Historic Preservation Tax Credits
The Process and Avoiding Common Problems
National Park Service, Technical Preservation Services
Success
• Over 36,000 projects approved
• Promoted investment of over $48 billion
• Repeat users
It Is a Regulatory Program
• Not uncommon that there will be some required changes
• Submit your project for review early in the planning process
Who
• Administered by the National Park Service in conjunction with State Historic Preservation Offices (SHPO)
What
• Unlike most other historic preservation review processes, your entire project will be reviewed
• Interior and exterior work on the historic building/s
• Any new construction on the site
• Parking
Where
• Most SHPO offices are located in the state capital
• National Park Service’s Technical Preservation Services is in Washington, DC
Two Certification Are Needed
• Certified Historic Structure
• Certified Rehabilitation
Three-Part Historic Preservation Certification Application
Part 1—Evaluation of Significance
• Is my building historic?
Certified Historic Structure
• Individually listed in the National Register of Historic Places
• Contributes to a National Register historic district
• Contributes to a registered historic district• For certified multi-building properties such
as a mill, only contributing buildings are eligible
Preliminary Determinations
• Proposed individually listed National Register property
• Contributing building in a potential historic district
• Certified Historic Structure status must be obtained no later than 30 months after the building is placed in service
Project Review
• Consult early on in the planning process with the SHPO
• Seek preliminary review from the National Park Service on potentially problematic issues prior to submission of Part 2 of the Application
Three-Part Historic Preservation Certification Application
Part 2—Description of Rehabilitation
• Does my proposed work meet the Secretary of the Interior’s Standards for Rehabilitation?
Secretary of the Interior’s Standards for Rehabilitation
• Widely used set of 10 broad principles intended to the historic character of the property
• Same NPS office issuing tax credit certifications administers the Standards for Rehabilitation
Three-Part Historic Preservation Certification Application
Part 3 Request for Certification of Completed Work (the last step)
• Submitted only after work is completed
• Issued by NPS only for certified historic structures where completed work has met the Standards for Rehabilitation
Phased Advisory Letters
• Projects involving multiple buildings in a complex that are being rehabbed one at a time
• Large building rehabilitation being done in distinct phases
If Your Project is Denied
• First, try to resolve the issues
• Alternative is the Appeals Process
Avoiding Common Problems
• Start the process early in the project planning
• Consult early with the SHPO
• Get decisions in writing from NPS
Avoiding Common Problems— Part 2 Application
• Include before and proposed after plans
• Provide good photographic documentation of the entire property in its before work condition
• Authorize prepayment of processing fee charged by NPS
Avoiding Common Problems
• Check websites of SHPO and NPS for additional information on the application submission
• Keep track as to which set of architectural plans have been approved
• Use services of a preservation consultant as needed
• Realize each project is different
Common Rehabilitation Issues— New Construction
• New buildings or new onsite parking
• Rooftop additions and mechanical equipment
• Adjacent and connecting new additions
Common Rehabilitation Issue—Exteriors
• Ground floor changes to commercial buildings
• Window work
• New balconies
Common Rehabilitation Issues—Interiors
• Dividing significant rooms or major common spaces
• Redefining a building’s basic floor plan
• Exposing mechanical ductwork in traditionally finished spaces
• Removing plaster to expose masonry walls and ceiling joists
State Incentives
• More than half of the states have tax credits or other incentives that can be piggybacked with the Federal tax credits
For Additional Information
• NPS website is www.nps.gov/history/hps/tps• To request copy of the Technical Preservation
Services Catalog of over 100 publications either email at [email protected]
• Or write Technical Preservation Services, National Park Service, 1840 C Street NW, Washington, DC 20240