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Historic Preservation Tax Credits. The Process and Avoiding Common Problems Charles E. Fisher New York City, June 2009. National Park Service, Technical Preservation Services. Success. Projects approved – 36,000 Investment of over $50 billion Repeat users. It Is a Regulatory Program.
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Historic Preservation Tax Credits The Process and Avoiding Common Problems Charles E. Fisher New York City, June 2009 National Park Service, Technical Preservation Services
Success • Projects approved – 36,000 • Investment of over $50 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
What 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 Certifications Are Needed • Certified Historic Structure • Certified Rehabilitation
Three-Part Historic Preservation Certification ApplicationPart 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
Certified Historic Structure For a certified property with multi-buildings, such as a mill complex or a former military base, 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
Part 1 Review paper trail routine communication Applicant SHPO NPS
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 • Most projects approved with conditions
Three-Part Historic Preservation Certification ApplicationPart 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 • 10 broad principals of preservation • Widely used by other agencies and organizations • Only NPS issues certifications
Part 2 and 3 Reviews Applicant paper trail communication project specific and/or state specific SHPO NPS
Three-Part Historic Preservation Certification ApplicationPart 3 Request for Certification of Completed Work (the last step) • Submitted only after work is completed • Issued by NPS only after 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 both before (existing condition) plans and rehabilitation (after) plans • Provide thorough photo documentation of the entire property in its before work condition— if shooting electronic images (good resolution), print on photo quality paper • 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
Special Considerations During The Current Economy • Need to clearly establish what has been approved by NPS when there is a change in ownership during rehab
Special Considerations During Current Economy • Dealing with large multiple building projects – phasing and financing • Obtaining Part-3 (final) certification – tenant fit-out
State Incentives • More than half of the states have tax credits or other incentives that can be piggybacked with the Federal tax credits • Current budgetary pressure on state tax credit programs
For Additional Information • NPS website is www.nps.gov/history/hps/tps • SHPO websites • To request copy of NPS 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; email NPS_HPS-info@nps.gov