Last week, Portland real-estate developer Homer Williams made headlines by announcing in The Oregonian an ambitious project to fight the city's surging levels of homelessness: a $100 million homeless campus on vacant city property in industrial Northwest Portland.

It wasn't the first large-scale homeless center to be proposed this year, or even the first time Portland officials discussed using this particular patch of industrial land for a shelter. But Williams' project—which he dubbed "Oregon Trail of Hope"—has captured the imagination of citizens and the interest of Mayor-elect Ted Wheeler.

Modeled on a $20 million San Antonio project, Oregon Trail of Hope could provide sanctioned outdoor sleeping and transitional housing for as many as 700 people a night at Terminal One North at 2400 NW Front Ave.

But a new memo being passed around City Hall today casts doubt on whether Williams' project could legally break ground on the chosen site within the next two years—if at all.

City Commissioner Nick Fish writes that the zoning on the property won't allow for a shelter—and changes to that zoning couldn't be made before 2018 because of the lengthy Comprehensive Plan process.

Fish has been a consistent critic of using the Terminal One property as a homeless shelter. But today's memo makes clear the hurdles Williams would have to surmount.

Other problems identified by Fish include the need to preserve industrial properties along the harbor, requirements from Metro for converting the zoning, and the hefty sum that the property is expected to fetch on the market—more than $10 million.

"In light of the technical, legal, and practical challenges outlined above, I do not believe that 'Oregon Trail of Hope' is an appropriate use for T1," writes Fish.

Williams is undeterred.

"You can make it work if you want to make it work, and I think most of the commissioners would like to make it work," he says, noting he's happy to consider other possibilities from Fish. "If he's got other solutions, that's terrific; we're happy to look at them."

Wheeler spokesman Michael Cox said the mayor-elect hadn't read the memo, but Wheeler remains supportive of the project.

"When Ted outlined his optimism about the proposal, he made clear that Portland is going to have to find ways of getting to yes when it comes to solving the most serious issues facing our community," says Cox. "We're going to have to dig deep and be innovative. Business as usual will not do."