1. August 23, 2023
To: City of Portland Commissioner Carmen Rubio
Cc: City of Portland Bureau of Transportation, Bureau of Planning and
Sustainability, Planning Commission
Technical Memo: Increasing access to housing through human-centered bike
parking policy and code
Dear Commissioner Rubio,
The Street Trust is writing to you in response to our current housing crisis and
how we can propose solutions for removing barriers to housing beyond PBOT
listed items in their 08-08-23 presentation to the City’s Bicycle Advisory
Committee. The Street Trust was a member of the Bike Code Stakeholder
Advisory Committee (2016 - 2017) and is uniquely qualified to provide a
multi-disciplinary expertise and vision of our housing and transportation needs
centered around human needs.
The previous revision of the bike parking code removed approximately 1-2 units
for every 200 units, the current bike parking code now removes approximately
1 out of 15 units. Both versions of the code achieved the same 1.5 bike parking
ratio. In e ect, the current bike parking code became ine cient at a time
when housing production demanded an increase in e ciency. This is not
acceptable in light of our housing crisis. Bike parking regulation must
contribute positively to housing production.
The largest change and ine ciencies in the current bike parking code was the
addition of cargo bike parking. We are proposing innovative, smarter cargo bike
count strategies. We also are proposing removing regulatory language that
simply gives flexibility back to living spaces. Examples of these regulations are
removing the alcove, and the 15’ rule.
P.O. Box 14745 ⧫ Portland, OR 97293 ⧫ www.thestreettrust.org

2. The current bicycle parking code is overly regulated for achieving the same 1.5
parking ratio as the previous code version. In addition, the current bike parking
code almost doubled from 8 to 15 pages, so there are opportunities to remove
or modify regulations. One large opportunity for simplification and deregulation
is to recognize that most of the bike parking code isn’t a structural or fire/life
-safety issue. Thus, we recommend some of the bike parking code be revised
to be advisory while maintaining hard parking ratios, bike stacker
requirements, ADA, and other regulatory housing requirements that provide
intent and safety.
Another recommendation is to minimize regulations inside a living unit. Simply
mandating one in-unit parking is enough to meet the intent of 25% bike share
by 2030. There is no reason we need to over-regulate only one way to park a
bike. As history has shown, more regulations often have negative unintended
consequences for our marginalized communities.
The Street Trust recognizes the city needs to encourage the “missing-middle”
housing projects (20 units or less) which is why we implemented thoughtful
recommendations that prioritize smaller-scale housing production. Smaller
building footprints invigorate walkable communities and increase a ordable
housing options. A cornerstone to lowering barriers for smaller housing
projects is to remove the 50% in-unit bike parking cap and reduce bike parking
ratio to 1.1. All units in a housing project should have the option to park a bike
inside the unit for a more equitable outcome. The 50% limit is another
regulatory example that limits options and flexibility for tenants and home
builders.
We recommend any future work group reviewing the bike parking code be
required to maintain a minimal percentage of ethnic and racial diversity to
ensure historically marginalized voices are included in transportation
decision-making.
Finally, we ask all future regulations to be more BIPOC-equity focused because
we can’t achieve 25% bike trips by 2030 if we are not including 25% of our
population’s needs in our system design and execution.
Commissioner Rubio, the time for bold action is now. We have a unique
opportunity to redefine Portland as a city that leads with compassion,
innovation, and inclusivity. Our plans, policies, and codes must be pro-human,
P.O. Box 14745 ⧫ Portland, OR 97239 ⧫ www.thestreettrust.org

3. not pro-bike or pro-housing. We are crafting a city for people, not just
buildings and bikes.
I urge you to champion these changes and set a new course for our city. Your
immediate attention and action on this matter will shape the future of
Portland.
Sincerely,
Victor Duong
Board Director, The Street Trust
Appendix: Proposed Code Changes for More Inclusive, Accessible Bike Parking
Simplicity
Permanently remove bike alcove from code. Implement dual-purpose,
fold-away bike rack options.
Permanently remove 15’ from unit entrance requirement.
Reduce maneuvering clearances for in-unit bike parking to 3'x3' and
make them advisory and non-binding.
Temporarily remove cargo bike parking requirements.
Flexibility
Modify 5% ratio of cargo to single bike space and allow projects to
choose: one larger cargo bike space could count as four standard bike
spaces (in bike rooms). Allow displaced single bike spaces in bike room
to be added to in-unit parking (option only possible with removal of 50%
cap)
Remove 50% cap for in-unit bike parking. Continuing to exempt bike
rooms from FAR would still incentivize dedicated bike rooms where
appropriate. This increases flexibility for tenants to choose to use bike
rooms or units for security.
P.O. Box 14745 ⧫ Portland, OR 97239 ⧫ www.thestreettrust.org

4. Permanently reduce 1.1 parking ratio for smaller developments. (20 units
or less) that typically have less access to capital.
Temporarily reduce 1.1 for large projects 20 units and larger.
Allow variances and modifications for all bike parking in code that do
not rely on appeals.
Exempt cargo parking count requirements for SRO, studio, & 1 bedroom
units.
Allow 2+ in-unit bike parking for 2+ bedrooms.
Centering User Needs
Reduce cargo bike space to 2’6” x 6’-0” with 3x5 advisory, non-binding
maneuvering clearances. More reflective of modern cargo bikes.
Allow auto/motorcycle parking standards to be applied for 8’ long or
larger cargo bikes.
Reduce maneuvering clearances for bike stacker parking to 5’-0” to min
ANSI/FHA standards.
Additional recommendations
Temporarily remove Design Review requirements for BIPOC
owners/developers and consider a permanent removal until the city
meets min diversity requirements for review board members. DR is a
financial burden for small BIPOC owned projects.
Direct Fees (SDC): lower fees for smaller projects and BIPOC developers
First floor active use: TST values importance of active use, this is why
we support lowering 1.1 bike parking ratio for smaller projects.
Additional clear diagrams in bike parking code to address accessibility
for non-english speaking communities.
Recommend the “carrot” approach to bike parking code, rather than the
“stick” approach.
We recommend “scalable” regulations for small to large projects
P.O. Box 14745 ⧫ Portland, OR 97239 ⧫ www.thestreettrust.org

5. Bicycle Parking
33.266.200 Minimum Required Bicycle Parking
A. Purpose. Bicycle parking is required for most use categories to encourage the use of
bicycles by providing secure and convenient places to park bicycles. These regulations
ensure adequate short and long-term bicycle parking based on the demand generated by
different uses. Minimum bicycle parking facilities are based on the City’s mode split goals,
while acknowledging the usage rates for different uses. These regulations will help meet
the City’s goal that 25 percent of all trips be made by bicycle, while still acknowledging that
to meet the citywide goal the bicycle mode split will vary by geographic area.
(2) CURRENT BIKE PARKING REQUIREMENT
FOR IN-UNIT PARKING: Typical 10x10
bedroom with bike alcove and 5x5 maneuvering
clearance occupies 40% of the overall space.
Note, current bike code prohibits furniture to
overlap into maneuvering clearance.
(Illustration by Victor Duong, TST)
(1) PREVIOUS BIKE PARKING REQUIREMENT
FOR IN-UNIT PARKING: Typical 10x10 bedroom
with fold-away bike parking hook occupies 12%
of the overall space, and 2% when not in use.
Note, no maneuvering clearance required.
(Illustration by Victor Duong, TST)
(5) CURRENT BIKE PARKING CODE REQUIREMENT
FOR CARGO BIKE PARKING: Typical 3x10 cargo bike
(in red) with 5x5 maneuvering clearance occupies about
the same width as a car stall.
(Illustration by Victor Duong, TST)
(7) CARGO BIKE TO SINGLE BIKE
PARKING COMPARISON: TST proposal to
allow 1 cargo bike to displace 4 single bike
stalls in bike rooms. Reduce cargo bike
dimension to 2'-6" x 6'-0" reflecting modern,
low-cost cargo bike trend (outline in red).
Make maneuvering clearances advisory and
non-binding.
(Illustration by Victor Duong, TST)
(8) LARGE CARGO BIKE PARKING OPTION: TST
proposal to allow 2 large cargo bikes (in red) to displace 1
car stall where applicable. Make maneuvering clearances
advisory and non-binding.
(Illustration by Victor Duong, TST)
(4) CURRENT BIKE PARKING CODE REQUIREMENT
FOR IN-UNIT PARKING IS NOT COMPATIBLE WITH
HALLWAYS: Typical 3 feet wide unit hallway with bike
parking in closet and 5x5 maneuvering clearance. Note,
current bike code prohibits building elements to overlap
into maneuvering clearance. Current 2'-0" wide closet
(and 1'-6" alcove depth) does not accommodate modern
mtn bikes with 800mm wide bars (mtn bike width
outlined in orange).
(Illustration by Victor Duong, TST)
D. Standards for Long-Term Bicycle Parking.
1. Development Standards. Long-term bicycle parking must be provided in lockers or
racks that meet the following standards. Long-term bicycle parking for Schools may
choose between (1) or (5) or a combination of those two locations:
a. Location Standards. Long-term bicycle parking may be provided in one or more of
the following locations:
(1) Within a building, including on the ground floor or on individual building
floors;
(2) On-site, including in parking areas and structured parking;
(3) In an area where the closest point is within 300 feet of the site; or
(4) In a residential dwelling unit. Up to 50 percent of long-term bicycle parking
spaces may be provided in a residential dwelling unit, if they meet the
following. Long-term bicycle parking provided in a residential dwelling unit
does not need to meet the requirements for Paragraph C.2. above.
Adjustments and modifications to this Subsubparagraph are prohibited.
• The bicycle parking is located within 15 feet of the entrance to the
dwelling unit.
• The bicycle parking is located in a closet or alcove of the dwelling unit
that includes a rack that meets the standard bicycle parking spacing
dimensions in Table 266-7.
(9) CURRENT BIKE PARKING SECTION 33.266.200 D.1.a.(4):
TST recommends remove item (4) and add language that allows
modifications/adjustments.
(Illustration by Victor Duong, TST)
(6) CURRENT BIKE PARKING PURPOSE STATEMENT:
"ensure adequate short term and long-term bicycle parking"
(Illustration by Victor Duong, TST)
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09-2023
v1.3
(3) CURRENT BIKE PARKING REQUIREMENT
FOR IN-UNIT PARKING: Typical 12x12 living room
with bike alcove and 5x5 maneuvering clearance
occupies 30% of the overall space. Note, current
bike code prohibits furniture to overlap into
maneuvering clearance. (Illustration by Victor Duong,
TST)
(10) TYPICAL 300 SF STUDIO UNIT IN A 15 DWELLING
UNIT PROJECT: Approximately 20'x15' unit dimensions
with current alcove and 5x5 maneuvering clearance. Note,
maneuvering clearance prohibits furniture overlap.
(Illustration by Victor Duong, TST)
(11) TYPICAL 300SF BIKE ROOM FOR A 15 DWELLING
UNIT PROJECT: Current 1.5 ratio requires 23 bikes for a
15 unit project. Approximately 20'x15' bike room dimension
with (3) typical bike stacker and (1) cargo based on current
bike parking code. Note, this is equivalent to 1 dwelling
unit, see diagram (10)
(Illustration by Victor Duong, TST)
(12) SMARTER BIKE ROOM WITH IN-UNIT BIKE
PARKING: TST propose reducing to 1.1 ratio for
smaller projects. Reduce maneuvering clearance from
8' to 5' for typical bike stackers. Reduce cargo bike foot
print to 2'-6"x6'-0". Make maneuvering clearances
advisory and non-binding. Allow in-unit bike parking to
supplement bike room count. The result is about 60%
reduction required bike room square footage.
(Illustration by Victor Duong, TST)
20'
5' - 0"
11'
15'
20'
10'
8' - 0"
15'