Video
Advanced Training on Historic Preservation Certification Applications – Webinar #3
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 third of this five webinar training series on the Historic Preservation Certification Application and application submission requirements. In this webinar, we are focusing on Part 2 applications and specifically how to structure them and how to describe proposed treatments. Presenting today are Angela Shearer and David Trayte from the TPS office.
(Angela Shearer) I'm Angela Shearer, Supervisory Historian. We are going to focus next on the Part 2 application, the description of rehabilitation work. The Part 2 narrative, along with the photographs, drawings, and other supporting materials is likely one of the largest parts of work for you to put together and for us as reviewers to evaluate. I'm going to present a big picture overview of how to structure the Part 2 narrative, followed by my colleague David Trayte, Acting Supervisory Architect, who will narrow the spotlight with a few case studies. The case studies will examine narrative examples of masonry, flooring, and HVAC. Overall, this presentation is going to focus on the written narrative, the words, if you will. The Part 2 discussion will be continued with a future webinar regarding documentation requirements that must accompany a Part 2 application, including drawings, window documentation, documentation for additions and new construction, as well as documentation requirements needed for evaluation of demolition of historic resources.
Taken together, we hope to provide the best practices of what to include in a complete Part 2 application. This is not a training on the interpretation of the standards, but we hope to provide the framework of what we as reviewers need to evaluate a proposal to ensure a timely review, which is important to everyone. The Part 2 is our contract in which all work is described and agreed upon or conditionally agreed upon by the NPS and the applicant. Decisions are conveyed in writing. We can talk about the project and sometimes we reviewers are able to make a site visit to see a property in person, but to officially make a determination we must go by the written record.
As you are very familiar with, the purpose of the Part 2 is to describe both the existing conditions of the building and proposed work. It should include the where, what, how much, and why of the project. The proposed work must take into account the preservation and retention of the existing historic fabric as well as preservation of the building's historic character. If the written application does not include enough information to make a determination, then the application may be put on hold for clarification or resubmission. At the completion of the Part 2 review, the NPS issues a decision that approves the project outright or approves with conditions.
Proposed work is evaluated using the Secretary of Interior Standards for Rehabilitation. Conformance with the standards is determined based on the application documentation and other available information. By evaluating the property as it existed prior to the start of rehabilitation work under the applicant’s ownership, the standards are applied in a reasonable manner, taking into consideration economic and technical feasibility. Certification of rehabilitation is based on whether the overall project, that is, the cumulative effect, meets the standards. How many hours have you spent filling out this form, and how many hours have we as reviewers spent reading your every word?
Please be aware that it is acceptable to submit the narrative portion of the Part 2 with your own template, provided it contains the same information in a format that is similar to this form. While there are different ways to write a narrative, organizational concepts should be utilized as such. Begin with site work and describe features from the exterior to the interior and from the general to the particular. Provide a general overview of the project in existing conditions. Organize this description of work by historic features or space.
Organize work item descriptions to best suit the building and the size of project. Keep in mind clear and precise descriptions don't need to be long. You can utilize bullet points when appropriate. How will organize the information is just as important as the information itself. Organize the work description in a manner that is best suited for the building.
It is often helpful, but it is not required, to provide an overview of the project, scope of work, and current building conditions. The summary should give us the highlights of the project as well as point out any unusual conditions or program requirements related to the proposed changes or site conditions that must be addressed such as flooding, seismic, retrofit, etcetera. Stating the unique challenges of the project helps the reviewer understand the overall project and why certain treatments are proposed. In this example, the project summary explains that this 1897 residence was converted to a fraternity house early within the period of significance. The summary also noted removing non historic vinyl siding to expose wood exterior cladding, replacement of vinyl windows with compatible wood windows, and the proposed installation of geothermic wells as part of the project.
Each feature should be numbered consecutively and named such as site work or windows along with the date of the feature. There may be more than one day if there are noted changes to the feature. Including the date or dates of each feature helps the reviewer quickly understand the evolution of the building and when specific features were added or modified. We suggest beginning with a general overview of the project or description of the project site. It is helpful to organize the features described in the narrative, from the exterior to the interior and lower floors to upper floors.
Depending on your building, site work may be followed by exterior cladding, porches, or other exterior features such as windows, doors, roof, and so on. All features of the building must be described, even if no work is planned for that feature. There are many ways to write a project narrative. In this example, descriptions of the exterior features of the building are grouped by elevation. While this approach may be appropriate for a small house or commercial building, it can involve a fair amount of unnecessary repetition when the elevations have the same features in a common treatment proposal.
Describing overall features such as windows, exterior cladding, etcetera, rather than each facade can make the application more efficient to write and clearer to the reviewer. We do want to make clear that there is flexibility in your approach and if the application is submitted following this example and includes all the information needed to evaluate the treatments, then your application will be processed. Just remember to use the organization of the narrative to guide the reviewer through the project in a way that makes the most sense given the project and the building. We all get to see a wide range of building types, from single family dwellings to large industrial warehouses and office complexes, historic churches, jails, hotels, barns, school buildings, and the list goes on. As previously stated, the organization of the narrative and the features described therein are influenced in part by the building type.
Different narrative approaches can be taken to address the diversity of features, finishes, forms, and existing conditions. For example, the Part 2 narrative for a historic hotel may require extensive discussion on the treatment of historic corridors, whereas a narrative for a historic church may focus on the primary assembly space. Each building type will generally have character defining features that are unique and should be addressed differently depending on the building. Likewise, building types will have certain features in common. For example, the Lear and Jacobson houses are 2700 miles and two centuries apart.
Yet despite their vastly different styles, materials, setting and plan, they share the same distinguishing characteristics of features such as the site cladding, windows, roof, doors, floor plan, walls, and ceilings, to name few. Some features are shared by all buildings regardless of age, for example, size, shape, scale, and massing. Other character defining features often include windows, wall surfaces, cornice and or roof details, entrances, and doors. On the exterior identify those features that distinguish the building, including its site and environment. Both of these examples are schools, but their character defining features and forms are addressed differently.
On the interior features such as stairs, corridors, plan circulation, space, trim, or in some cases, the lack of trim, doors, walls, ceilings, and floor surfaces. Every review of a project, no matter what age, style, or type of building, will establish a hierarchy of space. The purpose for which the building was constructed generally dictates the primary spaces that should be emphasized in the narrative. What are the primary and secondary spaces? How do you move through the building, and what is the circulation plan?
One of the basic principles of the program and the standards is that of historic character. A certified rehabilitation is one in which the rehabilitation of a certified historic structure is consistent with the historic character of the property. For example, the historic identity of most schools is that of a finished building with plaster ceilings and walls that must be retained and preserved. Unlike typical industrial buildings or mills that often have their structural components exposed, the expectation in any rehabilitation is to retain character defining features in order to preserve the building's historic character, as illustrated in these examples. Listed on the screen are examples of common features typical of any property and should be described in the application.
It is not an exhaustive list. Moreover, and obviously for this audience, the unique features of a building must often be included. For example, storefront in a commercial building, just as you have photographed the entire building, you must describe all features, whether or not work is proposed, including materials and spaces. And don't forget to include items such as built-in furniture, finishes and previous alterations, and indicate if they are historic. The narrative should include the specific materials as well as the location.
For example, when writing a narrative for windows, describe the material wood, steel, aluminum as well as the operation. Is a double hung, pivot, casement? The configuration is it 1 over 1, 6 over 6, and condition relative to each existing window type? This section of the application should also note whether the windows are original, historic, that is, within the period of significance or not historic replacements. Accompanying documentation will still need to be to supplement the narrative to illustrate the condition of the windows to determine the level of the treatment proposed.
The type of documentation specific to Windows will be discussed in a later webinar. When describing features in the narrative, the concept of acquired significance should be taken into account when addressing changes to a building after its original construction. Two common phrases we often see used interchangeably are the terms non original and non-historic, but as you are aware, these terms are not equal. A non-original feature implies a change after the initial construction, but it does not mean that the feature is not non historic as it could be a change within the period of significance that is important. This is just a reminder of why word choice is so crucial when addressing the subject in the narrative.
When addressing treatment proposals involving later changes to a building, the Part 2 narrative should clearly identify features and contexts of the building and historic district significance. To address if the changes are significant, refer to the national register nomination and the established period of significance. Present existing conditions in context of the building's history and evolution. Provide any historic documentation that tells the story of the building's change specific to its features and finishes. Use the information to create a framework for proposed treatments.
In the case of this 1924 office building, a 1965 modernization effort substantially altered exterior and interior of the building as part of a larger urban renewal effort. The concept of acquired significance doesn't only occur at a building wide scale. It can also present questions specific to select architectural features such as windows or storefronts or interior plan changes. The narrative should address how these changes are significant and how that informs your proposed treatment. Not all later changes to a building are significant.
In this example, in 1921, school received some modern updates during the stated period of significance, including dropped ACT ceilings below plaster, and the vinyl tile over wood floors. A description of the finishes in the context of the building significance should be provided in order to make a determination. In situations where a building has experienced substantial alteration over time, there can be the desire to return the building to a former appearance based on historic documentation available. Wanting to return a property to its original appearance is not adequate justification in and of itself without a case being made that the later changes have not acquired significance. This early 20th century department store had gone through several major facade alterations since construction, eventually resulting in the current configuration shown in the middle.
The proposal was to return the facade to its original configuration seen in the 1920s photo. Information was required to clearly establish a timeline of facade alterations, including historic photographs and drawings, documentation of interior alterations, and an understanding of when all extant building materials dated in order to make the case. Let's shift gears now from period of significance to discussing deterioration. It is the very nature of this program that we are dealing with buildings in varying degrees of deterioration. When addressing deteriorated conditions, applications should generally include the cause, the extent of deterioration, or if there are unknown conditions.
The narrative should answer questions such as what is the source of the moisture that contributed to the deterioration? Is it the result of a roof leak, masonry issues, faulty plumbing, and/or the building being open or closed to the elements? How much damage to historic materials exists? How will the treatment proposed mitigate the issues that cause the damage and preserve the space? The narrative should be used to describe the conditions that are shown in the photographs.
When describing finishes, it should be noted whether they are historic or modern, even though it may be obvious in some cases. For example, is an element painted or stained? It is also important to do at least a cursory examination to determine whether historic finishes are present behind or under modern finishes. As we have all seen, lifting a modern acoustical ceiling tile or lifting a loose corner carpet can reveal A historic pressed metal ceiling or hardwood floor. It is important to be specific about the proposed treatment.
This is a very simple example noting the difference of word choice. Deteriorated historic wood trim will be replaced with compatible new trim. Deteriorated historic wood trim will be replaced with new wood trim to match the historic. The issue here is the use of the term compatible versus to match, which of course do not mean the same thing. The same level of detail used to describe existing conditions should be applied to the proposed work.
Even if the scope of work does not have final plans, a basic outline of proposed changes should be included as part of the narrative. For example, final landscape designs are often not available when filling out the application, but it is still important to give a general description of how the landscape will be treated. The application narrative would have included the existing landscape features such as structures, driveways, parking, sidewalks and other hardscape, plant materials, mature trees, etcetera, and their location. The proposed work would address if the site will remain as is. Will there be additional access roads, parking, or new construction?
If the new site modifications require alterations to the existing landscape, describe how, where, and why proposed changes are necessary. The narrative for both existing condition and proposed work needs to be clear and precise, but it does not necessarily need to be long. This is an example from the application instructions which describes the treatment of the windows for a small house, and it conveys a general description of the existing windows and the proposed treatment. In two sentences, we know the type, material, and configuration. While the properties you are engaged in describing are far more complicated, a general rule is to keep the narrative concise, specific, and simple.
Bullet points can be a useful tool in noting specific elements of a feature and/or a proposed treatment. A proposed treatment that may be appropriate for a limited area may not be appropriate for the whole building or a larger area. Therefore, language such as repair or replace as needed, whenever possible, or greatest extent possible, should be avoided as this language is not specific enough for review and may result in the project being put on hold because the language is not precise enough to determine the extent or intention of the proposed treatment. The Preservation Briefs and other resources offer guidance on a variety of treatments and situations. Guidance publications should be used when choosing appropriate treatments, but the specific treatments that are proposed should be explained.
Simply stating that the work will be done in accordance with Preservation Brief X or will meet Standard X is not sufficient. The guidance outlined in a brief may be applicable to the circumstances of a project, but the details of how the guidance will be applied are necessary to understand the proposed treatment. Each specific treatment should be fully described in the narrative, with the area and the extent of the proposed treatment clearly defined. When best practices are the scope of the project, the project typically will meet the standards and be approved with ease. In such cases, a detailed written description and applicable supporting documentation is all the detail required.
However, when describing a treatment that may cause a red flag relative to the standards or on the face of the matter is not a recommended treatment that would give a reviewer pause, it is especially critical to explain the proposed treatment relative to the standards. In these cases, it is critical to explain why these changes are needed. How do the proposed treatments affect primary spaces, features, and materials? What alternatives have been considered in instances where the scope of work may not align with recommended treatments, the narrative should address how the proposed changes meet the standards in the context of the overall project. It is important to remember that while the project may be subject to additional requirements beyond historic tax credits, such as code related issues, sustainability, city ordinances, flood adaptation, or seismic reinforcement, these requirements may impact historic features, spaces, or materials which are still critical to maintain.
Alterations needed to comply with building codes and other requirements must be reviewed in the context of the overall rehabilitation and not solely on the need to comply with the requirements. By regulation, the Secretary's Standards for Rehabilitation take precedence over other regulations and codes into determining whether the rehabilitation project is consistent with the historic character of the property. However, creative solutions and flexibility can be found to meet the challenges while also complying with the standards. Talking through design challenges well in advance with SHPO staff or through a preliminary consultation may facilitate a solution well in advance of construction. For example, an important component of any rehabilitation project is bringing a building up to modern codes.
Illustrated here, the historic classroom doors are single light doors that offer no privacy to a new housing unit. They also don't meet fire code. An innovative solution applied in many projects is to keep the original door and utilize it like a screen door. A new fire rated door was installed on the interior of the unit in the former classroom. The historic doors are retained in the corridor and the required fire rating was achieved.
In addition to the written description of features that we have discussed, references to specific photos and drawing numbers in each item supplement the narrative as shown in this section of the form. Photographs are very important supplementary information and can convey the existing conditions which help reviewers to understand why specific treatment, particularly an intensive treatment, is being proposed. These photographs show the level of deterioration of the features and illustrate why treatments such as relaying masonry, replacement of missing features and or structural reinforcement are proposed in the narrative by providing important context. When photos are used strategically as an integral part of the narrative, they strengthen the case for the treatments described, fully document the existing conditions, and can also show the cause of the issue that a treatment is proposed to address, such as water infiltration, a catastrophic weather event, or a design flaw. In situations where the conditions are somewhat complicated, Annotated photographs can help illustrate the conditions and more precisely conveys information that may otherwise be difficult to describe in the narrative.
Illustrations such as this one can be referenced and added to the supporting documentation. There are many ways to illustrate conditions through the narrative and photographs. When writing an application, particularly an application for a building that requires complicated levels of intervention, choose the clearest way to describe and illustrate the treatments that are being proposed. As Amanda discussed in her presentation in progress photographs can help a reviewer understand work that was completed and or ongoing at the time of the application. It should be noted in the narrative when work has already been completed.
Photos of completed work should be referenced and submitted along with photographs illustrating the pre-rehabilitation conditions. Plans must be consistent with the work described in the narrative. If the narrative and the plans do not match, such as a narrative describes the first floor of an industrial building being converted to tenant spaces, but the plans illustrate proposed housing, the project will be put on hold for clarification. In certain limited facts and circumstances, such as the area pertains to a small component of the building, the project may be conditioned noting the discrepancy. A reminder that references to hit architectural and other drawings should not be substituted for the narrative, nor should the narrative description solely say, "see plans." In cases of applications involving functionally related buildings, all buildings must be described and labeled consistent with the Part 2 application, even if no work is being undertaken.
All buildings must be clearly identified on a site plan and in corresponding photographs. Describe the setting and all site improvements, including new construction, parking areas, and existing and proposed landscape features. Organize the Part 2 narrative on a building-by-building basis, starting with the primary building first, followed by the ancillary buildings and structures. And with that, I would like to introduce my colleague David Trayte for the second part of this presentation.
(David Trayte) Hey everybody, I'm David Trayte. In this next section, we want to take a deeper dive into the Part 2 application itself.
We have selected 3 building features, which include masonry, flooring, and MEP systems to use as case studies in crafting a specific narrative language. We selected these three as they tend to be areas of review delay, NPS conditions of approval, or potential problems during the course of the project. In each case study, we'll look at narratives that result in a review hold, approval with conditions, or approval without conditions. And each of these examples that it's either excerpts of text or perhaps bullet points of text from what the actual written narratives were, just for the sake of time and amount of text on each of these slides. In the Part 2 section of the HPCA instructions, Exterior Masonry Cleaning and Exterior Masonry Repair are called out under the Special Rehabilitation Concerns section.
This outlines technical concerns and recommendations for how to address these two Masonry topics in the Part 2 application. A successful Part 2 narrative will include detailed information regarding the existing condition and treatment of masonry. First, we need to know what the material is. Then clearly explain the condition of the masonry. How and where has the pointing failed?
Are there areas of heavy soiling or in need of replacement? It is best to avoid general terms such as good or bad. These words alone do not provide NPS distinct understanding of the building. In areas of deterioration, ratios, percentages, and other information like that can be useful in developing a deeper understanding of the condition if those figures are known. If the structure was coded historically or currently, it should be included in the narrative and photos provided.
Detailed photographs showing the condition and deterioration should be key to plans and referenced in the narrative. If any engineering or conservation reports have been completed and have guided the proposed treatment of the masonry work, those reports should be included in the submission as well. A successful Part 2 narrative will also clearly communicate the intended masonry treatment. While we understand that conditions and treatments can change and evolve throughout the project, it is important to define the areas of work in the materials, means, and methods in which the work will be undertaken, especially in the instance of cleaning and repointing. Be as specific as your current knowledge allows for the proposed work.
Treatment should have justifications. If abrasive blasting is proposed, why is it needed and preferred over other, gentler, perhaps more appropriate options? If replacement is necessary, the area of change should be documented, and replacement material should have a thorough explanation of its proposed use. In the same way, if mockups will be done, they should be called out and any information on what will be tested should be included in the narrative, along with any product specifications, if appropriate. On this former industrial building, the applicant submitted an amendment showing initial testing to remove localized exterior paint that was applied after the period of significance.
In this single-issue amendment, the applicant provided a collection of photographs with little information regarding the location and procedure that was used for testing. The narrative provided general statements such as the majority of blasting and the combination of both brick and wood elements as one. These statements do not give NPS an understanding of how much and where blasting utilized this procedure without descriptive photos, details of testing methods, and clarification on the use of multiple unspecified testing methods in a single area. NPS is unable to determine if the proposed work will meet the standards. While a mockup was technically submitted for review, the information provided in that mockup was lacking the context needed to complete review.
As a result, this amendment was placed on hold in order to request information regarding true pre-and-post cleaning samples, better product identification, better documentation of testing and cleaning procedures, product data for paint to recoat select areas, and mortar mockups for masonry repair as well. This treatment could have been a condition in a different circumstance, but as this was a stand-alone amendment with a substantial scope of work that could impact the project's ability to meet the standards, review hold was warranted in this case. In this example, the narrative for this painted concrete building was overly general with little description of what would or would not be treated. The information that was provided, such as the application of a breathable masonry coating, left many questions regarding the product and application procedure. As the concrete building seen in the photograph has a variety of finished and unfinished exterior surfaces, it was important to better understand what impact a breathable masonry coating would have on the aesthetic and physical character of the building.
A condition was placed on the application for information regarding the proposed product specifications and how it would be applied. The requested mockup will help NPS better assess the characteristics of the coding and any visual change to the concrete surface, with before and after photographs to be provided. The building shown here is an early to mid-20th century automobile showroom and repair shop. The primary facade has a distinct terracotta design that remains largely intact. The narrative described the different types and condition of the masonry on the building, with supplemental photo documentation, taking care to highlight specifically what is deteriorated and needs repair.
Details of the glazing deterioration, soiling levels, and structural issues were all clearly conveyed. The description of work subsequently covered what elements were to receive work and what work would entail. The cleaning description stated the intent and general parameters of the cleaning campaign and then completed the description by saying that before and after test photos would be submitted for review. While they acknowledged the need to submit mockups of the cleaning and mortar repointing, a narrative such as this is only as successful as the follow through submission of the mockups. A narrative from masonry work such as this one could be approved without conditions.
As Angela mentioned earlier, only citing Preservation Briefs in the narrative as in “masonry repointing will be completed in accordance with NPS Preservation Brief 2” isn't enough information to determine if the work meets the standards. Preservation Briefs provide guidance and identifying and developing appropriate treatments, but they don't tell us anything about your particular project. The Part 2 narrative still needs to specify an actual treatment. Moving on to the second case study, let's take a look at flooring. A good flooring narrative will describe the existing floor materials in each space and reference specific photographs that illustrate the flooring type and condition.
A good flooring narrative will also describe the condition of each type of floor material. If there are any applicable reports or surveys regarding condition or perhaps unique material situations, those should be provided if available. However, that's not always the case. It's not common that we need that level of detail or information. Is the existing floor known to be historic or non-historic?
What does the physical evidence tell us in answering that question? If the existing floor is covering an earlier, possibly historic floor, describe that underlying material and its condition, as well as the potential for uncovering and repair of the historic material itself. And if no historic flooring remains, describe what the historic flooring would have been based on the age, the use, and the type of building. Provide historic documentation if it's available. A good flooring narrative will also describe the proposed treatment clearly.
Include detailed information to justify removal, replacement or covering of historic flooring when the treatment is not due to obvious deterioration. What is the proposed replacement material? Be specific and include material type, dimensions, color, and finish as well as manufacturer specifications for any substitute material products proposed. Reference any code compliance or ADA accessibility issues by citing the specific code and how it impacts to the project and proposed treatment. The Part 2 narrative and photograph should work together to help reviewers understand the building.
Photographs should illustrate each type of flooring described and show overall as well as close up images of the various types of flooring. If multiple flooring types exist in a single space, those intersections and interaction of various flooring systems should be documented. If there is a lot of furniture, perhaps fallen plaster or trash all over the building, might be excessively dirty, a photo of a clean section of the floor can be helpful. The first example captures a general issue that can result in a review hold. We want to note that flooring is typically a treatment that can be worked out through conditions with the Part 2.
That said, we sometimes get examples like these buildings where the narrative describes a non-historic floor over extant historic flooring with a general reference to hazardous materials. The proposed work is only described to remove all flooring as part of widespread abatement efforts with a questionable replacement finish. A few examples shown here could include carpet with asbestos based glues over wood floors, asbestos tiles over wood, or maybe even wood block floors soaked in contaminants from industrial use, situations we certainly have seen in many projects before. A review hold may be warranted if we're missing documentation of the historic floor condition and location, confirmation and analysis of the hazardous materials that were referenced, missing justification for the specific treatment proposed to address that environmental contamination, and proposed replacement material is not compatible with the historic building. We all know these hazardous material situations can make it difficult to salvage buried historic materials, in which case there could likely be flexibility in finding a compatible replacement flooring material.
The point is you can avoid these type of holds by providing sufficient information for unique situations such as these. In this example of an industrial mill being converted to residential use, the description of the existing flooring provided sufficient information about the conditions of the floor, the type of damage and location, along with comprehensive photo documentation. The narrative provides a clear understanding of proposed floor alterations in creating a fire rated assembly for code compliance and how the existing flooring would be covered as part of that effort. Finally, the narrative describes a general replacement flooring type to be of similar dimensions as the historic. So, what's missing in this case?
Although we know the general type of flooring that will be used, too little information and no images were provided for the new flooring material. The specific dimensions should be included rather than just say it will be "similar" and the color, finish, general appearance, and in some cases the direction floorboards are laid can be important considerations for review depending on the historic and proposed materials. Therefore, a condition would be issued to require an appropriate match of the new floor to the historic characteristics, with details to be provided in order to prove an appropriate match. For replacement of historic flooring with new materials, providing photographs of both the existing and proposed replacement side by side for comparison is very helpful in confirming a good match. NPS does not typically need physical product samples or pieces of historic fabric sent to us for in person review.
As long as we have quality photographs or product specification sheets, we can quickly make an assessment on the proposed materials. This is an example of a 1920s lodge hall or social club converted to hotel use. The narrative explains the existing condition consisted of non-historic or missing finishes with concrete underneath. Photographic documentation was provided to confirm no historic flooring remains. Historic documentation was also provided, like the image on the bottom which confirmed the historic floor finishes throughout the building, in which case included rolled linoleum, tile or carpet depending on the space within the building.
The description of work proposed the vinyl product with intentions of being compatible with the historic character, in this case specifying a non-wood look product. The applicant also commits to providing product specifications and future amendments once decisions are made on those final finishes. Photographs and drawings are clearly referenced to help illustrate the varying conditions throughout the building. This example provides a sufficient level of detail to be approved without conditions. Our reviews and context of the standards always start with retention and repair, a replacement with a like material.
It's been our experience the new products that were emerging in the vinyl and laminate flooring markets have not been a good match in appearance or quality, and the products selected for rehabilitation projects weren't characteristic of the actual building. However, we note the range of available products has drastically increased with efforts to improve quality. The reality is there's a limit in what these products can appropriately match and may not be a good substitute for wood floors that are character defining to a building, or for wood that is not beyond repair. These two photos are prime examples of that, with laminate on the left and LVT on the right both being laid over historic wood. However, there are some instances in which the overall facts and circumstances may allow for the faux wood LVT where floors are missing or severely deteriorated beyond repair, with careful attention to dimensions and appearance.
We acknowledge the desire for consistency and review on this subject, and we also recognize that flooring has been an evolving challenge. We're committed to continuing our work in developing specific guidance on this subject and providing webinar training in the near future. However, in the meantime, crafting Part 2 narratives with clear identification of historic materials and existing conditions will allow us to engage in that conversation and help applicants find success and appropriate treatments and particular product. Moving on to our third case study. We know integrating new mechanical, electrical and plumbing systems into historic buildings can be quite a challenge, which is why our final case study topic will look specifically at MEP narratives.
A quick reminder of the special rehabilitation concerns of the Part 2 application. HPCA instructions call out new heating, ventilation, and air conditioning systems, similar to the two masonry items I mentioned earlier. The instructions identify 3 tips. One, indicate what effect the new equipment in ductwork will have on the historic building, Two, new systems must not run across windows or introduce an unfinished character to otherwise finished interior spaces. And three, installation of systems that cause damage to the building or visual loss of character may result in denial of certification.
Before we start to look at specific narrative examples, keep in mind the big picture here. SHPO and NPS need enough description to understand what the spaces are going to look like, so we can evaluate whether the installed systems will meet the standards for each building. Detailed information and other changes can be submitted later, but we need that baseline understanding with the Part 2. A complete MEP description should generally address the following questions. What are the new HVAC needs?
Will air conditioning and ventilation be added? What will be visible in primary spaces versus secondary spaces? How will systems be distributed not only horizontally, but what about vertically? If exposed, will new systems obscure architectural features? What is the relationship to window heads, exterior walls, or exposed structure?
If concealed, where and how will those systems be handled? What about central equipment? What is the location, the size or screening? Is a rooftop visibility study needed? Will plumbing waste lines be visible at ceilings below?
And are the interior descriptions coordinated with MEP plans? A word of caution on this. While a general description of quote exposed ducts may be acceptable at the Part 2, we encourage the applicant to determine the type of duct system intended for use to avoid potential issues with project certification at the end of construction. As you see in these images, there are numerous types of ductwork that could fall in the category of quote exposed systems with a wide range of potential impact to character. This could include placement such as below or between joists like you see in the bottom image on the right.
Shape and size? Are the ducts square? Are they round or oval shapes like the top right? Are they short and wide ducts because of ceiling height issues? Are they large in size to move a lot of air across big open spaces?
What about the finish? Is it natural metal or painted? Is there insulation intentions? When does that mean double walled ducts or blanket insulation wrapped around the exterior of the duct? Specifying more with the Part 2 description or even an MEP amendment will help reduce condition language review delays or Part 3 issues.
We are now going to look at three examples, each for industrial buildings and for finished interiors. Given the complexity and length of some MEP narratives. Again, as I mentioned earlier, these examples use bullet points or excerpts from narratives and for the purpose of your applications, submitted narratives may be in paragraph or bullet format. Whatever your preference of choice is. The three industrial examples all use the same common scenario.
An industrial building being converted from multifamily residential use. Units will be accessed from newly created corridors, and the existing columns and ceiling structure will remain exposed. In this first example, the MEP narrative and accompanying drawings provides very little information. The proposed work reads to include a new HVAC system that will generally be installed to meet contemporary codes and living standards, and there's mention of an all-electric heat pump system that's being considered. Is this enough to understand what the systems are and what they will look like?
There's no description of placement, location, size, or concealment strategy for the possible system. The possible all electric heat pump may address only heating and cooling. Will a separate ventilation system be required? There's also no discussion of how the systems will impact the specific historic character and features of the building. So, with this type of MEP description, NPS may request information on the existing and proposed systems and at least a basic level of understanding of the proposed scope of work. and, if available, drawings to clarify the design intent.
We're not asking for mechanical drawings with the Part 2, we want to be clear about that, but we want to know what it will look like. Similar to flooring, we can often work out MEP issues through conditions. This situation may result in the hold or condition depending on specific circumstances. This second industrial example proposes MEP concepts that are appropriate for the historic mill building, but it's not clear whether the actual installation will meet the standards. The MEP narrative outlines the typical approach of exposed ductwork and hallways and common spaces with limited drop ceilings and bathrooms and kitchens.
However, the narrative indicates additional systems will have to go in the corridor where they do not fit above drop ceilings within the units. The density of systems in primary spaces, specifically the newly created corridors, is not clear from the description and the supporting information provided. Will we receive Part 3 photos that look like the top image on this slide? Will the systems in the corridors obscure the historic exposed ceiling structure? As a result, this description warrants a condition related to the treatment of those public corridors.
The NPS condition underscores the importance of keeping systems neat and tight to ceilings and walls without crowding the public corridor. Corridor should retain the open mill character with the historic exposed structure visible more in line with the bottom image. The condition also notes some systems may need to be located on the unit side of the corridor wall. Reflected ceiling plans are requested to confirm conformance with the standard and the condition language issued. Our last MEP example for an industrial building is one that NPS can approve.
It succinctly describes how MEP features will look, and we are able to determine the proposed work will meet the standards. The proposed HVAC description clearly articulates where exposed ducts will be installed and where strategic soffits or drop ceilings will conceal MEP systems. There is reference to an appropriate set back from windows and exterior walls. The description of HVAC work is further confirmed by the conceptual reflected ceiling plan, and the application promises more information will be submitted once the design is developed. The narrative also addresses the strategy for electrical conduit and sprinklers.
In this case, no conditions of approval are needed. Switching over to examples that describe MEP systems for finished interiors. This example converts a former office building into multifamily residential. The narrative is brief, but it is both incomplete and proposes a treatment which appears to not meet the standards. Let's focus on the proposed work description.
It proposes that non-historic finishes will be removed to expose structure above with new systems installed. Radiant heat will be removed along with modern equipment and fixtures, and new electrical and sprinkler lines will be installed throughout. So, what wasn't included in this case? The description does not explain the type of HVAC system. There's no information provided on central equipment, or ductwork, or piping, or how electrical will actually be treated.
And then what may not meet the standards? The project proposes to introduce an unfinished character to historically an existing finished interior space. NPS placed this project on hold for missing MEP information and to revise their proposal for appropriate interior finishes. Our second finished interior example is a commercial building being rehabilitated for event space. In this example, the explanation of the mechanical system could be appropriate for the building, but the language does not provide enough specificity.
The Interior's description explains the special and typical historic features. However, the description of the proposed work is vague. It says new HVAC, electrical and plumbing will be installed generally throughout the building. Ducts will be held against the wall and hidden except for on the ground floor. So, what wasn't included here?
How will the installed ground floor ducts actually look? How will the HVAC be concealed on the upper floors? Will duct enclosures be visible through exterior windows and have impact to the exterior character of the building? Each of these issues can be addressed with conditions. The required work should be readily achievable, including painting the ground floor ducts, sufficiently locating enclosures above window heads, etcetera, so that no additional drawings are needed to be submitted.
NPS will look for conformance in the Part 3 photos. Our final MEP example converts a small-scale hospital building into multifamily housing. The narrative is complete and concise in description while also addressing all the aspects of work. So, what makes it so effective? The narrative does more than just say systems will be concealed or exposed.
It tells us how each component, which in this case is a small high velocity duct with registers, will be concealed and it also tells us what historic fabric will be disturbed. It says that all piping, conduit, and ductwork will be removed and relocated in soffits or above ceilings. It commits that where historic ceilings remain, all new ducting will run in the existing joist bays. It also commits that to placing ducts within the attic for the second floor and the basement for the first floor. And also says that registers will be installed in inconspicuous locations to damage as little historic fabric as possible.
The narrative also describes where exterior equipment will be placed and any screening that would be necessary to go with that. It says condenser locations will be on the roof of an addition. It outlines venting strategies that are going through the roof. Gas meters mounted to low visibility wall. Transformer location is noted.
Other equipment will be placed in the rear yard behind certain screening elements. And it also outlines that equipment locations and venting strategies that are clear. A thorough description like this can be approved without conditions. These were only three specific treatment examples, but remember, the Preservation by Topic page on our website is a useful tool in quickly finding relevant guidance documents for all treatment topics, not just these three. We want to end the Part 2 session by stressing the importance of the narrative in the description of rehab work.
In summary, the narrative should be organized efficiently, describe all features but avoid unnecessary repetition, be specific in describing treatments, avoid general references to preservation briefs or other resources, and non-specific language such as the as needed and repair or replace type of language. Narratives also need to be consistent with plans. Reference to architectural and other drawings should never be substituted for the narrative. Remember that program regulation states where there are discrepancies, the written application will always take precedence. And finally, high quality color photographs should be properly labeled and referenced in the narrative. Photos need to fully document the condition of the building before and after rehab.
(Brian Goeken) Thank you for listening to the third of this five webinar training series on the HPCA application. We hope you found the information helpful. The other webinars that are part of this training series, as well as the HPCA application form, 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 covers the Historic Preservation Certification Application Part 2 – Description of Rehabilitation Work, including how to structure the narrative and narrative case studies on masonry, flooring, and MEP systems.
Duration
55 minutes, 20 seconds
Date Created
05/20/2025
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