Logan Camporeale - Spokane Historic Preservation Office
Jan 30, 2026
Government / Technical
[PDF page 1 of 14]
Good afternoon, Tirrell and team,
Our office has completed review of the draft EIS for the Comp Plan revision. We provided comments in this linked.pdf but I will also provide a brief summary of our comments below:
The Spokane Historic Preservation Office greatly appreciates that the Draft EIS recognizes the significant adverse impacts that are likely to historic and cultural resources in the contemplated growth alternatives. However, our office does not think that the suggested mitigation strategies are sufficient to address the impacts, particularly to historic resources. We appreciate the proposed mitigation for cultural resources (a process modeled on the SMP process), but we think that process still needs clarity if it is to be sufficient mitigation for adverse impacts to cultural resources. As for appropriate mitigation for likely adverse impacts historic resources, our office recommends a mitigation strategy that includes proactive and preemptive survey as well as the development of a city-wide preservation plan.
Thank you for the opportunity to provide comment. Please let us know if you have any questions!
[PDF page 2 of 14]
From: Camporeale, Logan
To: Plan Spokane
Cc: Duvall, Megan
Subject: Spokane HPO Comments on Plan2046 Draft EIS
Date: Friday, January 30, 2026, 5:20:16 PM
Attachment: image002.png
Good afternoon, Tirrell and team,
Our office has completed review of the draft EIS for the Comp Plan revision. We provided comments in this linked .pdf but will also provide a brief summary of our comments below:
The Spokane Historic Preservation Office greatly appreciates that the Draft EIS recognizes the significant adverse impacts that are likely to historic and cultural resources in the contemplated growth alternatives.
However, our office does not think that the suggested mitigation strategies are sufficient to address the impacts, particularly to historic resources. We appreciate the proposed mitigation for cultural resources (a process modeled on the SMP process), but we think that process still needs clarity if it is to be sufficient mitigation for adverse impacts to cultural resources.
As for appropriate mitigation for likely adverse impacts historic resources, our office recommends a mitigation strategy that includes proactive and preemptive survey as well as the development of a city-wide preservation plan.
Thank you for the opportunity to provide comment. Please let us know if you have any questions!
Best,
Logan Camporeale
Historic Preservation Specialist
City/County of Spokane
[Professional contact details omitted from the reading text.]
C35_P46 Comments Summary Spokane Historic Landmarks Commission Comment Log Location in Document Comment Category
Assignment Page 1-4, Note under "Manito/Cannon Hill as well?" - regarding neighborhoods too Detail accuracy
Exhibit 1.1-2. small to be labeled at map scale. concern C35_P46_N105 "Highest levels of potential impact equals high levels of Page 1-15, Exhibit 1.4-2. mitigation" - regarding negative impacts to cultural and historic
2 Line 4 resources. Mitigation needs C35_P46_N109 "but more risk to historic buildings and neighborhoods" -
Page 1-25, bullet 3 under regarding higher risk to historic buildings from concentrated 3 Cultural Resources development in Center City and Hillyard due to Alternative 3. Mitigation needs C35_P46_N109
Page 1-26, bullet 4 under "nomination and regulation of" - appears to recommend What are some solutions changing language from only nominating historic landmarks or Recommended
4 or mitigation for impacts? districts, to also regulating them. regulation C35_P46_N110 "This is a fantastic mitigation strategy as far as preventing adverse
impacts to CR and HP resources, but I do wonder about the General support workload to do the review in this decision tree with only two and Page 1-26, bullet 5 under historic preservation staff" - regarding applying cultural resources Implementation C35_P46_N107
What are some solutions discovery policies to the full city limits, and develop a decision concern or &
5 or mitigation for impacts? tree to investigation/mitigation scale. recommendation C35_P46_N108
"This is articulated well and our office appreciates the inclusion of this language" - regarding the acknowledgment of Page 1-26, final potential/significant adverse impacts, and the desire for a 6 paragraph, protective vs reactive response in preserving resources.
General support C35_P46_N107
"In my opinion, formalizing this process seems especially Implementation important in light of the SEPA exemptions possibility" - regarding concern or 7 Page 1-27, first sentence the pre-project cultural resource review process. recommendation C35_P46_N108
[PDF page 4 of 14]
"Another effective way to mitigate is to do more proactive survey of historic and cultural resources. The city has not funded any big work on that front recently and all recent large-scale survey work has been funded with federal pass-through money" - regarding Implementation avoiding, minimizing, and mitigating adverse impacts to cultural concern or 8 Page 1-27, first sentence and historic resources. recommendation C35_P46_N108
"It feels like this is mostly concerned with archaeology (ie. 'inadvertent discoveries') - how are we thinking about mitigation for actions that result in the loss of historic built environment?" -
9 Page 1-27, first sentence regarding avoiding, minimizing, and mitigating adverse impacts. Mitigation needs C35_P46_N109
Page 1-29, first "Exactly.
Twice as many demolitions of existing housing units" & sentence under "This is a HUGE impact that I feel like needs more mitigation" -
Housing Production regarding the expectation that Alternatives 2 and 3 will demolish and Displacement over twice as many housing units compared to Alternative 1. Mitigation needs C35_P46_N109
Page 3-104, first paragraph under Building "Love this context setting downtown.
Good writing" - regarding
11 Types and Styles the architectural and historical variety of buildings downtown.
General Support C35_P46_N107
Page 3-104, second paragraph under Building "late 19th and early 20th century buildings" - regarding the Detail accuracy
12 Types and Styles description of the buildings downtown. concern C35_P46_N105 Page 3-104, third
paragraph under Building "late 19th and early 20th century" - regarding the description of Detail accuracy
13 Types and Styles early Spokane development. concern C35_P46_N105 Page 3-104, third "single unit homes in a variety of architectural styles" -
paragraph under Building recommended replacement of "craftsmen" as the description for Detail accuracy
14 Types and Styles the single unit homes. concern C35_P46_N105 Page 3-104, third paragraph, second
sentence under Building "and vary from" - recommended replacement of "all" in the 15 Types and Styles description of the height and scale of development.
Editing C35_P46_N106
[PDF page 5 of 14]
Page 3-104, third paragraph, second "to large historic homes and apartments on a typical grid street
sentence under Building pattern" - recommended inclusion in the description of the height "This map shows how the proposed decision tree would result in a lot of survey required depending on the threshold to initiate the Implementation
tree" - regarding the State Archaeological Risk Assessment Model concern or 17 Page 3-107, Exhibit 3.4-16 map. recommendation C35_P46_N108
"My guess is that this is actually referring to the Browne's Addition National Register Historic District Nomination from 1976
Page 3-108, first (https://properties.historicspokane.org/_pdf/districts/national/dis paragraph under Historic trict-national-18.pdf)" - regarding the Washington State Office of Detail accuracy
18 Resources Archaeology and Historic Preservation citation. concern C35_P46_N105 Page 3-108, third "and over 1,000 more properties included in local historic
19 paragraph under Historic districts" - regarding the over 400 individual historic sites Detail accuracy
Resources described. concern C35_P46_N105 Page 3-108, Exhibit 3.4- 20 17, Line 3 "e's" - regarding the spelling of Browne's Addition Editing C35_P46_N106
"We have added the Cannon Hill Park Local Historic District - in effect on 12/25/2025.
We don't have the acres handy, but can get
that info to you. Not on the National Register, South for area.
We could pretty easily give you the number of properties for these
rather than the acreage...but maybe there is a good reason for Page 3-108, Exhibit 3.4- using acreage" - regarding the Cannon Streetcar Suburb Detail accuracy
21 17, Line 4 information in the table. concern C35_P46_N105 "I know a pain, but not sure if you want to update these maps to include the newest local historic district.
It should be added to GIS
before end of January." & "Will want to add the newest Historic Detail accuracy 22 Page 3-109, Exhibit 3.4-18 District." concern C35_P46_N105
[PDF page 6 of 14]
Page 3-123, first paragraph under Cultural "and areas around the Spokane River" - regarding areas with Detail accuracy
23 Resources potential for Cultural Resource disturbance. concern C35_P46_N105 Page 3-123, second
paragraph under Cultural "adversely impact" - recommend adding "adversely" to the 24 Resources description of potential impacts to designated historic properties.
Mitigation needs C35_P46_N109
Page 3-126, third bullet
under Alternative 3:
Center City and Regional "Why is this related to CR?" - regarding the higher job growth 25 Hubs described in alternative 3.
Applicability C35_P46_N104
Page 3-126, third bullet under Alternative 3: "We have protections against demolition in local historic districts
Center City and Regional like Hillyard" - regarding pressure to alter or demolish historic Detail accuracy
26 Hubs buildings or districts in Hillyard. concern C35_P46_N105 Page 3-126, third bullet under Alternative 3: Implementation
Center City and Regional "We need ADDITIONAL incentives if we want to keep historic concern or 27 Hubs buildings in use" - regarding encouraging adaptive reuse. recommendation C35_P46_N108
"I guess I am still a little unsure of this reasoning." & "I agree - just Page 3-126, third bullet because you can develop in the areas called out in Alternative 3
28 under Alternative 3: doesn't mean no one will want to build in lower density areas" - Center City and Regional regarding the described less risk from development pressure
Hubs under Alternative 3.
Mitigation needs C35_P46_N109 "We just did one of these and we caught it in pre-dev.
I am glad we
caught it, but I am a bit nervous of a non-mandatory process being the best way to catch one of these with even more SEPA
exemption" - regarding Washington State Law for protecting archaeological resources and Indian burial grounds and historic Implementation
Page 3-128, first three graves, permits for disturbing an archaeological site, and concern or 29 bullets on the page prohibitions of knowing disturbance of burials/graves. recommendation C35_P46_N108
[PDF page 7 of 14]
"we don't have these - it was put in our code, but never was done. Honestly, we don't have utility incentives either.
We have facade Implementation Page 3-128, third improvement grants, code relief and property tax reduction concern or 30 paragraph incentives" - regarding sidewalk grants to support preservation. recommendation C35_P46_N108
"Since Cultural Resources are the most adversely impacted in all alternatives - it seems that proactive mitigation like a City-wide
historic preservation plan should be considered.
It would be useful for future development as well as a tool for developers to use to avoid major impacts to highly concentrated areas of Implementation
Page 3-129, first sentence historic resources" - regarding impact mitigation under all concern or 31 under Cultural Resources alternatives. recommendation C35_P46_N108
Page 3-129, second "Our office is unclear on what threshold will trigger the decision Implementation
paragraph under Cultural tree: all projects, projects of certain size, grading?" - regarding the concern or 32 Resources 'decision tree' for below-ground cultural resources. recommendation C35_P46_N108
"This is beyond just inadvertent discoveries.
A city-wide historic Page 3-132, first preservation plan would be an important tool for us and planning" -Implementation
paragraph under Cultural regarding the proactive consideration of impacts to cultural concern or 33 Resources resources vs a reactive response. recommendation C35_P46_N108
General support "HP loves this." & "Hear, hear!" & "Although, I'm not sure what and Page 3-187, Exhibit 3.5-44 'preservation credits' are?
Tax credits?" regarding the incentives Implementation C35_P46_N107
line 16, Low-Cost Rental aimed at presenting displacement and preserving naturally concern or &
34 Housing Preservation occurring affordable housing. recommendation C35_P46_N108 Page 3-217, Exhibit 3.6-5,
Line 13 Historic "adversely affect" - recommend adding "adversely" to the 35 preservation description of potential impacts to cultural resources.
Mitigation needs C35_P46_N109
[PDF page 8 of 14]
"I wish this included language about increased survey work so we can be proactive not reactive in identification of resources." &
"Exactly.
Mitigation for this adverse impact should be city-wide Implementation Page 5-7, first bullet on survey work so that we can use 'available data'." regarding the concern or 36 the page and sub-bullets documentation of cultural and historic resources regulations. recommendation C35_P46_N108
"I don't know if this section should include the Preservation of Page 5-14, Exhibit 3, Salvageable Materials ordinance (15.06) since it requires any
Line 13 Historic and building that is eligible for listing on the Spokane Register to be Cultural Preservation - deconstructed for important historic material preservation before
Local demolition may occur?
Or maybe it is better located with the Detail accuracy environmental section?" - regarding the Local sub-category. concern C35_P46_N105
[PDF page 9 of 14]
C35_P46 Comments Summary Spokane Historic Landmarks Commission Comment Log Location in Document Comment Category
Assignment Page 1-4, Note under "Manito/Cannon Hill as well?" - regarding neighborhoods too Detail accuracy
Exhibit 1.1-2. small to be labeled at map scale. concern C35_P46_N105 "Highest levels of potential impact equals high levels of Page 1-15, Exhibit 1.4-2. mitigation" - regarding negative impacts to cultural and historic
2 Line 4 resources. Mitigation needs C35_P46_N109 "but more risk to historic buildings and neighborhoods" -
Page 1-25, bullet 3 under regarding higher risk to historic buildings from concentrated 3 Cultural Resources development in Center City and Hillyard due to Alternative 3. Mitigation needs C35_P46_N109
Page 1-26, bullet 4 under "nomination and regulation of" - appears to recommend What are some solutions changing language from only nominating historic landmarks or Recommended
4 or mitigation for impacts? districts, to also regulating them. regulation C35_P46_N110 "This is a fantastic mitigation strategy as far as preventing adverse
impacts to CR and HP resources, but I do wonder about the General support workload to do the review in this decision tree with only two and Page 1-26, bullet 5 under historic preservation staff" - regarding applying cultural resources Implementation C35_P46_N107
What are some solutions discovery policies to the full city limits, and develop a decision concern or &
5 or mitigation for impacts? tree to investigation/mitigation scale. recommendation C35_P46_N108
"This is articulated well and our office appreciates the inclusion of this language" - regarding the acknowledgment of Page 1-26, final potential/significant adverse impacts, and the desire for a 6 paragraph, protective vs reactive response in preserving resources.
General support C35_P46_N107
"In my opinion, formalizing this process seems especially Implementation important in light of the SEPA exemptions possibility" - regarding concern or 7 Page 1-27, first sentence the pre-project cultural resource review process. recommendation C35_P46_N108
[PDF page 10 of 14]
"Another effective way to mitigate is to do more proactive survey of historic and cultural resources. The city has not funded any big work on that front recently and all recent large-scale survey work has been funded with federal pass-through money" - regarding Implementation avoiding, minimizing, and mitigating adverse impacts to cultural concern or 8 Page 1-27, first sentence and historic resources. recommendation C35_P46_N108
"It feels like this is mostly concerned with archaeology (ie. 'inadvertent discoveries') - how are we thinking about mitigation for actions that result in the loss of historic built environment?" -
9 Page 1-27, first sentence regarding avoiding, minimizing, and mitigating adverse impacts. Mitigation needs C35_P46_N109
Page 1-29, first "Exactly.
Twice as many demolitions of existing housing units" & sentence under "This is a HUGE impact that I feel like needs more mitigation" -
Housing Production regarding the expectation that Alternatives 2 and 3 will demolish and Displacement over twice as many housing units compared to Alternative 1. Mitigation needs C35_P46_N109
Page 3-104, first paragraph under Building "Love this context setting downtown.
Good writing" - regarding
11 Types and Styles the architectural and historical variety of buildings downtown.
General Support C35_P46_N107
Page 3-104, second paragraph under Building "late 19th and early 20th century buildings" - regarding the Detail accuracy
12 Types and Styles description of the buildings downtown. concern C35_P46_N105 Page 3-104, third
paragraph under Building "late 19th and early 20th century" - regarding the description of Detail accuracy
13 Types and Styles early Spokane development. concern C35_P46_N105 Page 3-104, third "single unit homes in a variety of architectural styles" -
paragraph under Building recommended replacement of "craftsmen" as the description for Detail accuracy
14 Types and Styles the single unit homes. concern C35_P46_N105 Page 3-104, third paragraph, second
sentence under Building "and vary from" - recommended replacement of "all" in the 15 Types and Styles description of the height and scale of development.
Editing C35_P46_N106
[PDF page 11 of 14]
Page 3-104, third paragraph, second "to large historic homes and apartments on a typical grid street
sentence under Building pattern" - recommended inclusion in the description of the height "This map shows how the proposed decision tree would result in a lot of survey required depending on the threshold to initiate the Implementation
tree" - regarding the State Archaeological Risk Assessment Model concern or 17 Page 3-107, Exhibit 3.4-16 map. recommendation C35_P46_N108
"My guess is that this is actually referring to the Browne's Addition National Register Historic District Nomination from 1976
Page 3-108, first (https://properties.historicspokane.org/_pdf/districts/national/dis paragraph under Historic trict-national-18.pdf)" - regarding the Washington State Office of Detail accuracy
18 Resources Archaeology and Historic Preservation citation. concern C35_P46_N105 Page 3-108, third "and over 1,000 more properties included in local historic
19 paragraph under Historic districts" - regarding the over 400 individual historic sites Detail accuracy
Resources described. concern C35_P46_N105 Page 3-108, Exhibit 3.4- 20 17, Line 3 "e's" - regarding the spelling of Browne's Addition Editing C35_P46_N106
"We have added the Cannon Hill Park Local Historic District - in effect on 12/25/2025.
We don't have the acres handy, but can get
that info to you. Not on the National Register, South for area.
We could pretty easily give you the number of properties for these
rather than the acreage...but maybe there is a good reason for Page 3-108, Exhibit 3.4- using acreage" - regarding the Cannon Streetcar Suburb Detail accuracy
21 17, Line 4 information in the table. concern C35_P46_N105 "I know a pain, but not sure if you want to update these maps to include the newest local historic district.
It should be added to GIS
before end of January." & "Will want to add the newest Historic Detail accuracy 22 Page 3-109, Exhibit 3.4-18 District." concern C35_P46_N105
[PDF page 12 of 14]
Page 3-123, first paragraph under Cultural "and areas around the Spokane River" - regarding areas with Detail accuracy
23 Resources potential for Cultural Resource disturbance. concern C35_P46_N105 Page 3-123, second
paragraph under Cultural "adversely impact" - recommend adding "adversely" to the 24 Resources description of potential impacts to designated historic properties.
Mitigation needs C35_P46_N109
Page 3-126, third bullet
under Alternative 3:
Center City and Regional "Why is this related to CR?" - regarding the higher job growth 25 Hubs described in alternative 3.
Applicability C35_P46_N104
Page 3-126, third bullet under Alternative 3: "We have protections against demolition in local historic districts
Center City and Regional like Hillyard" - regarding pressure to alter or demolish historic Detail accuracy
26 Hubs buildings or districts in Hillyard. concern C35_P46_N105 Page 3-126, third bullet under Alternative 3: Implementation
Center City and Regional "We need ADDITIONAL incentives if we want to keep historic concern or 27 Hubs buildings in use" - regarding encouraging adaptive reuse. recommendation C35_P46_N108
"I guess I am still a little unsure of this reasoning." & "I agree - just Page 3-126, third bullet because you can develop in the areas called out in Alternative 3
28 under Alternative 3: doesn't mean no one will want to build in lower density areas" - Center City and Regional regarding the described less risk from development pressure
Hubs under Alternative 3.
Mitigation needs C35_P46_N109 "We just did one of these and we caught it in pre-dev.
I am glad we
caught it, but I am a bit nervous of a non-mandatory process being the best way to catch one of these with even more SEPA
exemption" - regarding Washington State Law for protecting archaeological resources and Indian burial grounds and historic Implementation
Page 3-128, first three graves, permits for disturbing an archaeological site, and concern or 29 bullets on the page prohibitions of knowing disturbance of burials/graves. recommendation C35_P46_N108
[PDF page 13 of 14]
"we don't have these - it was put in our code, but never was done. Honestly, we don't have utility incentives either.
We have facade Implementation Page 3-128, third improvement grants, code relief and property tax reduction concern or 30 paragraph incentives" - regarding sidewalk grants to support preservation. recommendation C35_P46_N108
"Since Cultural Resources are the most adversely impacted in all alternatives - it seems that proactive mitigation like a City-wide
historic preservation plan should be considered.
It would be useful for future development as well as a tool for developers to use to avoid major impacts to highly concentrated areas of Implementation
Page 3-129, first sentence historic resources" - regarding impact mitigation under all concern or 31 under Cultural Resources alternatives. recommendation C35_P46_N108
Page 3-129, second "Our office is unclear on what threshold will trigger the decision Implementation
paragraph under Cultural tree: all projects, projects of certain size, grading?" - regarding the concern or 32 Resources 'decision tree' for below-ground cultural resources. recommendation C35_P46_N108
"This is beyond just inadvertent discoveries.
A city-wide historic Page 3-132, first preservation plan would be an important tool for us and planning" -Implementation
paragraph under Cultural regarding the proactive consideration of impacts to cultural concern or 33 Resources resources vs a reactive response. recommendation C35_P46_N108
General support "HP loves this." & "Hear, hear!" & "Although, I'm not sure what and Page 3-187, Exhibit 3.5-44 'preservation credits' are?
Tax credits?" regarding the incentives Implementation C35_P46_N107
line 16, Low-Cost Rental aimed at presenting displacement and preserving naturally concern or &
34 Housing Preservation occurring affordable housing. recommendation C35_P46_N108 Page 3-217, Exhibit 3.6-5,
Line 13 Historic "adversely affect" - recommend adding "adversely" to the 35 preservation description of potential impacts to cultural resources.
Mitigation needs C35_P46_N109
[PDF page 14 of 14]
"I wish this included language about increased survey work so we can be proactive not reactive in identification of resources." &
"Exactly.
Mitigation for this adverse impact should be city-wide Implementation Page 5-7, first bullet on survey work so that we can use 'available data'." regarding the concern or 36 the page and sub-bullets documentation of cultural and historic resources regulations. recommendation C35_P46_N108
"I don't know if this section should include the Preservation of Page 5-14, Exhibit 3, Salvageable Materials ordinance (15.06) since it requires any
Line 13 Historic and building that is eligible for listing on the Spokane Register to be Cultural Preservation - deconstructed for important historic material preservation before
Local demolition may occur?
Or maybe it is better located with the Detail accuracy environmental section?" - regarding the Local sub-category. concern C35_P46_N105
Logan Camporeale - Spokane Historic Preservation Office
Jan 30, 2026
Government / Technical
[PDF page 1 of 14]
Good afternoon, Tirrell and team,
Our office has completed review of the draft EIS for the Comp Plan revision. We provided comments in this linked.pdf but I will also provide a brief summary of our comments below:
The Spokane Historic Preservation Office greatly appreciates that the Draft EIS recognizes the significant adverse impacts that are likely to historic and cultural resources in the contemplated growth alternatives. However, our office does not think that the suggested mitigation strategies are sufficient to address the impacts, particularly to historic resources. We appreciate the proposed mitigation for cultural resources (a process modeled on the SMP process), but we think that process still needs clarity if it is to be sufficient mitigation for adverse impacts to cultural resources. As for appropriate mitigation for likely adverse impacts historic resources, our office recommends a mitigation strategy that includes proactive and preemptive survey as well as the development of a city-wide preservation plan.
Thank you for the opportunity to provide comment. Please let us know if you have any questions!
[PDF page 2 of 14]
From: Camporeale, Logan
To: Plan Spokane
Cc: Duvall, Megan
Subject: Spokane HPO Comments on Plan2046 Draft EIS
Date: Friday, January 30, 2026, 5:20:16 PM
Attachment: image002.png
Good afternoon, Tirrell and team,
Our office has completed review of the draft EIS for the Comp Plan revision. We provided comments in this linked .pdf but will also provide a brief summary of our comments below:
The Spokane Historic Preservation Office greatly appreciates that the Draft EIS recognizes the significant adverse impacts that are likely to historic and cultural resources in the contemplated growth alternatives.
However, our office does not think that the suggested mitigation strategies are sufficient to address the impacts, particularly to historic resources. We appreciate the proposed mitigation for cultural resources (a process modeled on the SMP process), but we think that process still needs clarity if it is to be sufficient mitigation for adverse impacts to cultural resources.
As for appropriate mitigation for likely adverse impacts historic resources, our office recommends a mitigation strategy that includes proactive and preemptive survey as well as the development of a city-wide preservation plan.
Thank you for the opportunity to provide comment. Please let us know if you have any questions!
Best,
Logan Camporeale
Historic Preservation Specialist
City/County of Spokane
[Professional contact details omitted from the reading text.]
----------------------------------------
ATTACHMENT / ADDITIONAL PAGES
----------------------------------------
[PDF page 3 of 14]
C35_P46 Comments Summary Spokane Historic Landmarks Commission Comment Log Location in Document Comment Category
Assignment Page 1-4, Note under "Manito/Cannon Hill as well?" - regarding neighborhoods too Detail accuracy
Exhibit 1.1-2. small to be labeled at map scale. concern C35_P46_N105 "Highest levels of potential impact equals high levels of Page 1-15, Exhibit 1.4-2. mitigation" - regarding negative impacts to cultural and historic
2 Line 4 resources. Mitigation needs C35_P46_N109 "but more risk to historic buildings and neighborhoods" -
Page 1-25, bullet 3 under regarding higher risk to historic buildings from concentrated 3 Cultural Resources development in Center City and Hillyard due to Alternative 3. Mitigation needs C35_P46_N109
Page 1-26, bullet 4 under "nomination and regulation of" - appears to recommend What are some solutions changing language from only nominating historic landmarks or Recommended
4 or mitigation for impacts? districts, to also regulating them. regulation C35_P46_N110 "This is a fantastic mitigation strategy as far as preventing adverse
impacts to CR and HP resources, but I do wonder about the General support workload to do the review in this decision tree with only two and Page 1-26, bullet 5 under historic preservation staff" - regarding applying cultural resources Implementation C35_P46_N107
What are some solutions discovery policies to the full city limits, and develop a decision concern or &
5 or mitigation for impacts? tree to investigation/mitigation scale. recommendation C35_P46_N108
"This is articulated well and our office appreciates the inclusion of this language" - regarding the acknowledgment of Page 1-26, final potential/significant adverse impacts, and the desire for a 6 paragraph, protective vs reactive response in preserving resources.
General support C35_P46_N107
"In my opinion, formalizing this process seems especially Implementation important in light of the SEPA exemptions possibility" - regarding concern or 7 Page 1-27, first sentence the pre-project cultural resource review process. recommendation C35_P46_N108
[PDF page 4 of 14]
"Another effective way to mitigate is to do more proactive survey of historic and cultural resources. The city has not funded any big work on that front recently and all recent large-scale survey work has been funded with federal pass-through money" - regarding Implementation avoiding, minimizing, and mitigating adverse impacts to cultural concern or 8 Page 1-27, first sentence and historic resources. recommendation C35_P46_N108
"It feels like this is mostly concerned with archaeology (ie. 'inadvertent discoveries') - how are we thinking about mitigation for actions that result in the loss of historic built environment?" -
9 Page 1-27, first sentence regarding avoiding, minimizing, and mitigating adverse impacts. Mitigation needs C35_P46_N109
Page 1-29, first "Exactly.
Twice as many demolitions of existing housing units" & sentence under "This is a HUGE impact that I feel like needs more mitigation" -
Housing Production regarding the expectation that Alternatives 2 and 3 will demolish and Displacement over twice as many housing units compared to Alternative 1. Mitigation needs C35_P46_N109
Page 3-104, first paragraph under Building "Love this context setting downtown.
Good writing" - regarding
11 Types and Styles the architectural and historical variety of buildings downtown.
General Support C35_P46_N107
Page 3-104, second paragraph under Building "late 19th and early 20th century buildings" - regarding the Detail accuracy
12 Types and Styles description of the buildings downtown. concern C35_P46_N105 Page 3-104, third
paragraph under Building "late 19th and early 20th century" - regarding the description of Detail accuracy
13 Types and Styles early Spokane development. concern C35_P46_N105 Page 3-104, third "single unit homes in a variety of architectural styles" -
paragraph under Building recommended replacement of "craftsmen" as the description for Detail accuracy
14 Types and Styles the single unit homes. concern C35_P46_N105 Page 3-104, third paragraph, second
sentence under Building "and vary from" - recommended replacement of "all" in the 15 Types and Styles description of the height and scale of development.
Editing C35_P46_N106
[PDF page 5 of 14]
Page 3-104, third paragraph, second "to large historic homes and apartments on a typical grid street
sentence under Building pattern" - recommended inclusion in the description of the height "This map shows how the proposed decision tree would result in a lot of survey required depending on the threshold to initiate the Implementation
tree" - regarding the State Archaeological Risk Assessment Model concern or 17 Page 3-107, Exhibit 3.4-16 map. recommendation C35_P46_N108
"My guess is that this is actually referring to the Browne's Addition National Register Historic District Nomination from 1976
Page 3-108, first (https://properties.historicspokane.org/_pdf/districts/national/dis paragraph under Historic trict-national-18.pdf)" - regarding the Washington State Office of Detail accuracy
18 Resources Archaeology and Historic Preservation citation. concern C35_P46_N105 Page 3-108, third "and over 1,000 more properties included in local historic
19 paragraph under Historic districts" - regarding the over 400 individual historic sites Detail accuracy
Resources described. concern C35_P46_N105 Page 3-108, Exhibit 3.4- 20 17, Line 3 "e's" - regarding the spelling of Browne's Addition Editing C35_P46_N106
"We have added the Cannon Hill Park Local Historic District - in effect on 12/25/2025.
We don't have the acres handy, but can get
that info to you. Not on the National Register, South for area.
We could pretty easily give you the number of properties for these
rather than the acreage...but maybe there is a good reason for Page 3-108, Exhibit 3.4- using acreage" - regarding the Cannon Streetcar Suburb Detail accuracy
21 17, Line 4 information in the table. concern C35_P46_N105 "I know a pain, but not sure if you want to update these maps to include the newest local historic district.
It should be added to GIS
before end of January." & "Will want to add the newest Historic Detail accuracy 22 Page 3-109, Exhibit 3.4-18 District." concern C35_P46_N105
[PDF page 6 of 14]
Page 3-123, first paragraph under Cultural "and areas around the Spokane River" - regarding areas with Detail accuracy
23 Resources potential for Cultural Resource disturbance. concern C35_P46_N105 Page 3-123, second
paragraph under Cultural "adversely impact" - recommend adding "adversely" to the 24 Resources description of potential impacts to designated historic properties.
Mitigation needs C35_P46_N109
Page 3-126, third bullet
under Alternative 3:
Center City and Regional "Why is this related to CR?" - regarding the higher job growth 25 Hubs described in alternative 3.
Applicability C35_P46_N104
Page 3-126, third bullet under Alternative 3: "We have protections against demolition in local historic districts
Center City and Regional like Hillyard" - regarding pressure to alter or demolish historic Detail accuracy
26 Hubs buildings or districts in Hillyard. concern C35_P46_N105 Page 3-126, third bullet under Alternative 3: Implementation
Center City and Regional "We need ADDITIONAL incentives if we want to keep historic concern or 27 Hubs buildings in use" - regarding encouraging adaptive reuse. recommendation C35_P46_N108
"I guess I am still a little unsure of this reasoning." & "I agree - just Page 3-126, third bullet because you can develop in the areas called out in Alternative 3
28 under Alternative 3: doesn't mean no one will want to build in lower density areas" - Center City and Regional regarding the described less risk from development pressure
Hubs under Alternative 3.
Mitigation needs C35_P46_N109 "We just did one of these and we caught it in pre-dev.
I am glad we
caught it, but I am a bit nervous of a non-mandatory process being the best way to catch one of these with even more SEPA
exemption" - regarding Washington State Law for protecting archaeological resources and Indian burial grounds and historic Implementation
Page 3-128, first three graves, permits for disturbing an archaeological site, and concern or 29 bullets on the page prohibitions of knowing disturbance of burials/graves. recommendation C35_P46_N108
[PDF page 7 of 14]
"we don't have these - it was put in our code, but never was done. Honestly, we don't have utility incentives either.
We have facade Implementation Page 3-128, third improvement grants, code relief and property tax reduction concern or 30 paragraph incentives" - regarding sidewalk grants to support preservation. recommendation C35_P46_N108
"Since Cultural Resources are the most adversely impacted in all alternatives - it seems that proactive mitigation like a City-wide
historic preservation plan should be considered.
It would be useful for future development as well as a tool for developers to use to avoid major impacts to highly concentrated areas of Implementation
Page 3-129, first sentence historic resources" - regarding impact mitigation under all concern or 31 under Cultural Resources alternatives. recommendation C35_P46_N108
Page 3-129, second "Our office is unclear on what threshold will trigger the decision Implementation
paragraph under Cultural tree: all projects, projects of certain size, grading?" - regarding the concern or 32 Resources 'decision tree' for below-ground cultural resources. recommendation C35_P46_N108
"This is beyond just inadvertent discoveries.
A city-wide historic Page 3-132, first preservation plan would be an important tool for us and planning" -Implementation
paragraph under Cultural regarding the proactive consideration of impacts to cultural concern or 33 Resources resources vs a reactive response. recommendation C35_P46_N108
General support "HP loves this." & "Hear, hear!" & "Although, I'm not sure what and Page 3-187, Exhibit 3.5-44 'preservation credits' are?
Tax credits?" regarding the incentives Implementation C35_P46_N107
line 16, Low-Cost Rental aimed at presenting displacement and preserving naturally concern or &
34 Housing Preservation occurring affordable housing. recommendation C35_P46_N108 Page 3-217, Exhibit 3.6-5,
Line 13 Historic "adversely affect" - recommend adding "adversely" to the 35 preservation description of potential impacts to cultural resources.
Mitigation needs C35_P46_N109
[PDF page 8 of 14]
"I wish this included language about increased survey work so we can be proactive not reactive in identification of resources." &
"Exactly.
Mitigation for this adverse impact should be city-wide Implementation Page 5-7, first bullet on survey work so that we can use 'available data'." regarding the concern or 36 the page and sub-bullets documentation of cultural and historic resources regulations. recommendation C35_P46_N108
"I don't know if this section should include the Preservation of Page 5-14, Exhibit 3, Salvageable Materials ordinance (15.06) since it requires any
Line 13 Historic and building that is eligible for listing on the Spokane Register to be Cultural Preservation - deconstructed for important historic material preservation before
Local demolition may occur?
Or maybe it is better located with the Detail accuracy environmental section?" - regarding the Local sub-category. concern C35_P46_N105
[PDF page 9 of 14]
C35_P46 Comments Summary Spokane Historic Landmarks Commission Comment Log Location in Document Comment Category
Assignment Page 1-4, Note under "Manito/Cannon Hill as well?" - regarding neighborhoods too Detail accuracy
Exhibit 1.1-2. small to be labeled at map scale. concern C35_P46_N105 "Highest levels of potential impact equals high levels of Page 1-15, Exhibit 1.4-2. mitigation" - regarding negative impacts to cultural and historic
2 Line 4 resources. Mitigation needs C35_P46_N109 "but more risk to historic buildings and neighborhoods" -
Page 1-25, bullet 3 under regarding higher risk to historic buildings from concentrated 3 Cultural Resources development in Center City and Hillyard due to Alternative 3. Mitigation needs C35_P46_N109
Page 1-26, bullet 4 under "nomination and regulation of" - appears to recommend What are some solutions changing language from only nominating historic landmarks or Recommended
4 or mitigation for impacts? districts, to also regulating them. regulation C35_P46_N110 "This is a fantastic mitigation strategy as far as preventing adverse
impacts to CR and HP resources, but I do wonder about the General support workload to do the review in this decision tree with only two and Page 1-26, bullet 5 under historic preservation staff" - regarding applying cultural resources Implementation C35_P46_N107
What are some solutions discovery policies to the full city limits, and develop a decision concern or &
5 or mitigation for impacts? tree to investigation/mitigation scale. recommendation C35_P46_N108
"This is articulated well and our office appreciates the inclusion of this language" - regarding the acknowledgment of Page 1-26, final potential/significant adverse impacts, and the desire for a 6 paragraph, protective vs reactive response in preserving resources.
General support C35_P46_N107
"In my opinion, formalizing this process seems especially Implementation important in light of the SEPA exemptions possibility" - regarding concern or 7 Page 1-27, first sentence the pre-project cultural resource review process. recommendation C35_P46_N108
[PDF page 10 of 14]
"Another effective way to mitigate is to do more proactive survey of historic and cultural resources. The city has not funded any big work on that front recently and all recent large-scale survey work has been funded with federal pass-through money" - regarding Implementation avoiding, minimizing, and mitigating adverse impacts to cultural concern or 8 Page 1-27, first sentence and historic resources. recommendation C35_P46_N108
"It feels like this is mostly concerned with archaeology (ie. 'inadvertent discoveries') - how are we thinking about mitigation for actions that result in the loss of historic built environment?" -
9 Page 1-27, first sentence regarding avoiding, minimizing, and mitigating adverse impacts. Mitigation needs C35_P46_N109
Page 1-29, first "Exactly.
Twice as many demolitions of existing housing units" & sentence under "This is a HUGE impact that I feel like needs more mitigation" -
Housing Production regarding the expectation that Alternatives 2 and 3 will demolish and Displacement over twice as many housing units compared to Alternative 1. Mitigation needs C35_P46_N109
Page 3-104, first paragraph under Building "Love this context setting downtown.
Good writing" - regarding
11 Types and Styles the architectural and historical variety of buildings downtown.
General Support C35_P46_N107
Page 3-104, second paragraph under Building "late 19th and early 20th century buildings" - regarding the Detail accuracy
12 Types and Styles description of the buildings downtown. concern C35_P46_N105 Page 3-104, third
paragraph under Building "late 19th and early 20th century" - regarding the description of Detail accuracy
13 Types and Styles early Spokane development. concern C35_P46_N105 Page 3-104, third "single unit homes in a variety of architectural styles" -
paragraph under Building recommended replacement of "craftsmen" as the description for Detail accuracy
14 Types and Styles the single unit homes. concern C35_P46_N105 Page 3-104, third paragraph, second
sentence under Building "and vary from" - recommended replacement of "all" in the 15 Types and Styles description of the height and scale of development.
Editing C35_P46_N106
[PDF page 11 of 14]
Page 3-104, third paragraph, second "to large historic homes and apartments on a typical grid street
sentence under Building pattern" - recommended inclusion in the description of the height "This map shows how the proposed decision tree would result in a lot of survey required depending on the threshold to initiate the Implementation
tree" - regarding the State Archaeological Risk Assessment Model concern or 17 Page 3-107, Exhibit 3.4-16 map. recommendation C35_P46_N108
"My guess is that this is actually referring to the Browne's Addition National Register Historic District Nomination from 1976
Page 3-108, first (https://properties.historicspokane.org/_pdf/districts/national/dis paragraph under Historic trict-national-18.pdf)" - regarding the Washington State Office of Detail accuracy
18 Resources Archaeology and Historic Preservation citation. concern C35_P46_N105 Page 3-108, third "and over 1,000 more properties included in local historic
19 paragraph under Historic districts" - regarding the over 400 individual historic sites Detail accuracy
Resources described. concern C35_P46_N105 Page 3-108, Exhibit 3.4- 20 17, Line 3 "e's" - regarding the spelling of Browne's Addition Editing C35_P46_N106
"We have added the Cannon Hill Park Local Historic District - in effect on 12/25/2025.
We don't have the acres handy, but can get
that info to you. Not on the National Register, South for area.
We could pretty easily give you the number of properties for these
rather than the acreage...but maybe there is a good reason for Page 3-108, Exhibit 3.4- using acreage" - regarding the Cannon Streetcar Suburb Detail accuracy
21 17, Line 4 information in the table. concern C35_P46_N105 "I know a pain, but not sure if you want to update these maps to include the newest local historic district.
It should be added to GIS
before end of January." & "Will want to add the newest Historic Detail accuracy 22 Page 3-109, Exhibit 3.4-18 District." concern C35_P46_N105
[PDF page 12 of 14]
Page 3-123, first paragraph under Cultural "and areas around the Spokane River" - regarding areas with Detail accuracy
23 Resources potential for Cultural Resource disturbance. concern C35_P46_N105 Page 3-123, second
paragraph under Cultural "adversely impact" - recommend adding "adversely" to the 24 Resources description of potential impacts to designated historic properties.
Mitigation needs C35_P46_N109
Page 3-126, third bullet
under Alternative 3:
Center City and Regional "Why is this related to CR?" - regarding the higher job growth 25 Hubs described in alternative 3.
Applicability C35_P46_N104
Page 3-126, third bullet under Alternative 3: "We have protections against demolition in local historic districts
Center City and Regional like Hillyard" - regarding pressure to alter or demolish historic Detail accuracy
26 Hubs buildings or districts in Hillyard. concern C35_P46_N105 Page 3-126, third bullet under Alternative 3: Implementation
Center City and Regional "We need ADDITIONAL incentives if we want to keep historic concern or 27 Hubs buildings in use" - regarding encouraging adaptive reuse. recommendation C35_P46_N108
"I guess I am still a little unsure of this reasoning." & "I agree - just Page 3-126, third bullet because you can develop in the areas called out in Alternative 3
28 under Alternative 3: doesn't mean no one will want to build in lower density areas" - Center City and Regional regarding the described less risk from development pressure
Hubs under Alternative 3.
Mitigation needs C35_P46_N109 "We just did one of these and we caught it in pre-dev.
I am glad we
caught it, but I am a bit nervous of a non-mandatory process being the best way to catch one of these with even more SEPA
exemption" - regarding Washington State Law for protecting archaeological resources and Indian burial grounds and historic Implementation
Page 3-128, first three graves, permits for disturbing an archaeological site, and concern or 29 bullets on the page prohibitions of knowing disturbance of burials/graves. recommendation C35_P46_N108
[PDF page 13 of 14]
"we don't have these - it was put in our code, but never was done. Honestly, we don't have utility incentives either.
We have facade Implementation Page 3-128, third improvement grants, code relief and property tax reduction concern or 30 paragraph incentives" - regarding sidewalk grants to support preservation. recommendation C35_P46_N108
"Since Cultural Resources are the most adversely impacted in all alternatives - it seems that proactive mitigation like a City-wide
historic preservation plan should be considered.
It would be useful for future development as well as a tool for developers to use to avoid major impacts to highly concentrated areas of Implementation
Page 3-129, first sentence historic resources" - regarding impact mitigation under all concern or 31 under Cultural Resources alternatives. recommendation C35_P46_N108
Page 3-129, second "Our office is unclear on what threshold will trigger the decision Implementation
paragraph under Cultural tree: all projects, projects of certain size, grading?" - regarding the concern or 32 Resources 'decision tree' for below-ground cultural resources. recommendation C35_P46_N108
"This is beyond just inadvertent discoveries.
A city-wide historic Page 3-132, first preservation plan would be an important tool for us and planning" -Implementation
paragraph under Cultural regarding the proactive consideration of impacts to cultural concern or 33 Resources resources vs a reactive response. recommendation C35_P46_N108
General support "HP loves this." & "Hear, hear!" & "Although, I'm not sure what and Page 3-187, Exhibit 3.5-44 'preservation credits' are?
Tax credits?" regarding the incentives Implementation C35_P46_N107
line 16, Low-Cost Rental aimed at presenting displacement and preserving naturally concern or &
34 Housing Preservation occurring affordable housing. recommendation C35_P46_N108 Page 3-217, Exhibit 3.6-5,
Line 13 Historic "adversely affect" - recommend adding "adversely" to the 35 preservation description of potential impacts to cultural resources.
Mitigation needs C35_P46_N109
[PDF page 14 of 14]
"I wish this included language about increased survey work so we can be proactive not reactive in identification of resources." &
"Exactly.
Mitigation for this adverse impact should be city-wide Implementation Page 5-7, first bullet on survey work so that we can use 'available data'." regarding the concern or 36 the page and sub-bullets documentation of cultural and historic resources regulations. recommendation C35_P46_N108
"I don't know if this section should include the Preservation of Page 5-14, Exhibit 3, Salvageable Materials ordinance (15.06) since it requires any
Line 13 Historic and building that is eligible for listing on the Spokane Register to be Cultural Preservation - deconstructed for important historic material preservation before
Local demolition may occur?
Or maybe it is better located with the Detail accuracy environmental section?" - regarding the Local sub-category. concern C35_P46_N105