An open letter to Portland City Auditor Mary Hull-Caballero

The current OCCL proposals to address the 2016 audit findings are deeply inadequate at best, and at worst are a frontal assault on Portland’s geographically-based, grass-roots democracy. 


Dear Ms. Hull-Caballero,

RE: 2016 Audit, “Community and Neighborhood Involvement: Accountability limited, rules and funding model outdated”

I am Vice-President of Goose Hollow Foothills League, but am writing to you today solely as a Portland citizen, and a researcher in urban development and governance.  I would like to preface this letter by noting that in my international work, I frequently meet people who express great admiration for Portland’s urban accomplishments, often singling out its pioneering neighborhood association-based public involvement system for praise. At the same time, I think we all recognize that the system has developed problems and needs improvements, as your office has also found.

 Recently I have become aware of proposals by a committee convened by the responsible bureau that would radically transform the system. In my view and that of many others, these proposals would not improve the neighborhood association component of the system, but rather, all but destroy this vital civic asset.  I will not address herein the method by which this committee was convened or managed, or the propriety or transparency of its notifications, except to note that I do have major concerns on these issues as well.

 In your November 2016 audit, you found a number of shortcomings with the then-named Office of Neighborhood Involvement. In the intervening time, while a number of actions have been taken, personnel have been changed, the office has been re-named and “re-branded” to the Office of Civic and Community Life, and some other specific issues raised by the audit have been addressed, I believe that other crucial issues identified in the audit findings have not only not been resolved, they have been made worse, or will be made worse, under current OCCL management.  Given the historic nature of the proposed changes, and the rationales based upon the findings from your own report, I ask you to review these actions and, if appropriate, issue updated findings.

 Following is a list of key issues as identified in the report, and responses that have been made or proposed to date.

  1. “The office needs a clear framework defining roles and responsibilities of City and community organizations and a focus on accountability.”  The current proposal is not to require new standards of responsibility, accountability and transparency for all groups including outside ones, but rather, to reduce responsibility, accountability and transparency for neighborhood associations.  This is moving in exactly the wrong direction from that called for in your audit.
  2. “Emerging issues, such as using email to make board decisions or disclosing potential conflicts of interest, have not been addressed in the standards.” Once again, the City bureau is proposing to dispense with all such requirements for transparent governance. The rationale given is that since neighborhood associations are composed of volunteers, they cannot be held to standards of public officials for transparency, accountability, and conflicts of interest.  However, your office found that the members of stakeholder advisory committees, though also volunteers, were in fact required to adhere to the standards of public officials. Such requirements can also be made as conditions of funding. At present, neighborhood associations for the most part do adhere to standards for public meetings and records, open elections, and disclosures of potential conflicts of interest, and in our view these requirements should be formalized, not relaxed.
  3. “Lack of clear structure limits effectiveness;” “Defining the expectations and roles of neighborhood associations and all community groups could help clarify how groups can work together.” The current proposals would further muddle the roles and responsibilities of neighborhood associations vis-à-vis other fundamentally different kinds of organizations, particularly non-geographic entities. Often these other groups are nonprofits with unknown donors, opaque governance processes, and unaccountable sources of influence. This is particularly troubling when it comes to obligations of accountability and transparency.  Neighborhood associations are by definition geographically inclusive of all their residents, and can more easily be held – as they should be – to that higher standard of open, transparent and democratic governance.
  4. “Funding is not equitable;” “Office of Neighborhood Involvement grant funding for the district coalition offices is based on a historical formula of unknown origin;” “The East Portland Neighborhood Office is funded at the lowest level of all of the coalitions on a per person basis.”  Both funding and coalition decision-making authority remain highly inequitable on a per-person basis at many levels throughout the city.  For example, in the Neighbors West-Northwest coalition alone, funding decisions and other matters are voted on by representatives of eleven associations, one of which (according to represents 718 people, while another represents 6,507 people – almost a ten-to-one resident ratio, yet they have exactly the same voting power on the coalition board.  The funding that is apportioned to the coalition by the City therefore disproportionately serves the residents of the smaller association – which in this case happens to represent a wealthy West Hills neighborhood.  As you noted, the problems with East Portland are even more egregious.
  5. “Residents report decreasing ability to impact public decisions;” “both neighborhood associations and other community groups reported that they felt their opinions were not being heard by City Hall.”   Your report rightly noted that neighborhood associations also feel ignored, along with other groups and individuals who have been historically excluded.  Yet the bureau’s current proposal seems to draw a false either-or distinction, apparently calculated to further marginalize neighborhood associations, under the claim that they have been getting preferential consideration.  This too is moving in exactly the wrongdirection from the findings of your audit.
  6.  “Some neighborhood associations and district coalitions are working within the existing neighborhood model, while also expanding outreach to diverse communities.”  Many of us who have sought to provide better representation, diversity and inclusion within our own NAs were very glad to see that finding. Our view is that neighborhood associations can and should be valuable (even essential) partners in promoting greater equity and inclusiveness in our city.  This geographic representation is particularly important in a city that elects its council at large, and that has had chronic problems with equity and inclusiveness, especially for Eastside and other underserved geographic areas (as your audit also noted).
  7. “In the 1970s, City Council created a system of neighborhood associations as the officially recognized channel for community involvement in City decision-making. Council granted neighborhood associations a formal role determining neighborhood needs, advising the City on budget decisions, and representing neighborhoods’ interests in land use and development decisions.” As your audit noted, this primarily geographic system has been regarded as a national model, and for good reason.  It serves no one well to commingle this form of representation with other kinds of non-geographic groups,  including business associations, non-profits, communities of identity and others.  In fact it was this commingling, and lack of clarity of roles, that produced so many of the dysfunctions of the bureau in the past – again as your audit found.

I think few disagree that major reforms are needed in the system, including the neighborhood association component, again, as your audit found.  But in my view, neighborhood associations need to be called on to do more, not less – more inclusiveness, more meaningful representation, more accountability and transparency.

In particular, a recognition must be made of the fundamentally distinct role of neighborhood associations as geographic forms of citizen representation, in marked contrast to other forms of groups and interests. In my own view, this distinction warrants a formal separation between neighborhood association governance and other forms of involvement (including business associations and other special interests).  It may well be that separate bureaus are needed for these very different functions.

Finally, we are all aware of the growing divisive atmosphere in governance today. In my view, what is needed is to find more effective, more constructive forms of collaboration, particularly within the democratic, geographically representative structures that we already have. I see no constructive purpose in demonizing neighborhood associations as wealthy retired homeowners (I note that I for one am none of those things) and who are bent on obstructing all development. (I am also a development consultant, but one who works respectfully and in good faith with stakeholders to facilitate better-quality development.)  To attack these citizens, to seek to diminish their rights to participate in the governance of the public realm – our urban commons – is only to foment more divisiveness, and further serve the agendas of unaccountable special interests. We must find a better way forward.


Michael W. Mehaffy, Ph.D.

Author’s post-script:  The entire 2016 Auditor’s Report can be downloaded and read at this link: