June 10, 2003

Update On Reservoirs and the National Register

As a follow-up to my previous item about residents trying to have the Mt. Tabor and Washington Park reservoirs placed onto the National Register of Historic Places, I present below the response I received from one Paul R. Lusignan, the National Register reviewer with the National Park Service for all Oregon nominations and the other West Coast states, regarding my inquiry into the timeframe and process once the nominations have been received:

The nomination process here in Washington D. C. begins with our receipt of a completed nomination form packet from the State Historic Preservation Officer (forms, maps, photos). The nomination packet is logged in and a 45-day review window begins. The Keeper's office has 45 days in which to render its decision regarding the nomination, either listing the property in the National Register, rejecting the nomination, or returning the nomination to the State for more information. Each nomination is given a technical review by our Control Unit to make sure that the packets are complete and that the nomination form is correctly filled out. Soon after receipt a notice is prepared for publication in the FEDERAL REGISTER announcing our receipt of the pending nomination and soliciting public comments. The public comment period usually extends for 15 days after publication in the FEDERAL REGISTER. Once the technical review is completed and the notice is placed in the FEDERAL REGISTER the nomination is given to a National Register reviewer (me) for a detailed substantive review. When the 15-day public comment period is over, the Keeper or her delegated agent (me) can render a final decision on the nomination any time up to the end of the original 45-day review window.
Once a property has been listed in the National Register a notice is created and included on a "List of Weekly Actions" published by our office and sent to each State Historic Preservation Office. The "weekly list" is also posted on our web site. The State is then responsible for notifying the proper local officials, owners, and interested parties of the Keeper's actions. In the rare case that a nomination is rejected or returned to the State for additional work, a formal return letter is prepared and sent to the State along with the nomination packet.
The short answer then to your question is: the nomination will be acted upon by the Keeper's office within 45 days of our receipt of the completed nomination form. Public comments, letters of support or objection may be provided to the Keeper any time during that period and will be reviewed.

Meanwhile, I had also asked Commissioner Saltzman's office about whether or not they had indeed been notified of the proposed nominations. Matthew Grumm, staff assistant for Commissioner Saltzman, left a response on my voicemail.

"We are obviously very aware of that," Grumm said, "and actually the Water Bureau went down and testified in support, that they definitely were eligible for national historic designation." He continued, "Our expectation is that they will be designated in the near future."

In a brief follow-up to this response, I asked about the Friends of the Reservoirs assertion that, under city code, such a designation would "place the reservoirs in a category which requires design review at the city level." Here is his response:

The design review issue seems correct and we would hope that Portland's Design Commission would take an active interest in the project. The replacement project is going forward and we hope that the national historic designation will create excitement and energy for the final design of the reservoir sites. Through the current public process now under way, it is obvious that the history of these facilities is of vital importance to citizens. The designation can only help bring support to that effort. We see the designation as a positive step.

One thing on which I remain unclear is whether the Friends of the Reservoirs believe that an historic designation would stop the entire Open Reservoir Replacement Project in its tracks, or simply provide better leverage for the "what goes on top" considerations -- and, if they believe this, whether or not they are correct.

Clearly, the city believes the only aspect it could impact is the "what goes on top" discussions, or they would not have been supportive of the nomination to the National Register at all.

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