it was written for — which is why requirement 5 matters as much as the rest.

Keep this what the draft gets right

The requirements, in detail close before Council

Requirement 1 · load-bearing

Pair the 79-E overlay with the one by-right zoning change it needs

Tax relief lowers the cost of a project the zoning already permits; it does nothing for a project the zoning forbids. Name a narrow by-right change — conversion of existing structures to 2–3 units in SRA/SRB, with dimensional relief — as a near-term companion to the 79-E ordinance. The ADU experience is the evidence: the rule change tripled applications but produced few units, because enabling a use isn’t the same as making it pencil.

Requirement 2 · load-bearing

Put city land in the plan — and commit to initiating projects on it

The matrix has no action to dispose of, ground-lease, or contribute city-owned land, and no commitment to initiate anything — it is almost entirely “review / recommend / amend.” For permanently-affordable housing, land cost is the binding constraint. Add a disposition framework, and commit to putting 2–3 identified sites out to mission-driven developers via RFP, with a timeframe. “The market decides where it will work” is true, but left alone it becomes a reason to do nothing.

Requirement 3 · essential

Set measurable targets — and don’t flinch from the numbers

There may be reluctance to commit to figures. But without ranges or percent increases, there is no way to tell whether the plan is working, and no way to defend it to Council or the public. Set targets the plan can be held to — e.g. double annual ADU output, a set number of conversions per year, 2–3 larger projects initiated before the term ends. Measurable goals are what separate a plan that is adopted from a plan that is implemented.

Requirement 4

Name the affordability standard, deliberately

The plan says “below market” but never defines it — the known weakness of traditional 79-E. The 79-E expansion turns that silence into a choice: Portsmouth can set its own standard rather than defaulting to 80% AMI. Set the share, AMI level, and covenant term to what actually pencils (West End Yards and Sage used 100–110%). Confirm the enrolled-bill relief-period terms before the plan cites specifics.

Requirement 5

Bring renters — half the city — to the table

Most of the plan’s desired outcomes are aimed at rental housing. Yet renters, who are roughly half of Portsmouth’s households and the intended beneficiaries, have not been engaged and have no presence at the table. A plan written largely for renters, without renters, carries a legitimacy gap. Before it goes to Council, the process needs a deliberate step to reach and include them — not a box-check hearing, but real engagement.

Ways to reach them fast: a short online survey (five questions, one QR code) pushed through the property managers of the larger rental communities and posted in building lobbies and laundromats; a targeted mailing to the non-owner-occupied parcels the Assessor can already identify; one evening or virtual listening session, with childcare, rather than a daytime hearing renters can’t attend; and partners who already reach renters — the Housing Authority, major employers whose workforce rents, and local nonprofits. Most of this can be stood up in days, not weeks.

Also close these

Capacity ≠ affordability
Most of the matrix is zoning capacity. In our market — small, land-capped, a regional demand sink — new market-rate supply won’t lower price levels. Don’t present density as affordability; distinguish the two tracks so Council adopts each for what it delivers.
Elevate preservation
Preserving existing below-market units is the fastest, cheapest affordability move — cheaper per unit than building new. It currently sits low; move it into the top tier, paired with the Housing Trust Fund.
Split the tracks
Visibly separate the fast 79-E package (moves now, under the city’s own authority) from the slow master-plan rezone (handed to the consultant, with the plan setting the consultant’s scope). Don’t let the comprehensive rezone hold the tax-relief package hostage.