The National Park Service is available to provide advice in the early stages of project planning to the extent possible within its workload. This guidance applies to all requests for preliminary consultations and meetings about projects for which the Historic Preservation Certification Application has not yet been submitted.
Applicants should discuss questions they may have about the application, program requirements, or rehabilitation treatments with the SHPO early in the planning stages of a project. In cases involving a specific problematic rehabilitation treatment or treatments that may not meet the Standards—and could cause the overall project to not meet the Standards—the SHPO may decide that a preliminary consultation with the NPS may be useful prior to submitting a Part 2 application. Also, a preliminary consultation is strongly recommended prior to the submission of a Part 1 application for all projects involving multiple buildings functionally related historically that an applicant proposes to be treated as separate projects for the purposes of certification under NPS guidance.
A preliminary consultation generally focuses on one or a few specific issues (e.g., a change to a street façade or a change to a significant floor plan or primary interior space); it is not a review of an entire project. Preliminary consultations are advisory only, limited to the specific issue or issues for which the consultation is requested, and are never a substitute for the review of an entire rehabilitation as described in a Part 2 application. Facts and circumstances of a project may change between the time of a preliminary consultation and submission of a Part 2 application.
Whether to request a preliminary consultation with the NPS for a specific project is at the discretion of the SHPO, not the applicant. The SHPO must feel that NPS input is warranted prior to submission of the application. SHPOs regularly consult with the NPS on an informal basis when questions arise pertaining to the administration of the program or specific treatments, and a preliminary consultation is generally therefore not necessary in most instances. A preliminary consultation is typically more formal, requiring supporting information prepared by the applicant, and the nature of the issue requires that the NPS weigh in on the project more formally.
The NPS generally conveys an oral 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 NPS, the NPS response to the SHPO may be in writing to the SHPO or jointly conveyed to the applicant. The NPS response to a preliminary consultation is advice and guidance only; it is not a certification decision that may be appealed. Even when a preliminary consultation has occurred, the NPS advises applicants to submit a complete Part 1 and/or Part 2 application, as applicable, early in the project planning process so that any questionable issues or treatments can be resolved prior to beginning work.
It is at the discretion of the SHPO, not the applicant, to request a preliminary meeting. The SHPO must feel that NPS input is warranted prior to submission of the Part 2 application.
If not previously provided, photographs of the historic property, a description of the significance of the property (such as a draft or completed National Register nomination), and applicable plans of existing conditions and proposed work must be provided through the SHPO to NPS for review prior to the meeting.
The location, whether on site or in Washington, and time of the meeting will be determined by NPS. The SHPO will have the opportunity to attend the meeting in person or to participate via telephone. When the SHPO is unable to attend the meeting, the applicant must first consult with the SHPO about the issues of concern.