City of Detroit
HISTORIC DESIGNATION ADVISORY BOARD
218 Coleman A. Young Municipal Center, Detroit, Michigan 48226
Phone: 313.224.3487 Fax: 313.224.4336
December 7, 2021
Mr. Robb McKay
State Historic Preservation Office
300 North Washington Square
Lansing MI 48913
RE: Draft Rules Comments
Dear Mr. McKay,
Thank you for the opportunity to review the proposed rulemaking for the State Historic Tax Credit program.
On behalf of the Detroit City Council Historic Designation Advisory Board, please accept these comments
Revise the proposed fee structure for owner-occupied residential properties pending public
comments from large municipalities such as Detroit, Flint, Pontiac, Saginaw, etc. Recommend
reducing to $50 per application, regardless of anticipated qualified expenses.
Recommend inserting specific language that bars individual property owners from receiving
simultaneous tax credits for multiple projects at different locations.
Recommend specifying the photograph quality that will be accepted as part of the application(s)
rather than current “deemed sufficient” language.
Will applications be able to be submitted directly via the SHPO website? Otherwise, recommend
specifying how applications will be submitted (i.e. whether or not it will be permissible to submit
electronically or only by mail).
Recommend shortening the Part 1 Application (certification of historic significance) timeline for
review to 60 days of receipt of complete application. The current 120 days (i.e. 4 months) might
have the unintended consequence of delaying successful applications beyond the calendar year.
Please specify the deadline to issue the certification letter after a complete Part 2 Application is
submitted to the SHPO. Recommend 60 days.
If you require any additional information, you can reach out to Janese Chapman, Director of HDAB, directly
Dr. Carolyn Carter
Chair, Historic Designation Advisory Board