Meeting the Secretary’s Standards: NPS Guidance on Special Issues

1. Meeting the Secretary’s Standards: NPS Guidance on Special Issues Gary Sachau, National Park Service Historic Tax Credit Developer’s Conference St. Pete Beach, Florida February 7 and 8, 2008

2. NPS Publications

3. http://www.nps.gov/history/hps/tps/tax Standards Guidance Search by Topic

4. http://www.nps.gov/history/hps/tps/tax/guidance.htm Report: Final Guidance and Implementation of NPSAB Recommendations (includes summary of NPS flexibility on the specified topics)

5. Interpreting and Applying the Secretary of the Interior’s Standards for Rehabilitation • Project meets Standards when overall effect of all work is consistent with property’s historic character, even when some individual features may not have been given “recommended” treatments.

6. Evaluating Historic Windows for Repair or Replacement • Other factors may be considered, in addition to deterioration, in determining that historic windows may be replaced. • Historic windows that do not meet safety requirements may be replaced with matching windows. • Replacement of very small percentage of total number of historic windows does not need to be justified by deterioration. • A full window survey is not required to document deterioration.

7. Replacement Windows that Meet the Standards • The more important a window is, the more critical it is to match: • Primary facades, 3 stories or less. • Primary facades, base of high-rise. • Existing windows that are not historic may be replaced with compatible new windows—these new windows need not replicate missing historic windows. • Substitute materials may generally be used for replacement windows on secondary elevations of buildings, and above the base on all elevations of tall buildings.

8. Documentation Requirements for Proposed Window Replacement • Clear photos of existing windows. • Same-scale drawings (with measurements, materials): • Elevations, horizontal and vertical sections of existing windows. • Elevations, horizontal and vertical sections of proposed replacements. • Small projects, windows with simple design– cut sheets may be acceptable.

9. Documentation Requirements for Proposed Window Replacement - 2

10. Identifying Primary and Secondary Interior Spaces in Historic Buildings • Primary spaces – essential in conveying the historic character of a building. • Secondary spaces – less critical in defining a building’s importance; because of size, location, or function.

11. Identifying Primary and Secondary Interior Spaces in Historic Buildings - 2 • Guidance on primary and secondary spaces within certain building types: • Houses, rowhouses, duplexes • Apartment Buildings and tenements • Shotgun houses • Schools • Factories, industrial buildings and warehouses • Fraternal and lodge halls • Commercial office buildings • Churches • Hotels • Hospitals

12. Changing Secondary Interior Spaces in Historic Buildings • Secondary spaces offer more opportunities for change and alteration: • May be subdivided vertically (new walls) or horizontally (new floors, mezzanines). • New floor openings may be introduced.

13. Subdividing Assembly Spaces in Historic Buildings • Public assembly spaces, such as auditoriums and ballrooms, usually most significant spaces. • More opportunity for change is provided where finishes and features are seriously deteriorated or missing, or where space has already been significantly altered—surviving historic character must be maintained, but such spaces are never required to be restored or reconstructed. • Opportunity for alteration or subdivision is provided in treatment of assembly spaces that are not primary, or are secondary to other assembly spaces in same building.

14. Retaining Corridors and Other Circulation Spaces in Historic Buildings • Corridors almost always primary spaces. • Opportunity for change provided through shortening or truncating corridor ends. • More opportunity for change where integrity of corridors was previously eroded.

15. New Additions to Historic Buildings • Evaluating new additions in accordance with Standards 9 and 10: • Historic building’s form/envelope, materials and features must be preserved. • Addition must be compatible (massing, size, scale, features, location). • Addition must be differentiated from historic building—Standards do not dictate style so long as compatibility is achieved and historic fabric is preserved.

16. New Additions to Historic Buildings - 2 • New additions in densely built environments, urban historic districts: • May be opportunity for larger addition when façade of addition can be broken up into elements consistent with scale of historic building and surrounding structures.

17. New Construction within the Boundaries of Historic Properties • Property’s historic function and setting must remain evident. • Compatibility of new construction viewed in a wider context, and may allow greater size and design flexibility the further away the new construction is from historic buildings.

18. Codes and Regulatory Requirements for Rehabilitating Historic Buildings • Evaluations for code and other performance requirements must be done on a building-by-building basis. NPS continues to encourage early consultation to ensure that proposed modifications comply with both code requirements and the Standards. • NPS will continue to work with national code/regulatory organizations and preservation organizations to seek solutions that promote preservation of historic materials and features (performance-based requirements).

19. Energy Efficiency, Sustainability, and Green Building Practices in Historic Buildings • Rehabilitating a historic building, rather than constructing a new one, reflects philosophy of environmental sustainability and “green” building practices. • NPS will continue to work with consortium to re-evaluate Leadership in Energy and Environmental Design (LEED) requirements in context of historic buildings and the Standards.

20. Evaluating Substitute Materials in Historic Buildings • If original material is too deteriorated to repair, compatible substitute material may be acceptable. • New technologies will likely lead to improvements in appearance and performance of substitute materials.

21. Very Large and Diverse Historic Properties Listed in the National Register as Historic Districts • Very large historic properties, such as military bases, will be treated as historic districts, allowing NPS to review distinct usage-related groupings as “functionally related buildings.” • Each grouping, along with associated site and environment, will be considered single project (further defined by ownership parcel). • Long-term lessees will be treated as owners.

22. Functionally Related Structures—General Criteria • Select criteria on specific property types: • Industrial sites • Commercial properties • Domestic properties • Apartments, public housing and other multi-family housing • Military bases, university campuses, medical and corporate campuses

23. Meeting the Secretary’s Standards: NPS Guidance on Special Issues Gary Sachau, National Park Service Historic Tax Credit Developer’s Conference St. Pete Beach, Florida February 7 and 8, 2008