Comparative Market Analysis · public sources only · prepared 2026-09-28

28131 SE Orient Drive
Gresham, OR 97080

5.76 acres. Five tax lots. $2,500,000, or $434K per acre. This page explains why that is the right number, answers the objections before you raise them, and gives you a test you can run yourself.

Prepared by the seller, Johny Saephan (Johny Sells Property). This is not an appraisal and not a broker opinion of value. Every figure carries a superscript that jumps to a public source anyone can open without a login. Figures marked as estimates are the seller's own and say so. Verify everything with Multnomah County and the City of Gresham before relying on it.

The answer§ 01

Why this land is worth $2,500,000.

The ask is $2,500,000 for 5.76 acres, $434K per acre61. That is a residential land price in Gresham. The closest in-city sale by size, SE 190th Dr, sold at $575K per acre33,61. The raw-land sale on this same road sold at $387K per acre35,61. Neither has an industrial path. This one does. Five lots, one owner, eligible for annexation into Gresham and, if annexed, zoned industrial with limited commercial, in the City's written words58, with the same industrial designation drawn on all five lots on the City's Springwater plan map and zoning GIS, applied at annexation9,10,13, at a signalized corner passing 15,948 vehicles a day19,61, in a submarket at 3.9% industrial vacancy21 where the county has frozen new competing supply8. You pay a residential price for an industrial future. The three programs pay the land back in 2.2 to 3.0 years of rent59,61.

Reason 1
$434Kper acre

Priced like residential land, with an industrial path if annexed.

17 verified Gresham land sales since 2022. Every one priced below the ask per acre is residential or farm ground with no industrial path61. The only commercial-zoned sale, a quarter acre downtown, went for $2,227K per acre27,61. The subject, in the City's own words, is eligible for annexation, and if annexed, will be zoned industrial with limited commercial58. The City's Springwater plan map and zoning GIS show the same industrial designation on all five lots9,10,13.

Reason 2
2.2 to 3.0years

In the buyer scenarios, the land pays for itself in project rent.

Three worked buyer programs: small-bay flex, HQ flex with a showroom, and a Note 9 multi-outlet mix. Gross rent runs $834,900 to $1,130,690 a year at market-band rents59. Divide the $2,500,000 ask by that rent and the land is covered in 2.2 to 3.0 years61. Rents and costs are the seller's estimates, not an appraisal.

Reason 3
3.9%vacancy

Buildings are full and new supply is frozen.

Southeast Portland industrial vacancy is 3.9%, against 7.7% for the metro21. Under county rules inside the RSIA: no new commercial, no land divisions, no zone changes8,7. Gresham's own EOA lists "limited supply of development-ready industrial land" as a key disadvantage: about 90% of vacant sites are under 10 acres, and 272 of 388 vacant acres sit in Springwater, where nothing industrial has been built since 200214.

Summary for quick readers

  • The property is 28131 SE Orient Drive, Gresham, OR 97080, at the signalized corner of SE 282nd Ave and SE Orient Dr.
  • It is 5.76 acres (250,906 square feet) in 5 tax lots, APNs R341024, R341025, R168986, R168985, R341018, all owned by S&N Saephan Inc.1,2,3,4,5.
  • The asking price is $2,500,000, which is $434,028 per acre61.
  • Today the land is in Unincorporated Multnomah County, zoned OCI / OR + RSIA overlay. County rules allow homes and farm uses but no new commercial, no land divisions, and no zone changes7,8.
  • Zoning at annexation, in the City's written words: the parcels are eligible for annexation into Gresham, and if the owners choose to annex, the land will be zoned industrial with commercial uses allowed in a limited way58. The City's Springwater plan map and public zoning GIS show the same industrial designation on all five lots, applied at annexation under Development Code 4.1502, checked 2026-09-299,10,13. That district allows industrial, flex, R&D, and manufacturing, with warehousing only as an ancillary use (20% or less of a building, no pure warehouse), plus limited commercial under Note 913. Annexation is owner-initiated.
  • Key comparable sales: the only commercial-zoned land sale in Gresham since 2022 was $2,227,273 per acre (405 NE 3rd St, 0.22 acres, January 2022)27. The closest in-city sale by size was $575,448 per acre (SE 190th Dr, 3.91 acres, December 2024)33. The raw-land sale on the same road was $387,324 per acre (1335 SE 282nd Ave, 2.84 acres, May 2025)35, and its platted lots later resold for about $1,370,000 per parent acre55. Half a mile west, 12.37 acres sold for $355,699 per acre (SE Salquist Rd, April 2026)40.
  • The reconciled value range is $2.24M to $2.98M: the low is the adjusted mean of the four closest comparables (1335 SE 282nd Ave, SE 190th Dr, SE Salquist Rd, 3105 SE Powell Valley Rd), the high is SE 190th Dr adjusted. The ask sits inside it, 36% of the way from the low to the high61.
  • Traffic: 8,425 vehicles per day on SE Orient Dr (2025) and 7,523 per day on SE 282nd Ave (2024), county counts19.
  • Flood zone: FEMA Zone X, outside the mapped special flood hazard area on the February 1, 2019 panel; buyer to verify with lender and insurer20. Utilities, by the seller's memo: city water 9 to 12 feet away, sewer 149 feet away56. 2025 property tax: $15,610 across the five lots61.
  • The seller is Johny Saephan of Johny Sells Property, part of Saephan Enterprise. Email johnysellshomes@gmail.com. The public listing is on Zillow.
  • This analysis was prepared by the seller from public sources on 2026-09-28. It is not an appraisal. Figures marked as estimates are the seller's own.
The price, in order§ 02

Where $434K per acre sits.

Start at the top. Land with a commercial entitlement in Gresham has sold for $2,227,273 per acre27,61. Dirt on this road, once platted, has sold for about $1,370,000 per parent acre55,61. Now read down to the ask. Everything below it is residential or farm ground with no industrial path61.

Gresham land sales ordered by price per acre, with the ask in position
SaleWhenAcres$ per acreZoning path
405 NE 3rd St, Gresham, the only commercial-zoned sale27,61Jan 20220.22$2,227,273Downtown commercial (DCC), served
1335 SE 282nd Ave as finished lots, same road, after entitlement55,6,61Mar to Aug 20262.84about $1,370,000 per parent acrePlatted townhome lots (TR)
SE 190th Dr, closest in-city sale by size33,61Dec 20243.91$575,448High-density residential (HDR-PV)
THE ASK: 28131 SE Orient Drive61,58,9,10Now5.76$434,028OCI/OR today; eligible for annexation, and if annexed, industrial with limited commercial per the City
3105 SE Powell Valley Rd, including a 1964 house38,61Apr 20261.10$409,091Medium-density residential (MDR-24)
1335 SE 282nd Ave as raw land, same road35,61May 20252.84$387,324Townhome residential (TR), in city
SE Salquist Rd, half a mile west40,61Apr 202612.37$355,699Low-density residential (LDR-5), in city
2605 SE 282nd Ave, same road42,61Mar 202525.79$287,887Low-density residential (LDR-5), in city
Rural ground with no urban path (3 sales, incl. 8081 SE 282nd Ave)53,49,47,612022 to 2025various$66,208 to $96,778MUA-20 and OR, county only

The commercial sale is a ceiling, not a comp. A quarter-acre downtown lot is not 5.76 acres at a rural arterial corner, so the grid takes 50% off for zoning and 25% off for size before comparing it60. Even after those cuts it indicates $833K per acre61, 48% above the ask. It proves one thing: land with a commercial or industrial entitlement in this city clears far higher prices than anything residential.

The ask is 12% above the raw same-road sale61 and 22% above the Salquist tract61. Both of those are residential subdivision ground. The premium buys the industrial path, the signalized dual frontage, and a county freeze on competing supply9,10,19,8. Below the ask, the gap between $66K and $387K per acre on the same road is the price of an urban zoning path61.

What you are buying§ 03

Five things the price is made of.

1. The day after closing
5.76 acres
five lots, one deed

You own 5.76 level acres in five tax lots from one seller1,2,3,4,5. Dual frontage on SE Orient Dr and SE 282nd Ave at a signalized corner, 15,948 vehicles a day past it19,61. FEMA Zone X, outside the mapped special flood hazard area (buyer to verify with lender and insurer)20. City water 9 to 12 feet away and sewer 149 feet away, by the seller's memo56. Property tax is $15,610 a year61. Under county rules today you can farm it, build a home, or hold it7.

2. After annexation
Industrial
with limited commercial, per the City

The City's words to the seller: eligible for annexation, and if the owners choose to annex, zoned industrial with commercial uses allowed in a limited way58. The City's Springwater plan map and public zoning GIS show that industrial designation on every lot, and the Development Code applies the map at owner-initiated annexation9,10,13. Allowed: industrial, flex, R&D, and manufacturing, plus limited commercial under Note 913. Not allowed: a pure warehouse. Warehousing and distribution can be 20% or less of a building, not the building itself13. The lots touch the city at Samson Acres. The industrial designation is already drawn on the City's plan map; annexation is still an owner application that the City decides.

3. What a built project earns
$834,900 to $1,130,690
gross rent per year, three programs

Program A, Small-bay flex, 55,000 sf: $834,900 a year, land payback 3.0 yrs. Program B, HQ / showroom, 51,000 sf: $848,325 a year, land payback 2.9 yrs. Program C, Note 9 mix, 60,000 sf: $1,130,690 a year, land payback 2.2 yrs.59,61 These are market-band rents at 92% to 95% occupancy, the seller's estimates, not leases in hand59. The seller is not building anything; the programs show what the land supports.

4. What platted land resells for
$1.37M
per parent acre, same road, 2026

1335 SE 282nd Ave sold as raw land for $387K per acre in May 202535,61. Within ten months it was platted and Weekley Homes was buying finished lots: 26 lots for $3,890,797, about $1.37M per parent acre, 254% above the raw price55,6,61. Lot development cost is not public, so that is not profit. It is the public record of what entitlement did to dirt on this road. For the subject, the residual for Program C at a 6.0% cap is $3.03M, $527K per acre61.

5. What waiting costs
$69,575 to $94,224
a month of program rent, not earned

Every month between an offer and a groundbreaking is a month of that rent not collected59. On this road, the price agreed for 1335 SE 282nd in August 2022 was $387K per acre; by 2026 the same dirt, platted, traded at $1.37M per parent acre34,55,61. One date to know: the City's staff report for the August 24, 2026 Planning Commission hearing lists the City Council hearing on Gresham's Goal 9 / EOA plan amendment, file CPA-25-00645, as scheduled for October 6, 202615. The Council makes the final decision at that hearing. The memo behind the amendment puts the Springwater question on the table14. That hearing does not rezone this land or change its path; annexation is owner-initiated under the existing Springwater plan map either way. Worth watching, not a deadline.

Run it yourself§ 05

What would have to be true for this to be a bad buy.

For $2,500,000 to be too much, at least one of these six would have to hold. Each has a public check. Run them in any order.

  1. 1

    Annexation would have to be unavailable, or the zoning after annexation something other than industrial.

    Check: Open the City's public zoning GIS, the Gresham Map, and the Springwater plan map; read Development Code 4.150210,12,9,13. The City told the seller in writing that the parcels are eligible for annexation and, if annexed, will be zoned industrial with limited commercial58. On the GIS, open the Springwater Zoning layer, read the field ZONE for each of the five lots, and compare it against the value listed in the City map service source entry10; every lot should return the same industrial value listed in that entry and nothing else.

  2. 2

    An urban zoning path would have to be worth little on this road.

    Check: Compare three deeds on SE 282nd Ave: $66K per acre with no urban path (8081), $387K per acre in the city (1335, raw), and $1.37M per parent acre once platted (1335, finished lots)53,35,55,61.

  3. 3

    Gresham would have to have plenty of ready industrial land.

    Check: Read the May 2026 EOA memo14. On paper, a 337-acre industrial surplus. In the same memo: about 90% of vacant sites are under 10 acres, 272 of 388 vacant acres sit in Springwater with nothing built since 2002, and "limited supply of development-ready industrial land" is listed as a key disadvantage.

  4. 4

    Southeast industrial buildings would have to be sitting empty.

    Check: CBRE: 3.9% Southeast vacancy, 7.7% metro21. Kidder Mathews: Gresham 5.6%, asking $0.94 per square foot per month against $0.88 metro23.

  5. 5

    All three programs would have to fail at every reasonable exit cap.

    Check: Read the residual table below. Program C supports $4.66M at 5.5%, $3.03M at 6.0%, and $1.66M at 6.5%. Program A reaches $1.88M at 5.5%59,61. Inputs are the seller's bands; swap in your own.

  6. 6

    A cheaper parcel with the same path would have to exist.

    Check: Scan the 17 verified sales in the grid. None carries an industrial path61. Under the RSIA, the county cannot create one by zone change or land division8. The only route is owner-initiated annexation; the City confirmed the subject is eligible in writing, and it already touches the city58.

As of 2026-09-28, none of the six holds. The closest is number five: at mid-band costs, only Program C clears the ask, and only at a 6.0% cap or lower, which is why the ask is $2,500,000 and not more. If your own check shows one of the six is true, the price should move. If none holds, the ask is what the evidence supports.

Same road spotlight§ 08

Three sales on SE 282nd Ave.

May 2025
1335 SE 282nd Ave, Gresham35,36,34
$387K /acre61
$1,100,000 · 2.84 ac · TR · adjusted $298K60

Corner of 282nd and Powell Valley Rd. County lot is 2.84 ac; the listing described 2 acres. Price agreed August 2022, closed May 2025, then platted into townhome lots (see the same-road spotlight).

Mar 2025
2605 SE 282nd Ave, Gresham42,41
$288K /acre61
$7,424,607 · 25.79 ac · LDR-5 · adjusted $345K60

Subdivision tract with a 1910 farmhouse. Largest sale in the set.

Oct 2025
8081 SE 282nd Ave, Gresham53,52
$66K /acre61
$529,000 · 7.99 ac · MUA-20 · adjusted $115K60

Rural acreage south of the subject. Resold from $360,000 in March 2024.

The nearest like-for-like sale is 1335 SE 282nd Ave: 2.84 acres at the corner of 282nd and Powell Valley Rd, $1,100,000 in May 2025, $387K per acre raw35,61. The ask is 12% above that61. The price was agreed in August 2022 and closed nearly three years later, after entitlement34. Within ten months of closing, the buyer had platted the parcel and was selling finished townhome lots to Weekley Homes LLC: 12 lots for $1,711,200 (Mar 2026), 8 lots for $1,165,297 (Apr 2026), 6 lots for $1,014,300 (Aug 2026)55,6. That is $3,890,797 for 26 lots, about $150K per lot and $1.37M per parent acre, 254% above the raw-land price61. Lot development cost is not public, so this is not a profit figure. It is the public record of what entitlement did to the value of dirt on this road.

The other two same-road sales bracket the subject. North, 2605 SE 282nd Ave, 25.79 acres of LDR-5 subdivision ground with a 1910 farmhouse, went for $7,424,607 in March 2025, $288K per acre42,61; at $345K adjusted for its size, it lands under the ask60. South, 8081 SE 282nd Ave, 7.99 acres of MUA-20 rural ground with no urban path, sold for $529,000 in October 2025, $66K per acre53,61. The gap between $66K and $288K on the same road is the price of an urban zoning path. Half a mile west, 12.37 acres on SE Salquist Rd traded at $356K per acre in April 2026, the largest recent land purchase near the subject40,61.

Scarcity§ 10

Full buildings, frozen supply.

3.9%21
Southeast submarket industrial vacancy, Q2 2026, on 31,180,455 sf; metro 7.7%
5.6%23
Gresham submarket vacancy, 2Q 2026, asking $0.94/sf/mo; metro direct vacancy 7%
~388 ac14
vacant industrial land citywide; about 70% (~272 ac) in water-constrained Springwater
~90%14
of vacant industrial sites are under 10 acres; no industrial development in Springwater since the 2002 UGB addition

Demand side: CBRE puts Southeast Portland industrial vacancy at 3.9% with 4.4% availability, against 7.7% for the metro21. Kidder Mathews, using its own submarket lines, reports Gresham at 5.6% with asking rents of $0.94 per sf per month, above the $0.88 metro average23. Two independent public reports, same direction: east-side industrial space is functionally full.

Supply side: the City's May 2026 EOA memo counts roughly 388 vacant industrial acres and, on paper, an industrial surplus. The same memo lists "limited supply of development-ready industrial land" as a key disadvantage: about 90% of vacant sites are under 10 acres, and about 70% of the acreage (272 acres) sits inside Springwater, where water infrastructure has held industrial development at zero since 200214. Outside the city line, the subject's OCI and OR zoning sits inside a Regionally Significant Industrial Area, where state policy blocks new non-industrial uses and any reduction of industrial land7,8. Competing supply cannot be created under county jurisdiction. It can only be annexed, and the subject already shares a boundary with the city58.

Reconciled value conclusion§ 11

Where $2.50M sits.

$2.24M61
Low: adjusted mean of the four closest comparables (1335 SE 282nd Ave, SE 190th Dr, SE Salquist Rd, 3105 SE Powell Valley Rd), $389K per acre x 5.76 acres
$2.50M61
Ask: $434K per acre, 36% of the way from the low to the high
$2.98M61
High: SE 190th Dr, the closest in-city sale by size and frontage, adjusted, $517K per acre x 5.76 acres
Why $2.24M is a floor, not a value
  1. 1All four floor comparables are residential-path land on the county record: TR (1335 SE 282nd Ave), HDR-PV (SE 190th Dr), LDR-5 (SE Salquist Rd), MDR-24 (3105 SE Powell Valley Rd). None carried an industrial designation. The subject is eligible for annexation and, if annexed, zoned industrial with limited commercial, in the City's written words, with the same industrial designation drawn on the City's Springwater plan map and zoning GIS, applied at annexation.35,33,40,38,6,58,9,10
  2. 21335 SE 282nd Ave enters the floor at $298K per acre. Within ten months of its May 2025 closing, the same parcel resold as platted lots to Weekley Homes LLC for $3,890,797 across 26 lots, about $1.37M per parent acre, per county deed records.35,55,6,60,61
  3. 3SE Salquist Rd, the largest of the four at 12.37 acres, sits on a local street off Orient Dr with no arterial frontage, and its net adjustment is only +15% (size +10%, frontage +10%, utilities -5%).40,60,61
  4. 4The floor gives zero weight to the only commercial-zoned sale, $833K per acre after a 50% zoning cut and a 25% size cut, and zero weight to the Program C residual, $3.03M at a 6.0% cap, which is above the ask.27,60,59,61
  5. 5All four floor comparables closed before the City's May 11, 2026 EOA memo, and all four closed before Grainger's August 19, 2026 opening in Gresham. The latest of them, 3105 SE Powell Valley Rd, closed Apr 2026.35,33,40,38,14,17
Value range, $ per acreReconciled range shaded. Ask marked.
1
2
3
4
5
ASK $434K
$0$300K$600K$900K
  1. 1Adjusted median, all 15 sales: $331K61
  2. 21335 SE 282nd, raw: $387K35
  3. 3Low: four closest, adjusted mean: $389K61
  4. 4High: SE 190th Dr, adjusted: $517K61
  5. 5Commercial ceiling, adjusted: $833K61
Reconciled range $389K to $517K per acre ($2.24M to $2.98M): from the adjusted mean of the four closest comparables to SE 190th Dr adjusted.61
Middle half of the 15 adjusted sales, $168K to $641K.61
The ask, $2,500,000 for 5.76 acres, sits 36% of the way through the reconciled range.61

Three indicators, weighted by how much of the subject they describe. The sales comparison carries the most weight: 15 verified, adjusted sales put the whole-set median at $331K and the middle half at $168K to $641K per acre, and the four closest comps, which set the floor, average $389K60,61. The residual check confirms the ask for Program C at a 6.0% cap and caps the upside61. The commercial ceiling and the Weekley lot takedowns show what entitlement is worth on this road and in this city, without being relied on for the number27,55.

Reconciled range: $2.24M to $2.98M, $389K to $517K per acre61. The ask of $2,500,000 is inside the range, 36% of the way from the floor to the high, and below every in-city sale under one acre, the commercial ceiling, and the Program C residual61. It is priced for the buyer who values the industrial path, the signalized dual frontage, and the frozen county supply. It is not priced as farm ground, and it is not priced as if it were already annexed and served. That gap is the buyer's margin.

Next step§ 12

One email starts it.

Email Johny Saephan for the diligence package: APNs and title chain, the City's correspondence (eligible for annexation; if annexed, zoned industrial with limited commercial), the plan map and GIS readout of the industrial designation, county tax roll excerpts, traffic counts, the utility memo, and the EOA excerpt. Proof of funds is required before detailed materials go out58.

Johny Saephan, Johny Sells Property
johnysellshomes@gmail.com
Public listing reference: Zillow.
  1. Step 1

    Choose your program

    Pick A, B, or C from your tenant pipeline.

  2. Step 2

    Book the pre-app

    Gresham pre-application: owner-initiated annexation, shared-boundary survey, utilities, and confirmation of the City's words, eligible for annexation and if annexed, zoned industrial with limited commercial, against the Springwater plan map and zoning GIS.

  3. Step 3

    Lot of record

    Run the MultCo Type II determination in parallel.

  4. Step 4

    Real GC number

    Get a contractor bid inside the cost bands, then write the offer at $2.5M.

Plain-language glossary§ 13

The terms, one line each.

Annexation
The legal step that moves land from county jurisdiction into a city. Here, from Multnomah County into the City of Gresham. The owner applies; the City decides.
Industrial with limited commercial
The City of Gresham's description of the zoning the Springwater plan map applies at annexation (3,000 sf single outlet / 20,000+ sf multi-outlet). Allows industrial, flex, R&D, and manufacturing, plus limited commercial under Note 9. Warehousing is ancillary only, 20% or less of a building; a pure warehouse is not allowed.
OCI and OR
Multnomah County rural zones: Orient Commercial Industrial and Orient Rural. The subject's zoning today.
RSIA
Regionally Significant Industrial Area, a state designation. Inside one, new non-industrial uses and any reduction of industrial land are restricted.
Note 9
A footnote in the industrial use table of Gresham's Springwater plan code (Section 4.1500). Commercial uses are capped at 3,000 square feet for a single outlet, or must exceed 20,000 square feet across a multi-outlet project.
Lot of record
A county determination that a parcel was legally created and can be developed on its own. The subject needs a Type II (staff-level, with notice) determination from Multnomah County.
Contiguity
Sharing a boundary with the city. Required for annexation. The subject touches Samson Acres, which is inside Gresham.
EOA
Economic Opportunities Analysis. A study Oregon cities must produce under Statewide Planning Goal 9 to show they have enough employment land for 20 years.
Goal 9
Oregon Statewide Planning Goal 9, Economic Development. It requires cities to inventory and plan for employment land.
UGB
Urban Growth Boundary. The line around the Portland metro inside which cities may grow. Springwater was added to it in 2002.
ADT
Average daily traffic, the number of vehicles passing a counter in a typical day.
FEMA Zone X
FEMA's label for land outside the mapped special flood hazard area (the 100-year floodplain) on the effective flood insurance rate map (panel effective February 1, 2019). It is a map designation, not an insurance decision: a lender or insurer can still require flood coverage, so buyer to verify with lender and insurer.
RMV
Real market value, the county assessor's estimate of what a property would sell for. Used for taxes; not a sale price.
Arm's length
A sale between unrelated parties, each acting in their own interest. Bargain and sale deeds and family transfers may not be.
Comparable sale (comp)
A recent sale of similar land used as a yardstick. Adjustments move each comp toward the subject so they can be compared per acre.
Adjusted $/acre
A comp's raw price per acre multiplied by the adjustment factor for zoning path, size, frontage, date, and utilities.
Merchant build
Building a project to sell it on completion rather than to hold it. Its math is the thinnest because it captures no rent growth.
Cap rate
Capitalization rate: yearly net operating income divided by value. A 6.0% cap means a buyer pays about 16.7 times NOI.
NOI
Net operating income: rent collected minus operating costs. The programs use 95% of gross rent.
Residual land value
What a builder can pay for land after everything else: finished value at the exit cap rate, minus hard and soft cost.
Hard and soft cost
Hard cost is construction. Soft cost is design, permits, financing, and fees, taken here as about 20% of hard.
Land payback
The land price divided by the project's yearly gross rent: how many years of rent cover the land.
Hero yield
Yearly gross rent divided by total capital (land plus hard plus soft). A quick, unlevered return figure.
Pre-app
A pre-application meeting with City planning staff to confirm the path, the studies required, and the fees before a formal application.