Historic Preservation Tax Credits
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Transcript of Historic Preservation Tax Credits
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Historic Preservation Tax Credits
The Process and Avoiding Common Problems
Charles E. Fisher
New York City, June 2009
National Park Service, Technical Preservation Services
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• Projects approved – 36,000
• Investment of over $50 billion
• Repeat users
Success
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It Is a Regulatory Program
• Not uncommon that there will be some required changes
• Submit your project for review early in the planning process
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Who
• Administered by the National Park Service in conjunction with State Historic Preservation Offices (SHPO)
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What
• Unlike most other historic preservation review processes, your entire project will be reviewed
• Interior and exterior work on the historic building/s
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What•Any new construction on the site
•Parking
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Where
• Most SHPO offices are located in the state capital
• National Park Service’s Technical Preservation Services is in Washington, DC
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Two Certifications Are Needed
• Certified Historic Structure
• Certified Rehabilitation
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Three-Part Historic Preservation Certification Application
Part 1—Evaluation of Significance
• Is my building historic?
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Certified Historic Structure
• Individually listed in the National Register of Historic Places
• Contributes to a National Register historic district
• Contributes to a registered historic district
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Certified Historic Structure
• For a certified property with multi-buildings, such as a mill complex or a former military base, only contributing buildings are eligible.
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Preliminary Determinations
• Proposed individually listed National Register property
• Contributing building in a potential historic district
• Certified Historic Structure status must be obtained no later than 30 months after the building is placed in service
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Applicant
SHPO NPS
Part 1 Review
paper trail
routine communication
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Project Review
• Consult early on in the planning process with the SHPO
• Seek preliminary review from the National Park Service on potentially problematic issues prior to submission of Part 2 of the Application
• Most projects approved with conditions
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Three-Part Historic Preservation Certification Application
Part 2—Description of Rehabilitation
• Does my proposed work meet the Secretary of the Interior’s Standards for Rehabilitation?
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Secretary of the Interior’s Standards for Rehabilitation• 10 broad
principals of preservation
• Widely used by other agencies and organizations
• Only NPS issues certifications
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Part 2 and 3 Reviews
paper trail
communication
project specific and/or state specific
Applicant
SHPO NPS
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Three-Part Historic Preservation Certification Application
Part 3 Request for Certification of Completed Work (the last step)
• Submitted only after work is completed
• Issued by NPS only after completed work has met the Standards for Rehabilitation
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Phased Advisory Letters
• Projects involving multiple buildings in a complex that are being rehabbed one at a time
• Large building rehabilitation being done in distinct phases
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If Your Project is Denied
• First, try to resolve the issues
• Alternative is the Appeals Process
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Avoiding Common Problems
• Start the process early in the project planning
• Consult early with the SHPO
• Get decisions in writing from NPS
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Avoiding Common Problems— Part 2 Application
• Include both before (existing condition) plans and rehabilitation (after) plans
• Provide thorough photo documentation of the entire property in its before work condition— if shooting electronic images (good resolution), print on photo quality paper
• Authorize prepayment of processing fee charged by NPS
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Avoiding Common Problems
• Check websites of SHPO and NPS for additional information on the application submission
• Keep track as to which set of architectural plans have been approved
• Use services of a preservation consultant as needed
• Realize each project is different
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Special Considerations During The Current Economy
• Need to clearly establish what has been approved by NPS when there is a change in ownership during rehab
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Special Considerations During Current Economy
• Dealing with large multiple building projects – phasing and financing
• Obtaining Part-3 (final) certification – tenant fit-out
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State Incentives
• More than half of the states have tax credits or other incentives that can be piggybacked with the Federal tax credits
• Current budgetary pressure on state tax credit programs
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For Additional Information
• NPS website is www.nps.gov/history/hps/tps• SHPO websites • To request copy of NPS Technical Preservation
Services Catalog of over 100 publications either email at [email protected]
• Or write Technical Preservation Services, National Park Service, 1840 C Street NW, Washington, DC 20240; email [email protected]