“A symbol of what could have been — and who stopped it.” Banks had a chance to honor its history. That chance was extinguished by decision-makers who treated our most historic building as an obstacle instead of an asset.

Setting the Record Straight: A Fact-Based Response to the School District’s Opposition to Historic Designation

This response exists because the truth is being rewritten. The National Register nomination was simply an attempt to honor Banks’ historic school before it was destroyed. By opposing the nomination and claiming the building was never historic, the District is trying to make that demolition easier to defend — even though the public record says otherwise.

This response addresses statements made in the Banks School District opposition letter as posted in the public BoardBook agenda for the January 12, 2026, Regular Board Session (6:00 PM).

Text from the District’s opposition letter appear in black italics. Responses appear in bold.

Source:

Banks School District Board of Directors. *Opposition Letter to National Register Nomination. *BoardBook agenda materials, January 12, 2026.

To Whom It May Concern, On behalf of the Banks School District Board of Directors and Superintendent Dr. Brian Sica, thank you for the opportunity to provide additional context regarding the application titled Banks Union High School and the proposed designation on the National Historic Registry.

Response:

Thank you for the opportunity to review this response. Accuracy and completeness of the historical record are essential when evaluating eligibility for the National Register of Historic Places.

We want to begin by acknowledging the deep care many members of our community have for this building and the role it has played in the shared history of Banks. We respect that connection and appreciate the thoughtful advocacy that has brought this application forward. At the same time, as the elected governing body of the District, we have a responsibility to weigh historical interest alongside student safety, educational adequacy, fiscal stewardship, and long-term community impact.

Response:

No one disputes the District’s responsibility to balance multiple considerations. However, National Register eligibility is based on historical significance and integrity, not on present-day operational preferences or future development plans.

For clarity, this letter is a formal response opposing the designation of the Banks District Administration Building, located at 12950 Main Street, Banks, Oregon. While the application references an address of 13050 Main Street, that address corresponds to the current high school and will remain the address following completion of the new construction.

Response:

Historic resource identification is based on the physical building and its documented history, not on contemporary address assignments. The Washington County Cultural Resource Inventory, City of Banks Goal 5 documents, and Oregon Historic Sites Database all identify the same historic structure regardless of address changes.

The building under consideration is registered with the Oregon Department of Education as the “District Administration Building.” After extensive study and public process, the Board determined that this structure has reached the end of its useful life and must be removed as part of the District’s long-term facilities plan.

Response:

Current administrative use and internal District determinations do not negate a building’s historic significance or eligibility for listing on the National Register. The assertion that the building had “reached the end of its useful life” is incorrect and is directly contradicted by the District’s own November 2023 feasibility study prepared by Soderstrom Architects. That study concluded: “It is the conclusion of this report that the most effective use for the district office structure would be to convert it to a media center to support future expansion of the high school.” A recommendation for adaptive reuse confirms that the building remained viable and capable of continued service and directly contradicts any determination that the structure had reached the end of its useful life or required removal.

Source:

Soderstrom Architects, Feasibility Study for Banks School District Office and Community Gym (Barn) Building (Nov. 2023), p. 4. https://drive.google.com/file/d/18znWJ71Iri3awVGyl1kx99-kTbu6vwDN/view

In January 2025, the Board adopted a 20-Year Master Plan for the District campus. That plan included removal of the District Administration Building, an auxiliary gymnasium, and two wings of the existing high school. This decision was not made lightly, nor was it sudden.

Response:

The Master Plan reflects a policy choice, not a historical evaluation under adopted preservation standards. Demolition being embedded in long-range planning does not substitute for, or preclude, an independent historic determination.

Historical context has been considered for decades. In the 1980s, the Washington County Museum conducted a county-wide inventory of cultural and historic resources. That inventory was not adopted. When Washington County formally adopted its Cultural Resources Inventory in 1989 through a public process, the Banks Union High School building was not included. In fact, there are no properties in Banks listed on the adopted County inventory.

Response:

This statement is not merely misleading; it is factually incorrect. The City of Banks’ adopted Comprehensive Plan and Goal 5 documentation demonstrate that Banks Junior High School was formally identified and recognized as a historic resource.

While an early county-wide inventory effort was undertaken in the 1980s, the Washington County Museum also sponsored a Cultural Resources Survey and Inventory for the City of Banks in 1984, which identified seven historically significant buildings, including Banks Junior High School. The City’s adopted Goal 5 documentation explicitly states that this inventory served as the starting point for the City’s historic resource evaluation.

The City of Banks formally amended its Comprehensive Plan in 1989 to recognize four buildings identified in that inventory, explicitly including Banks Junior High School. The building’s historic status was therefore not informal or provisional; it was adopted by the City as part of its planning framework. Further, as part of the 2002 Goal 5 Periodic Review, formally adopted in 2003, the City incorporated the 1984 Cultural Resources Survey and Inventory in its entirety, again identifying Banks Junior High School as a historic resource.

Accordingly, the assertion that the inventory “was not adopted,” that the building “was not included,” or that “there are no properties in Banks listed on the adopted County inventory” is not supported by the City of Banks’ adopted Comprehensive Plan and Goal 5 planning record.

Source:

City of Banks Comprehensive Plan (2003), pp. 201–203.

This conclusion is further confirmed by the Oregon Historic Sites Database, maintained by the State Historic Preservation Office, which includes an entry for Banks Union High School / Banks Junior High along with scanned Washington County Cultural Resource Inventory forms. The claim that no properties in Banks were included in adopted inventories is therefore contradicted by both City-adopted documents and State-maintained records.

Source:

Oregon Historic Sites Database, Banks Union High School / Banks Junior High record https://heritagedata.prd.state.or.us/historic/index.cfm?do=v.dsp_printRecord&resultDisplay=48675

That same year, the Banks City Council considered placing several properties, including this building, into a historic overlay. At that time, the building was determined to lack architectural distinction and to lack integrity due to surrounding development. The Council also recognized that additional regulatory requirements would impose an economic burden on the District and local taxpayers.

Response:

No adopted findings have been identified that establish the building as non-historic or ineligible for listing, and no National Register evaluation has ever concluded that the building lacks architectural distinction or historic integrity under federal criteria.

It is important to acknowledge that an early evaluation document from the early 1980s has been cited by the City in support of this claim. That document reflects a preliminary Washington County Cultural Resource Inventory evaluation that applied a numeric scoring system focused primarily on architectural distinction and physical integrity. However, it was not an adopted determination of non-historic status, nor was it a National Register evaluation, and it predates the City of Banks’ formal Goal 5 adoption process.

To the contrary, the Washington County Cultural Resource Inventory includes a detailed architectural description and explicitly recognizes the building’s historic role in local public life. The City of Banks’ adopted Comprehensive Plan further states, in the past tense, that Banks Junior High School had already been designated with the City’s Historic Resource Overlay Zone, directly contradicting the assertion that the building lacked recognized historic value.

Source:

City of Banks Comprehensive Plan (2003), pp. 207, bottom of page.

Despite this adopted designation, claims that the building lacks architectural distinction or historic integrity have continued to be repeated without citation to any adopted finding establishing ineligibility under National Register criteria. These claims are contradicted by the Washington County Cultural Resource Inventory, which identifies Banks Junior High School as architecturally significant as one of the few brick buildings in the area and notes its distinctive architectural detailing. Repetition of unsupported assertions has contributed to a public narrative favoring demolition rather than an objective evaluation grounded in the adopted historic record.

Source:

City of Banks Comprehensive Plan (2003), pp. 217–218.

Over the following decades, the District made multiple attempts to address facility needs through bond measures. While two measures passed prior to 2012, they did not provide sufficient funding to address the growing maintenance demands of the aging structure. By the early 2000s, the building was deemed unsafe for student use due to insufficient seismic capacity, and most of it became unoccupied.

Response:

Operational safety concerns and funding challenges do not determine National Register eligibility and were not part of the historic evaluation criteria used in the County or City inventories. The building’s noncompliance with modern seismic standards for active public school use does not mean it was inherently unsafe, unusable, or incapable of continued service. Like many older civic, commercial, and residential buildings, it required repairs and upgrades to meet contemporary standards. The need for rehabilitation or modernization does not render a historic building unsalvageable or establish removal as the only reasonable course of action.

As the District itself states below, by 2018–2019 a facilities planning committee was already evaluating the building with removal as the recommended outcome. Once that direction was adopted internally, reduced use and physical deterioration followed from policy and funding decisions, including the decision to discontinue meaningful investment in the building rather than pursue rehabilitation or adaptive reuse. Over time, this sequence of decisions contributed to a narrative that the building was beyond repair, even though that conclusion was never established through a comprehensive or unbiased evaluation.

In 2018 and 2019, a facilities planning committee made up of staff and community members evaluated District buildings and recommended removal of the administration building. That work resumed in earnest in 2023 and 2024 as part of preparation for a bond election and a comprehensive master planning process. Throughout that time, all conceptual plans presented to the public showed removal of the building.

Response:

This timeline confirms that removal had already been established as the preferred outcome prior to later public engagement, substantially limiting the neutrality of alternatives considered. The facilities planning committee referenced was a limited advisory group and did not represent the full District or its taxpayers. Its recommendation to remove the building was not based on an equal evaluation of preservation, rehabilitation, or adaptive reuse alternatives, yet it set demolition as the default assumption before broader public engagement occurred.

The assertion that “all conceptual plans presented to the public showed removal of the building” further conflates internal planning materials with voter disclosure. The voting public did not rely on conceptual site plans when approving the bond measure; it relied on the bond language presented on the ballot. That language did not disclose plans to demolish the historic Banks Union High School building or to replace District administrative offices. At the time of the bond vote, the historic building housed those offices. In the absence of such disclosure, many voters reasonably assumed the building would remain in use.

Accordingly, the claim that the public was aware of or consented to demolition is not supported by the ballot language. The planning history reflects a process in which demolition was treated as the expected outcome, rather than the result of a transparent evaluation that the broader community understood and approved.

Additionally, following the passage of the Bond Authorization, the Board also directed the District’s architectural firm to explore two scenarios: one that removed the building and one that attempted to incorporate it.

Response:

Because demolition had already been embedded in the District’s long-term planning framework, the two scenarios were not evaluated from a neutral starting point. The scenario incorporating the historic building was developed later, in response to preservation advocacy, and was consistently treated as secondary to demolition.

Plans that retained the historic building were introduced late, received limited analysis, and were not advanced by the administration as viable alternatives. Even when a cost-neutral option retaining the building was presented, it was not meaningfully considered: the Board voted two days later, the alternative was never presented to the public, and the process was not paused for review.

This sequence demonstrates that preservation alternatives were structurally disadvantaged and that demolition was favored throughout the process — not because preservation was infeasible, but because earlier decisions constrained and biased subsequent evaluation.

The resulting master planning process, conducted over six months in late 2024, involved monthly Board meetings with unlimited public comment, multiple supplemental work sessions, open community forums, one-on-one meetings, and direct engagement with concerned community members, including the Banks Historical Society.

Response:

While the District describes extensive opportunities for public input and engagement, participation alone does not demonstrate an unbiased or neutral evaluation of alternatives. Community members who opposed demolition, including those who participated consistently throughout the process, reported that demolition remained the assumed outcome and that renovation and adaptive reuse were not evaluated on equal footing.

Additionally, multiple participants reported that the tone and dynamics of public meetings discouraged open expression of dissenting views. Although public comment was technically permitted, the meeting environment was not consistently conducive to meaningful consideration of alternatives, particularly those involving preservation or adaptive reuse.

Engagement occurred within a framework where removal had already been established as the preferred direction. As a result, public input was received after key assumptions had been set, limiting the objectivity of the review and the meaningful consideration of preservation alternatives.

After evaluating all reasonable alternatives… the Board reached the following conclusions: [bullet points omitted for brevity]

Response:

These conclusions reflect project feasibility, cost, and scope considerations, not an evaluation of historic significance or integrity under National Register criteria. While such factors may inform internal planning decisions, they are not determinative of eligibility for listing.

The conclusions also fail to acknowledge that renovation and adaptive reuse of the historic building were viable alternatives capable of preserving an important community landmark while addressing functional needs. Such an outcome had the potential to honor Banks’ heritage and serve as a unifying solution for the community. However, because demolition had already been established as the preferred outcome, renovation and adaptive reuse were not evaluated from a neutral standpoint and were never afforded meaningful or equitable consideration.

Based on these findings, the Board formally concluded… that demolition is the only prudent and fiscally responsible option.

Response:

Fiscal prudence is not a criterion for National Register eligibility. Moreover, the assertion that demolition is the only prudent and fiscally responsible option is unsupported by the record. Such a conclusion would require a neutral, comparative evaluation of reasonable alternatives, including rehabilitation and adaptive reuse, which did not occur.

The record reflects a policy choice reached through a planning process in which demolition had already been established as the preferred outcome, constraining later analysis. Fiscal considerations were treated as determinative, while the historic, cultural, and community value of retaining a documented historic resource was not meaningfully evaluated or weighed. As a result, the conclusion reflects planning assumptions and value judgments, not an objective assessment of historic significance, preservation potential, or eligibility under National Register criteria.

Importantly, opposition to this designation does not reflect a disregard for history… mitigation strategies already underway.

Response:

Mitigation measures, while valuable, are not substitutes for preservation and do not negate a building’s eligibility for listing. Under established preservation practice, mitigation is a secondary measure applied only after preservation has been rejected; it does not offset the loss of a historic resource or substitute for a good-faith evaluation of preservation alternatives.

At the time of this submission, the District is well into the construction process…

Response:

The timing of demolition activities does not alter the historical record or the building’s eligibility for designation. Although demolition would effectively preclude the next step in the nomination process, that procedural outcome does not negate the building’s documented historic significance. Nor does it justify opposing designation on the basis of inaccurate or misleading claims. The possibility that demolition may prevent further review only heightens the importance of ensuring that the record before decision-makers is complete and accurate.

For these reasons… the Banks School District Board of Directors respectfully opposes designation…

Response:

The documentary record demonstrates that Banks Union High School was formally inventoried, recognized by the City of Banks, and never found non-historic. The District’s opposition relies on assertions that are contradicted by the City’s own adopted documents and planning record. Repeating those assertions perpetuates a narrative that does not reflect the historical facts and should not be the basis for evaluating National Register eligibility. Eligibility determinations must rest on the documentary record, not on policy preferences or post hoc justifications

References:

**City of Banks Comprehensive Plan*, adopted February 11, 2003

• (see pp. 201–203, 207–208, 217–218)

Soderstrom Architects. *Feasibility Study for Banks School District Office and Community Gym (Barn) Building*. November 2023.

**Oregon Historic Sites Database. *Banks Union High School / Banks Junior High*.**