Video
Frequent Program-User Training: Historic Preservation Certification Applications Day 1
Transcript
(Brian Goeken) Hello, my name is Brian Goeken and I'm the Chief of the National Park Services, Technical Preservation Services Office, also known as TPS. Our office administers the Federal Historic Preservation Tax Incentives Program in partnership with the State Historic Preservation Offices, as well as produces guidance and technical preservation information on the rehabilitation of historic buildings. The Tax Incentives Program, commonly referred to as the Historic Tax Credits, provides a 20% federal income tax credit for the rehabilitation of historic buildings, and is responsible for 6-8 billion in private investment in historic rehabilitation in communities small and large across the nation, as well as the creation of 120,000 to 130,000 jobs annually.
Thank you for joining us today for the first of a five-part series of webinars on the Tax Incentives Program intended for building owners, developers, consultants, design professionals, and other frequent program users. This advanced training is on the Historic Preservation Certification Application, or HPCA, the three-part application that owners of historic buildings use to request certification by the National Park Service that their building is historic and that their completed rehabilitation preserves the building's historic character, required so that the rehabilitation is eligible for the historic tax credits. This training is focused on the application requirements and how the NPS and the SHPO's review applications to help streamline the review process and reduce review times for applicants, avoiding incomplete submissions, delays in review and their associated costs. We originally piloted this material in this webinar at an in-person, all-day training held here in Washington, D.C., attended by 285 people. We were encouraged by the response, and we repeated the training virtually. In now offering this training in an on-demand recorded format, we hope to make this information even more broadly available.
Each webinar in this five-part series focuses on a different aspect of the HPCA application, preparation, submission, and review process, and the webinar's varying length from about 30 minutes to a little over an hour. This first webinar reviews best practices to ensure a complete application and a smooth application and review process. The second webinar discusses Part 1 applications and documentation requirements. The third webinar covers the Part 2 application and specifically how to structure it and how to describe proposed treatments. The fourth webinar provides a comprehensive overview of the documentation requirements through the Part 2 application, including for special circumstances such as additions, new construction, and demolition. And the fifth and final webinar discusses amendments, phasing requirements, phased advisory determinations, and the Part 3 application. We will generally not be discussing the standards for rehabilitation on the training except in a few instances as it pertains to the HPCA application requirements, but we are developing a separate companion advanced training focused on the standards which we expect to present soon.
I also want to remind you that this is an advanced training for those already familiar with the HPCA, the application process, and the historic tax credit program requirements. We will not be spending any time today explaining the overall three-part application submission process or HTC program basics. We assume everyone watching this webinar series already comes to it with that basic knowledge. Introductory information about the program, program requirements, and the application process is available in our website. The regulations and HPCA application instructions take precedence in the application requirements and should always be consulted first. Likewise, the TPS website should always be consulted to make sure you are using the most current version of the application form, the application instructions, and other published guidance and information. This training is intended to provide insight into the review process and how best to develop an application that provides the needed information that can help expedite review of a project as well as to avoid holds or avoidable conditions of approval that are not necessary. We are hopeful that this training will help bring down review times, reduce the time and cost of preparing an application, and continue to improve the administration, effectiveness, and utilization of this important program.
So, thank you for taking the time to view this training and with that let's start. I'm going to do a brief introduction concerning the overall application process generally and then Amanda Apple and Quanisha Quick will cover electronic application submission, photo documentation, preliminary reviews, and completing application cover sheets and avoiding administrative holds due to missing or unclear information.
Today's training is primarily focused on application requirements, what constitutes a complete application, and how the NPS and the SHPO's review projects, so that you will have a better understanding of what we look for in reviewing an application, with the ultimate goal of streamlining the review process, reducing review times, and avoiding unnecessary holds and conditions of approval in the review of projects. Let's begin with these three overarching topics to get us started.
In preparing the application, organizing the project narrative and identifying the necessary supporting materials, remember that the reviewer is not going to be as familiar with the building or the project as you are. When they open the application, they're likely seeing the building for the first time and know nothing about the project. Even if, for example, the SHPO or the NPS reviewer was on a site visit of the property, their experience of the building and knowledge of the proposed project would still be limited. The project narrative and supporting materials of the application should be developed in a logical and organized way to make it as easy as possible for the reviewer to quickly understand the building and the work that is proposed and to evaluate its conformance with the standards. Imagine a person with no prior knowledge of the project reading the application for the first time. Is the description of the building and the photographs adequate to understand the building's historic character, such as the hierarchy of interior spaces, circulation, and extant historic features and materials? Have you anticipated any questions that would need to be answered to evaluate the proposed work for conformance with the standards? Remember, the reviewer is only interested in product information to the extent is relevant to whether or not the proposed work meets the standards. It's important to also note that the reviewer can only base their evaluation on the application itself. The alternatives that may have been considered before selecting the proposed treatment, the information that the reviewer may infer or glean, or that may have been shared with them on a site visit, does not count unless it's made its way into the application. Under the program regulations, the NPS decision is based slowly on the written application and supporting materials. The clearer and more thorough the submitted information is, and the more well organized the narrative and submittal materials are, the speedier and more efficient the review. The training that follows today will help provide additional guidance and information on best practices for more complete applications and more streamlined reviews.
What are some of the common project pitfalls and how can they be avoided? Well, the most common pitfall is work undertaken without prior NPS review and approval. We strongly encourage that work not be undertaken without such approval, whether before submitting the Part 2 application, or in the course of the project. Once work has been completed, it makes it more difficult, time consuming, and costly to address it, if remediation will be necessary for the project to meet the standards. It's therefore important to allow enough time in the project planning process to obtain SHPO and NPS approvals. Preliminary consultations with the SHPO and/or NPS can also be valuable in avoiding treatments that may be problematic and not meet the standards and doing so in a timely manner. The work to be undertaken should be fully described, whether in the Part 2 application, subsequent amendments for future work, or work for which such details are not yet known, and for unexpected changes and conditions and the course of the project. Again, the National Park Service and the SHPO can only review and comment on the work described in the application. If important details relative to the standards for rehabilitation are not included in the application or never submitted for review, the reviewer generally has no way of knowing or anticipating this. Work should generally meet the standards when at all possible, but every rehabilitation project likely will include some work that may be problematic and is why projects are reviewed for conformance with the standards on a cumulative effect basis. The standards recognize that some changes will undoubtedly be necessary to accommodate a new or continued use as part of a rehabilitation project and they establish a hierarchy. More important and distinctive feature spaces and materials should be preserved with more flexibility possible if needed in other portions of the building. When proposed work negatively impacts more important to distinctive features, spaces, and materials, for example, for code or programmatic reasons, the narrative should include justification, analysis, or other information addressing what alternatives were considered and why the proposed treatment was selected. Finally, make use of preliminary consultations with the SHPO and/or the Park Service when needed, particularly when such preliminary guidance can provide timely direction on an aspect of the project before possibly wasting time and money on going down a wrong path.
It takes a qualified team to achieve a successful historic tax credit project. The role of each team member in a historic rehabilitation project is important and should be made clear from the beginning of every project, as well as who is responsible for coordination and ensuring that the project meets the standards and conforms with the project approvals once issued.
A project team for a large and complex project can include many team members. The owner, sometimes an owner's representative, consultants, architects, project managers, contractors and subcontractors, engineers from different disciplines, craftspeople, and more. But whether a large or small project, someone should be designated the lead or leads in being responsible for preparing the HPCA application and coordinating with the other team members, ensuring that the application accurately describes the project as proposed and intended and that the work meets the standards. And that once approved, the project continues to conform with the approved scope of work where amendments are sought should the proposed scope of work change. A member of the project team needs to be responsible for these overlapping areas, ensuring that the work as it is developed meets the standards. This is the place where a project can sometimes go wrong with decisions made, whether in the architect's office, by the developer, by the contractor, or in the field, without coordinating with the rest of the project team.
In preparing the Part 2 application, this coordination is critical, including communicating the program requirements, identifying the treatments that may be problematic, seeking guidance from the SHPO or the NPS as necessary, clarifying and helping problem solve when work needs to be changed to meet the standards, and ensuring that the project narrative and the drawings are coordinated. Once approved, the scope of what has been approved, as well as what has not been approved, for example, future work to be submitted later for approval, should be communicated to the entire project team and a member or members of the team should ensure that any conditions of approval are addressed, monitor the project for consistency with the approvals, and flag any issues that might arise, seek guidance from the SHPO or the NPS as necessary, and submit amendments for any proposed changes that occur in the course of the project. Whether the responsible team member is the historic consultant, the design professional, or the owner themselves, this communication and coordination among project team members throughout the life of the project, particularly for larger and more complex projects, can be important to its success. For larger and more complex projects, some best practices include ensuring that there are clearly defined roles and responsibilities of the project team as it pertains to the HPCA approvals, an established communication system among team members, kick-off meetings or other ways to communicate the requirements of the tax incentive program, and whom to contact when questions or changes arise, regular coordination meetings on site, if possible, site visits and regular monitoring during project construction, and finally coordination on change orders, shop drawings, product specifications when they impact important aspects of the historic rehabilitation project.
(Amanda Apple) Hello all, my name's Amanda. For my part of today's presentation, I'll be covering three topics that cut across all parts of the application, electronic submission, photo documentation, and preliminary reviews. My first topic, which we hope you've all heard about before now, is that the Park Service moved into the 21st Century with the launch of electronic submissions on August 15, 2023. We want to assure you our review process has not changed just the delivery method in which we send and receive information, which we hope will translate into smoother transfers of documentation, reduced times for processing, and faster reviews. If you've not looked into the electronic process yet, please note that each state has developed a process for accepting the electronic submissions in their office based on their state requirements. Links to their individual sites are on our webpage pictured on the screen. Also, on our webpage you'll find all the information you need to successfully develop and transmit an application. We've included a thorough set of standard operating procedures, as well as documents on naming conventions, photo requirements, file standards, etc. We couldn't have done this alone and we want to thank everyone who helped us test this process. Prior to the launch, in August, NPS staff held multiple virtual trainings with both the public and SHPO staff. If you have any questions regarding the electronic application, they can be directed to the email address on the screen nps_tps@nps.gov. The combined experience on this call today is immense and some of my next topic may seem a little basic, but even a seasoned professional may fall into one of these traps. This presentation is going to highlight a few items related to photos where we've had some hiccups in the past and have needed to put projects on hold for additional documentation. The main takeaway for this part of the presentation is we want your review to go smoothly and your photos should act as a virtual tour of the project. We're sure everyone here has heard the adage a picture is worth a thousand words and understands how this applies to your project. Photo order is not a requirement but it helps your SHPO and NPS reviewers if your photos follow a standard progression and start with the front primary exterior elevation of your main building and work your way around the building. Then, inside, start at the basement or lower floor, then move your way up the building. If there is more than one building, start again on the outside of the second building, and repeat basement to attic for each subsequent building.
Next, we're going to discuss the Goldilocks effect. As every building is different, there is no "right" number of photographs. Too few photographs is the problem, such as only providing images of the area where work is proposed and not the entire property, as seen in the left image. The problem of too few images can also happen by just providing one photograph of each room, which may be fine for a Part 1 to determine if the property is historic but might not be enough information to evaluate the entire scope of work in the Part 2, especially if major historic details such as fireplaces or historic stairs are not documented and work is proposed on them. On the flip side, too many photos overwhelms us as seen in the image on the right. Not only is it a lot of work for you to prep all the images it causes your reviewers to spend more time trying to figure out why there are so many and what exactly you are trying to convey that we aren't seeing. Also, an important takeaway here is no matter the number of photographs they do all need to be numbered, described, dated, and keyed to a plan. A circumstance where the number of photos could be reduced is when a building has multiple stories with a repetitive floor plan and the same materials and finishes throughout. In this case, you may submit representative photographs that show those conditions without producing a large quantity of photographs that all look similar. Some building examples where this may be applicable could be a hotel, school, or office building, such as the example on the screen, which is a 16-story commercial building with a similar finish schedule and floor plate on the upper stories. When you have a building with a repetitive floor plate but with different tenant buildouts or unique plans and finishes, those unique features must be photographed. And we do recommend providing a representative sampling of photos of each floor treatment and highlight the repetitive nature in the narrative description. Another example where fewer photographs may be appropriate is when a large open uninterrupted space can be captured easily as in this well-lit mill with an open floor plan. These couple of photos convey the character of the space, including the unique detail such as a pile of ponies in the corner.
Apart from the process and organization of photos, the nature of the photo itself is also critical. Abandoned buildings are a tough environment to work in and photograph and we realize this. So it can be a challenge when a site doesn't cooperate and things are out of your control. If there are safety concerns on-site such as a space is not accessible or is dangerous, please note this condition in the narrative. Don't endanger yourself. When explaining this condition, please provide a plan for when you might be able to get us the needed photographs. For example, gaining access to a flooded basement is prohibitive. In your application, explain why the basement photos are missing and that when the basement is cleared of water, you will provide an amendment with the additional photographs prior to the start of work.
Another tough situation for photos can be lighting. Reviewers should not require night vision goggles to understand photographs. Photos really need to have adequate light to show the features of the room, walls, floors, ceilings, details. In these images on the left you can see the windows are actually boarded up in this building but the photographer came prepared with a secondary source of light and these are adequate to understand the character of the space. The photo on the right shows windows backlit and a dark room, making it near impossible to see any of the room details, trim, floor, ceilings, walls. If you find yourself in this situation, you could use a longer exposure when taking the picture. Or you could lighten the photo with photo editing software. While one poor photo won't hold up your project, several poor photos may. With reduced light, another item to be careful about is blurry photographs, which can distort details and if the purpose of the photo is to see the details, well, you see the problem. When providing a close-up detailed photograph of special elements or important character defining features, it is critical to also provide a photo showing the feature in context of the building or room. The example of the pressed metal ceiling tile in the center of this slide shows us the pattern on the ceiling, but without the contextual photo on the left we wouldn't know a large section of this feature is actually missing. The photo on the right on the other hand is a beautifully restored marble staircase without an accompanying photograph showing it in context of the building or space. This is valuable information if we were say evaluating fire separation for a building. So context photos do matter. Now, the detailed photos we don't really need are broken bathroom fixtures or even unbroken bathroom fixtures.
Part 2 photos need to show exactly what the current condition is before any work begins. On this slide, the left photo shows a deteriorated condition and the accompanying application narrative was not clear about what is going on here. Did the applicant purchase the property in this condition? Did the applicant already begin demolition work? Part 2 photos should be indicative of a building before any work starts. So, photos showing work in progress will give us enough pause to question whether the project is well underway without NPS review. If the questionable photo is not explained in the narrative, the project would probably be put on hold and if the photo is conveyed to show a mid-project condition, the review would be placed on hold and a request for pre-construction photos will be made. In the opposite situation, Part 2 photos appearing to show completed work, such as the photo on the right, should be explained in the narrative and may require additional follow-up from the park service. Our next two situations deal with obstructed views. Photographs obstructed by scaffolding, vegetation, other buildings, cars are not useful or informative. If you can't see the building, I promise we can't. These three photos show the same building. The far left is Google Street View, where the front is not visible at all. The next photo is the Part 2 photo. Luckily we can see most of the front elevation, at least enough to identify character defining features. And then the far-right photo was taken at the Part 3. You don't have to wait until winter to take your photos but please try and get the best photo you can that captures as much of the building as possible which might mean ducking around a parked car or a very large street tree. Getting a clear photo can also be a challenge for interior shots, especially if there are drop ceilings, large furniture, curtains, or hoarder situations. Do the best you can with the initial photos, as in other situations, if something is abnormal, reference it in the narrative and let us know when you expect to be able to send pictures with an amendment. The photos on the screen highlight a wooden coffered ceiling hiding above a drop ceiling. By simply moving a ceiling tile or two we can plainly see that there is a historic ceiling in place. Another tip to speed your project review along while not a requirement is to synchronize your photos. Take the same photos in the same location and direction in both Part 2s and 3s. You can reuse your photo key and it'll make a reviewer's day. Our final note of photographs while we hope the transition to electronic PDFs makes the documentation process a little easier for you. We do know some of you have been doing this type of submittal for a while. We want to stress that the size of photographs still matter. If it is worth taking and sharing the photo, it is worth saving it as a four by six, which is a maximum of two pictures per page. If you need a refresher on the naming conventions, JPEG requirements, or an example of a PDF photo sheet, please review the instructions for electronic submissions. In closing, photos are a critical element of our review and evaluation of the historic character of any space, and poor quality or missing photos can cause your project to be put on hold and delay its progress. You need to help us understand your building's story.
Pivoting away from documentation and our application requirements for a sec to a topic for which we are currently updating our guidance. Have you ever asked yourself what the Park Service would say about, well, you fill in the blank, when developing a project? As we are talking about ways to develop successful applications, we want to make sure you all know you have the option of working with your SHPO to request a preliminary review, these reviews are brought to the National Park Service through your SHPO office. This process is how you can get advice from us in the early stages of project planning and development for specific make or break issues.
A preliminary review on a Part 2 is not a complete soup to nuts review of the entire project. It should focus on one or two specific issues that are critical to the project successfully meeting the standards. These reviews are advisory only because we are looking at a discrete part of a project and not the facts and circumstances of the entire project. A few topics that rise to the level of a preliminary review request, as shown on the slide, could be subdivision of public assembly spaces, demolition, and major new construction or additions including rooftop additions. Other topics might also include major changes to primary elevations, major changes to internal circulation patterns, floor cuts, or implementation of seismic upgrades. These preliminary reviews are presented and discussed at internal NPS staff meetings to facilitate a broad understanding of issues and maintain consistency in our application of the standards. A preliminary review might also involve specific rehabilitation treatment that is unusual and may not meet the standards on its own or could be seen as a drastic measure and could cause an overall project not to meet the standards. An example of this might be to reskin a building because of damaged or deteriorated historic materials. Any request for preliminary consultation must be accompanied by supporting information that is sufficient to illustrate the issue. This documentation could include a written narrative or explanation of the issue, photographs showing existing conditions, a mock-up for a rooftop addition, site plans with a massing study for new construction, images, drawings, or renderings that convey a proposed treatment or treatment options or material samples, and references for any pertinent code or regulations related to the issue or treatment. The Park Service usually conveys a verbal response to a preliminary consultation directly to the SHPO, and the SHPO conveys the response to the applicant. In limited cases at the discretion of the Park Service, a response to the SHPO may be in writing or jointly conveyed to the applicant.
The NPS response to a preliminary review is advice and guidance only and is not a certification decision that may be appealed. Another instance when preliminaries are strongly recommended before the Part 1 involves breaking up large and diverse functionally related complexes into separate projects. On this slide is the former Buffalo State Asylum for the Insane, which has many functionally related buildings with multiple historic uses. How this application could be separated into smaller groupings is an excellent topic for a preliminary review. While we are on the topic of multiple buildings, a couple footnotes we want to clarify. The Park Service makes a determination at the Part 1 about whether a project with multiple buildings on a historic site will be treated as a single project or separated into multiple projects is made on an individual basis based on specific facts and circumstances of the rehabilitation. We take into consideration are the buildings functionally related historically, which means were they joined or interconnected during the period of significance? Are they on the same property? Were they designed as a complex, were they owned, built, operated, and managed by one organization? We look at the timing and phasing of the project and ownership. And a reminder about these types of projects regarding the issue of ownership specifically. Even if functionally related historically, buildings owned by an unrelated independent 3rd-party, i.e., an arms-length transaction, are generally treated as separate projects. Buildings owned by different legal entities, however, may still be considered part of one overall rehabilitation project if there is overlapping, common, or related beneficial ownership management or control between the entities. After this potpourri of topics, I'm going to turn the mic over to Quanisha who's going to be discussing the secrets of avoiding administrative holds and after her presentation we'll be taking questions together.
(Quanisha Quick) Hello, my name is Quanisha Quick and I am the supervisor of the TPS admin team. I'm going to talk briefly about administrative holds and why applications get put on hold due to missing and unclear information. This is different from holes placed by reviewers for lack of information or work that doesn't meet the standards. I'm going to focus on common mistakes in filling out the HPCA application. Some of the most common mistakes made in filling out the application, and please note that the wording and order of my slides are a little different than what's in your packet. Please use the most recent version of the application forms. The current forms have revised June of 2023 on the top left, and you should always download a new form from our website when starting a new application. With the hard copy applications, you will be surprised how many applications lack signatures. With the introduction of electronic applications and e-signatures, this may not be much of a problem. Please do not leave any blank spaces. List N/A when a field doesn't apply. This is true for all applications. If the line is blank, admin staff doesn't know if the field is intentionally blank or just missed. Believe it or not, we sometimes get forms with $0 for the QREs. Total estimated project costs should be QREs plus non-QREs. We often get non-QRE costs entered into the total project cost field. Dates should be provided in the format month, day, and year. It needs to be an actual date. Seasons like spring or fall will not be accepted. When multiple individuals are the applicant, always provide signatures and social security numbers for each individual person. If the applicant is not the fee simple owner, the program regulations require that the application must be accompanied by a written statement from the fee simple owner, indicating that he or she is aware of the application and has no objections to the request for certification, and the box shown in green should be checked. The two prior slides are some of the most common reasons why applications are placed on administrative hold. As Amanda discussed, when requesting a preliminary determination of eligibility, please select one of the three bottom boxes shown here in red. If the preliminary determination is for a district, then you also need to check this box shown in yellow. In submitting amendments, please follow NPS amendment numbers. You can always verify the amendment numbers on the TPS Check Project Status website.
When responding to an NPS hold for additional information, while you do use the amendment form to submit this information, the NPS system does not treat this as an amendment and will not assign an amendment number. Responses to holds will not appear as amendments on the TPS Project Status website, but will show up on the website as information received for the application put on hold and not separately logged in. Responses to NPS hold should only address the reason for the hold and not include new issues that should otherwise be submitted as separate amendments. If you select boxes for both additional information in response to a hold and for new information that amends your application, you will need to submit the amendment to the SHPO. Alternatively, the information in response to the hold should be submitted directly to NPS and the new information that amends your application should be submitted to the SHPO as an amendment through the normal process.
(Brian Goken) Thank you for listening to the first of this five webinar training series on the HPCA application. I hope you found the information helpful. The other webinars that are part of this training series, as well as the HPCA form, application instructions, contact information for our office, and how to subscribe for news and updates are available on the main page of our website.
Description
The topics of this video are: Introduction to the Training, Best Practices for a Successful Application, Electronic Submission of Historic Preservation Certification Applications, and Secrets to Avoiding Administrative Holds
Duration
37 minutes, 47 seconds
Date Created
05/09/2025
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