historic preservation tax credits the process and avoiding common problems national park service,...

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 NPS_HPS-info@nps.gov

• Or write Technical Preservation Services, National Park Service, 1840 C Street NW, Washington, DC 20240