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Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

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Page 1: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

Historic Preservation Tax Credits

The Process and Avoiding Common Problems

National Park Service, Technical Preservation Services

Page 2: 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

Page 3: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

It Is a Regulatory Program

• Not uncommon that there will be some required changes

• Submit your project for review early in the planning process

Page 4: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

Who

• Administered by the National Park Service in conjunction with State Historic Preservation Offices (SHPO)

Page 5: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

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

Page 6: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

Where

• Most SHPO offices are located in the state capital

• National Park Service’s Technical Preservation Services is in Washington, DC

Page 7: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

Two Certification Are Needed

• Certified Historic Structure

• Certified Rehabilitation

Page 8: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

Three-Part Historic Preservation Certification Application

Part 1—Evaluation of Significance

• Is my building historic?

Page 9: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

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

Page 10: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

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

Page 11: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

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

Page 12: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

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?

Page 13: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

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

Page 14: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

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

Page 15: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

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

Page 16: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

If Your Project is Denied

• First, try to resolve the issues

• Alternative is the Appeals Process

Page 17: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

Avoiding Common Problems

• Start the process early in the project planning

• Consult early with the SHPO

• Get decisions in writing from NPS

Page 18: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

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

Page 19: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

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

Page 20: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

Common Rehabilitation Issues— New Construction

• New buildings or new onsite parking

• Rooftop additions and mechanical equipment

• Adjacent and connecting new additions

Page 21: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

Common Rehabilitation Issue—Exteriors

• Ground floor changes to commercial buildings

• Window work

• New balconies

Page 22: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

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

Page 23: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

State Incentives

• More than half of the states have tax credits or other incentives that can be piggybacked with the Federal tax credits

Page 24: Historic Preservation Tax Credits The Process and Avoiding Common Problems National Park Service, Technical Preservation Services

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