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A new development proposal popped up in mid-July for a 19-unit apartment building that would be built along Southeast Division Street in Portland. Two weeks prior, a separate proposal was unveiled on Southeast Milwaukie Avenue. The size: 19 units.

For apartment projects 20 units or larger, developers in mixed-use zones must build affordable units or pay a hefty fee.

Portland planning officials are watching carefully to see whether multifamily developers are avoiding providing affordable apartments by keeping the number of units just under the 20-unit threshold.

鈥淲e’re tracking it,鈥� said Tyler Bump, senior economic planner for the Portland Bureau of Planning and Sustainability.

By one measure, proposals for apartment buildings with fewer than 20 units are steady. There were seven proposals for apartment buildings of 15-19 units from Feb. 1, when inclusionary housing requirements took effect, to July 7. During the same period last year, there were eight such proposals, according to Bump.

Bump is preparing a report on the inclusionary housing policy’s first six months. He noted many developers are busy with proposals that vested under the old rules, which did not require affordable units.

The city would be most concerned if developers are building small structures on large lots, Bump said. That would indicate developers aren’t building projects with as much density as city officials desire.

鈥淚f they’re bigger sites, that’s certainly an issue,鈥� Bump said.

Design Commission Chairman David Wark said density is also his primary concern with small apartment buildings.

鈥淚f those start becoming 19-unit buildings across the city, the real question is how many units could have been built?鈥� he said. 鈥淭hat might be the unfortunate byproduct of a low threshold.鈥�

Portland officials are encouraging bigger and denser multifamily development as part of their response to the city’s self-declared housing emergency.

Wark said the city should incentivize developers to build more densely, rather than find ways to punish those who build smaller structures.

鈥淚t’s really about focusing on incentives versus more requirements, let’s say,鈥� he said.

The inclusionary housing policy requires developers to provide 15 percent affordable units at 80 percent of the Portland area’s median income, or 10 percent affordable units at 60 percent of median income. The fee in lieu of providing affordable units varies from $19.50 to $29.85 per gross square foot, depending on location and zoning.

The most recent proposal for 19 units was for a four-story apartment building at 4130 S.E. Division St., part of the eastward creep of redevelopment on the Southeast Portland neighborhood. The property is currently the site of Division Medical Clinic. Its single-story, 2,880-square-foot building was built in 1957.

Efforts to reach the developer through the applicant, Jennifer Rinkus of Baysinger Partners Architecture, were not successful. A staffer at the clinic said she was unaware of planned development on the site.

Another recent proposal calls for an 18-unit apartment building in the Alphabet District of Northwest Portland. In June, a 19-unit proposal emerged for a five-story building at 5340 S.E. Milwaukie Ave. The proposed building would replace an existing eight-unit apartment building. The applicant, architect Sinan Gumusoglu of Wilsonville, could not be reached for comment.

Nineteen-unit buildings are the natural result of developers attempting to make their projects pencil out, Wark said.

鈥淚t’s not a surprise,鈥� he said. 鈥淧eople that are trying to build apartments are trying to make them work financially. And if they can’t make them work financially with affordable housing, they turn to the metrics that make them work.鈥�