Video
Advanced Training on Historic Preservation Certification Applications – Webinar #2
Transcript
(Brian Goeken) Hello, my name is Brian Goeken and I am the Chief of the National Park Services Technical Preservation Services Office. Thank you for joining us for the second of this five webinar training series on the Historic Preservation Certification Application and the application submission requirements. In this webinar, we are focusing on Part 1 applications and presenting today are Paul Lusignan and Roger Reed from the National Park Service National Register Program with whom our office closely coordinates in the review of HPCA applications.
(Paul Lusignan) Hi, my name is Paul Lusignan and I'm a historian with the National Register of Historic Places Program in Washington, DC Office of the National Park Service. I will start off this session with a look at the Part 1 application of the certification process where we determine if a property qualifies as a certified historic structure and is therefore eligible for the historic tax credits. We’ll try to give you a sense of what we at the National Park Service are looking for when we review a Part 1 application, outlining best practices and common issues so that we can all work to reduce holds and facilitate the certification process. Again, this is not intended to be a 101 intro course. We assume you have some advanced knowledge and experience with the program, but I’ll try and outline what is essential in a Part 1. And as we seek ways to both streamline the process, also, we’re sure we have essential information that we need to review the application.
Sometimes it can be as simple as considering three things which are true for both National Register nominations as well as Part 1 certifications, and that would include focus, context, and interconnectivity. Focus, as you approach the creation of a Part 1 application, it is key to keep in mind the goal of providing sufficient information with which to make informed decisions on National Register eligibility. Part 1s are not the repository for the definitive history of the community or biographies of all the individuals who have come in contact with the place. Does the information I am providing aid in making informed decisions on eligibility? Does the description capture the particular qualities of the property? Does the history provided aid in understanding the resource? It is easy to throw the kitchen sink into a submission, but much harder to consider what is essential to answering that eligibility question.
Next, context. Resources do not exist in a vacuum. Each is a reflection of its location, time, and history. In order to evaluate a property, we need to be provided with sufficient context to understand why any of that is important. Again, however, it’s important to focus that context on the question of eligibility. What do I need to know about this particular resource to evaluate its role, importance, or significance? And the final one that I’d like to call interconnectivity. All of the pieces of the Part 1 go to serving those goals of establishing significance. The description, maps, images, history, all working together to convey the story. When those pieces do not connect, leave gaps or open questions, then the Part 1 may fail and we have a hold or a return. So you ask yourself, as you’re preparing the Part 1, do the images correspond to the description presented? Does the description note all the buildings and additions shown on the maps? And is the context that we read relevant to this particular building and this particular time? Now, let’s look at all the component pieces of a Part 1.
Next, the description section. The property must be described, highlighting the important physical features. The significance of the property will often guide the identification of character, defining features, and the level of detail necessary. The Criterion C argument, for instance, might focus more heavily on details of design, whereas the Criterion A argument may focus more on form and the ability to convey function and use. Understanding how significance is reflected in the physical property is important. It’s more than just historic materials. It can include spaces, interiors, landscapes, and setting. All those components that go together to create an active description of a property.
Next, include all resources. All buildings, structures, objects, and sites that are associated with the property need to be described and evaluated within the property’s significance. This is a common omission, thinking only the main building matters. The levels of discussion will vary again based on the types of resources, with the factory complex perhaps demanding a comprehensive discussion of every element, while a housing garage may allow a simplified mention of the outbuildings. Clearly identifying construction dates and dates of alterations becomes important when evaluating significance and integrity. Again, use the significance to craft what you say and how much you say about the resources, but don’t be afraid to address integrity honestly and make convincing arguments. Again, gaps in the holes in description arguments are grounds for a hold. We would rather have a truthful discussion and description of the property than something that kind of circumvents or gets around issues. They’ll only come to light later on. Include a map indicating the location of the resource within the historic district or maps that depict property boundaries and all of the resources within those boundaries. Again, remember the idea of interconnectedness. A boundary should be based on the significance and full extent of the historic property, not based on current ownership or proposed work. And the best maps will show dates of buildings and additions, contributing status, and the context surrounding that property as well. These are just some examples of different ways to convey that information in districts and resources. And again, we will look to make sure that all of those components mesh together in the Part 1.
Next, for projects where a property is already listed, either as an individually listed property with more than one building or as part of a listed historic district, a Part 1 is required. So if you have an individually listed house whose 1982 nomination does not mention the garage or other major outbuildings, a Part 1 will be required. Even if the outbuilding was constructed after the listing, it still triggers the need for a Part 1. All properties located in listed districts require a Part 1 to ascertain the status of the building. Older nominations for districts and individual properties might not have an inventory or only a partial inventory. They also may not have a specifically defined period of significance. In such cases, the Part 1 application will have to tell us as much about the property as it can.
Next, for contributing buildings in listed historic districts, the Part 1 documentation levels will largely be dependent on the quality of the original nomination. Where district nominations have well-developed inventories and historic context, the Part 1 they will take a cut-and-paste format updated to reflect current conditions. When the district nomination is older, there may be little to no information on a particular building, in that case requiring the Part 1 to provide a much more detailed description and justification statement. There may be need to outline specific criteria, areas, and periods of significance consistent with the original nomination as they apply to the subject property matching those connections. Make sure that the description is up to date, including outbuildings again. So, a lot of those nominations for historic districts and individual properties are quite old and they do not have up-to-date information. And so the Part 1's task is to update that information, particularly the physical condition of the property. But if the original documentation cites a different status for the building, the Part 1 will need to directly address the basis for reconsideration and require substantive discussions or additional context. Again, districts and buildings evolve and change over time. The Part 1 is your opportunity to update that with those components, including the contributing or non-contributing status of the property.
Next, significance. A Part 1 certification can provide page upon page of historic facts, personalities, or events associated with the building and yet never answer the question, why is this property important? The basis for meeting one or more of the National Register Required criteria requires an evaluation within the appropriate context. So, for a property not currently listed, the Part 1 application is seeking a preliminary determination of individual listing or a PDIL. The regulations for the tax credit program require "substantially the same information as a National Register nomination." Of course, each property will be different and the amount of information will differ and that is sometimes where there is a bit of consternation or confusion, because many feel that quote National Register level documentation needs to be exhaustive. The best practices for both nominations and Part 1 applications will keep to those three elements we discussed earlier: focus, context, connectivity. If you can answer those 3 evaluations, then you've got a solid strong Part 1. In order to establish the importance or significance of a property, it must be evaluated within an appropriate context. The basis of a context involves three things, the theme, the time, and the place. Evaluating any property within the proper context requires some level of comparison. If looking at the theme of industry, we need to know the importance of that theme in a particular place and how the particular property fits into that theme. It’s not enough to provide statistics and facts that pertain to the property, it requires analysis. Again, answer the question, why is this place important? The less that is known about the theme, the time, or the place, the more information and research is recorded in a Part 1. And this is again where focus comes into play. Evaluating a 1920s school or bank, for instance, does not require an exhaustive history of a community from day one settlement up to the present, but it may require understanding of the local community environment immediately before, during, and after the 1920s in order to place the property in context. Lack of direct context is perhaps the largest missing component of Part 1 applications. That discussion also involves comparing Part 1 resources with others that compare to the same context.
Next slide please. Part 1 applications also need to make sure that all the criteria noted for a particular property are directly addressed. It doesn't mean that every National Register criteria has to be applied or considered in every case, but if selected in the Part 1, all must be justified. You don’t get extra points from multiple criteria in a Part 1 evaluation. The eventual nomination, the National Register nomination, can expand on criteria and their significance. If you can't concentrate the discussion to one or two, to all, you can't answer all of the criteria questions. You might consider limiting or focusing on just one criterion and making that a solid case for eligibility. Consideration of the period's significance also needs to be carefully addressed as it may well impact Part 2 efforts. Next slide, please.
Wrapping things up a little bit, for properties in historic districts or previously listed resources, it’s important to describe the property as it exists now. No changes from the listing date. If known, tell us what might have changed between the time the property was listed and now. You are presenting in the Part 1 a current day description of that property. Evaluate within the stated areas and periods of significance. Review the nomination for its areas of significance. If the period of significance is not specified in the original nomination, then the nomination does not provide you many clues except maybe mentioning 19th century buildings. You can assume in most cases 50 years from the date of listing would be the end date for the period of significance. Evaluate as to whether the property in its current state contributes to the significance of the overall listed district. Again, taking the information from the original nomination, the updated information you have on your particular property, fitting it into that context, that area, and period of significance to make an evaluation of it. Do not assume that if it contributed in 1988 when listed, it still does today. We are again looking at the current conditions of the property in the current conditions. And the final one there, a site plan when necessary, clear map places a property within that larger historic district. And next, please.
So, to recap the main component elements, you must demonstrate that the property meets one or more of the National Register criteria for evaluation. This is not the same as providing a history for all the history of the property. All properties have histories, but it’s demonstrating that a property has significance, takes analysis, takes looking beyond the limits of the property itself. Answer the question why? Some properties lend themselves to easy assessment, but many do not. The newer the property is, the less likely there is to be an established context. The more common the property is, the greater need to provide an analytical, comparative context. If there are many, why is this one in particular important? There needs to be a direct and important association between the property and the historic theme. Do not discount or ignore an area of significance because it might affect treatment decisions and make sure that the period of significance accurately reflects and encompasses the time period of the historic theme. And finally, please, please organize the supporting documentation, photos, and maps in a logical way that relates to the narrative. Remember that interconnectivity so that all the pieces of the Part 1, as focused and concise as they are, mesh together to be able to answer those questions about why this property is eligible.
And with that, I will turn it over to my partner in crime, Roger Reed, and he will discuss more examples. Thank you.
(Roger Reed) Thank you, Paul. In this section, I will provide a bit more focus on specific issues that can present problems in the approval PDILs or Part 1s. As you can see from the bullet points, many issues relate to the preparation of National Register nominations. Completed nominations are not required for Part 1 approval, although the applicant may choose that option.
Next slide. Brevity in a Part 1 is often more acceptable with Criterion C, I’ve found, unless it is a common property type in a given locality. In this example, modern-style buildings associated with the automobile industry are not uncommon nationally but should be considered in terms of local significance.
The brief Part 1 in this case was successful because the applicant's claim of architectural significance was supported by SHPO comments that also supported the listing. SHPO reviews are taken very seriously because they know their state's historic resources. And again, a note on this case: it did not require a complete history of modern-style architecture. A brief summary of that style is sufficient, and the focus should be on the building.
Criterion A arguments often require more substantial documentation. As you can see in this slide, historical significance claimed might begin as early as 1830 and extend well into the 20th century.
However, as a common property type, in this case, SHPO supported a narrower focus on the building's use as a grain chawl and its importance to the community. Note that this does not mean leaving out documentation on the early history of the property, but the focus can be on the justification for listing that is presented in the Part 1.
Both of the previous examples required historical context. For some property types, such as public housing, documenting a property context may be more demanding. And this is something that Paul touched on in his talk.
How much is the quite usual question in preparing a Part 1. It depends on the locality. Oftentimes, this Kansas example is in a small town, which makes the context documentation easier both for architecture, social history, politics, and government.
As you might guess, large cities such as New York present more of a problem.
Here's a good time to mention that good visual documentation will help a partner reviewer and the applicant obtain approval. But as the slide indicates, even though the property has been very well documented, context was necessary to support listing because there are so many housing complexes in New York City or in many large American cities.
So, in this example, it was not sufficient that the property retained good integrity, especially since public housing is typically designed without flashy exterior architecture, and interior changes are very common.
Integrity is much discussed for all property types, and we recommend that you refer to this bulletin available on the National Register website.
As this example illustrates, levels of integrity can depend upon the resource. The original architectural drawings shown on the left illustrate why alterations to this building, with the cover removed, did not offer a strong justification for architectural significance due to loss of integrity. However, Criterion A, as the major hotel in this small town, did offer a successful path to listing.
Next slide. The question of how much can also apply to additions. Hospitals can be very problematic because, as a property type, they almost inevitably have multiple additions.
Next slide. Here again, good visual documentation is essential. Note the historic view just shown survives in this complex facing the major highway, and it's outlined in blue.
Other additions to this large complex have been well documented, and this is really very beneficial to the Part 1 reviewer and, therefore, will help in getting a Part 1 approval signed. Next slide.
Although no longer the entry—sorry, in the rear of the complex are additions that later became the main entrances. Again, good site maps are essential to sort out these changes where you can't even tell what is the front of the hospital and what is the historic front of the hospital, and how much integrity the complex retains. Next slide.
Although no longer the entrance, the original building survived. Documenting contributing and non-contributing portions of the hospital is required in the Part 1. Next slide.
Up to now, we have been talking about individual properties not yet listed. A Part 1 is also required for every building listed in a district, and as the slide notes, because the nomination may indicate the property is contributing, this needs to be confirmed in the Part 1. It cannot be assumed, with or without alterations, that the contributing status is appropriate. Next slide.
In some cases, to confirm that a building in a district contributes, it is usually only necessary to provide a brief description and statement of significance. And although you can't read the page on the right, what isn't—we are attempting to convey here is that all the information necessary for the Part 1 for a building which was clearly contributing to a district can fit on one page of the Part 1 form. Next slide.
As Paul mentioned, in some cases, particularly older nominations, outbuildings may not even be mentioned but must be documented in the Part 1. And this, of course, applies not only to districts where a building has more than one outbuilding, but also individual building listings as well, which aren't normally required for a Part 1. But they are when there’s more than one building on the property and where that outbuilding or support building is not documented. That will require additional documentation. Well, oftentimes much beyond the nomination itself. Next slide.
Covered buildings and districts that are not contributing are a common problem. Excuse me, common aspect of Part 1 reviews. Oftentimes, they’re not a problem. As this slide shows, removing the cover can produce a happy result without a great deal of worry about contributing status. Next slide.
The general guideline, as noted here, is enough of the historic cover has to be removed so that the building would contribute if all work stopped. In this case, although you can see a portion of the one facade, a corner, we required that the entire facade on one side of the building, one of the two principal elevations, be uncovered in order to determine that the building would be eligible as a certified historic structure. Next slide.
This slide, in other cases, the damage caused by installation of covers can be less successful.
It is important to consult the nomination when you are proceeding with removing a cover or investigating whether a cover can be removed in order to lessen the chances of surprises and what you're going to reveal. Next slide.
This slide shows the damage and worst-case removal. In this case, the importance of the brick facade in the continuity of the city plan was a deciding factor to overcome a very clear loss of integrity. In other words, approval in this unusual case hinged on the area of significance, which was community planning and development.
Next slide. As in the previous examples, the SHPO input is important. The block of buildings shown here is the entire commercial district of this small town, and there was no historically opposing row of buildings. Next slide. Documentation is also critical.
In this case, both covered buildings were in fact halves of otherwise intact facades, so that we were able to approve the Part 1, even though in both cases half the facade was covered. Next slide.
Finally, there can be a problem with old nominations where a complete inventory or period of significance is lacking. Sometimes, a justification for a building contributing is in the general statement of significance in the old nomination. Ultimately, however, revising the nomination may be the only option if the documentation available is not sufficient for Part 1 approval.
(Brian Goeken) Thank you for listening to the second of this five-webinar training series on the HPCA application. We hope you found this information helpful. The other webinars that are part of this training series, as well as the HPCA application form, the application instructions, contact information, and how to subscribe for news and updates from our office are all available on the main page of our website.
Description
This webinar focuses on the Historic Preservation Certification Application Part 1 – Evaluation of Significance and documentation requirements.
Duration
31 minutes, 33 seconds
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