To the Planning and Sustainability Commission (PSC) members:

Thank you for the opportunity to comment on the Historic Resources Code Project (HRCP). This ambitious plan undertaken by the Bureau of Planning & Sustainability (BPS) is a necessary step by the City to come in alignment with Oregon’s Land Use Goal 5 rules, and is an attempt to update and improve the processes, regulations, and incentives to protect Portland’s historic, cultural and architectural places that matter!

I urge the PSC to adopt the HRCP with one significant amendment.

I support providing local protection status to existing National Register Historic Districts and Landmarks, as well as increasing protections for Conservation Landmarks and contributing resources in Conservation Districts. Many of these Conservation Districts are in North and Northeast Portland and contain culturally important sites, especially in the African American community.

I support the creation of a demolition review process for these resources, which replaces the current 120-day demolition delay.

I also support expanding provisions for adaptive re-use in historic districts. This will allow for more economic opportunities and creative housing solutions within these areas.

The major amendment I urge the PSC to include relates to the creation and/or delisting  of local landmarks and districts. I’m concerned about the current proposal that has the PSC as the only “recommended body” for this. This is contrary to how the process works in almost every major municipality in the US, where the Landmarks Commission plays a central role. Further, the PSC does not have the appropriate expertise to evaluate the historic value based on eligibility criteria. Only the Portland Historic Landmarks Commission (PHLC) has the expertise necessary to advise City Council on historic preservation matters and it’s crucial that PHLC plays a more central role in this process.