HPCA SHPO Review & Recommendation Sheet Rehabilitation Part 2

Historic Preservation Certifications, 36 CFR Part 67

10-168 HPCA Instructions June 2016

HPCA SHPO Review & Recommendation Sheet Rehabilitation Part 2

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OMB Control No. 1024-0009

NPS Form 10-168i (06/2016)
National Park Service

Historic Preservation Certification Application
National Park Service

Instructions
The National Park Service (NPS) administers the Federal Historic Preservation Tax Incentives program with the Internal
Revenue Service (IRS) and in partnership with State Historic Preservation Offices. The tax incentives promote the
rehabilitation of income-producing historic structures of every period, size, style and type. Through this program,
underutilized or vacant schools, warehouses, factories, retail stores, apartments, hotels, houses, offices and other
buildings throughout the country have been returned to useful life in a manner that maintains their historic character.
The Historic Preservation Certification Application is
a three-part application used to apply for
certifications required for Federal historic
preservation tax incentives. The NPS certifies whether
a building is a “certified historic structure” and whether a
rehabilitation meets the Secretary of the Interior’s
Standards for Rehabilitation and is consistent with the
historic character of the building and, where applicable,
with the district in which it is located.

At a glance

Department of the Interior regulations (36 CFR Part 67)
take precedence in the event of any inconsistency with
this application. Approval of applications for Federal
historic preservation tax incentives is conveyed only in
writing by duly authorized officials of the NPS acting on
behalf of the Secretary of the Interior. Approval of a
project by other Federal, State, and local agencies and
organizations does not ensure approval by the Secretary
of the Interior for Federal tax purposes.
Applicants are strongly encouraged to contact their State
Historic Preservation Office (SHPO) early in the project
planning process, to submit applications describing
proposed work, and to receive approval from the NPS
before beginning rehabilitation work. Owners who
undertake rehabilitation projects without prior approval
from the NPS do so at their own risk. In the event of any
discrepancy between the application form and
supplementary materials submitted with it (such as
architectural plans), the application form takes
precedence. Photographs and other materials sent with
the application become the property of the NPS and may
be reproduced without permission.
IRS code and regulations govern all financial and other
tax matters relating to the rehabilitation tax credits
(Section 1.48-12) and the tax deduction for easement
donations (Section 1.170A-14). General information,
prepared by the IRS, about the tax aspects of these
incentives is available at the program website. Specific
questions about the tax aspects of these incentives
should be addressed to the IRS. Approval of historic
preservation certification applications by the NPS does
not mean that applications meet IRS requirements.

page 1

Federal Tax Incentives for Historic
Preservation

page 2

Before Applying

page 2

Application Process

page 3

Part 1—Evaluation of
Significance

page 5

Part 2—Description of Rehabilitation

page 8

Amendments / Advisory Determinations

page 9

Part 3—Request for Certification of
Completed Work

page 10 Photographs for Certification
Applications
page 10 Review Fees

Federal Tax Incentives for Historic
Preservation


20% income tax credit for the “certified rehabilitation”
of a “certified historic structure.”


A “certified historic structure” is a building that is
listed individually in the National Register of
Historic Places; or located in a “registered
historic district” and certified by the Secretary of
the Interior as contributing to the historic
significance of the district. A “registered historic
district” is a district listed in the National Register
or a state or local district certified by the
Secretary of the Interior.







How to Apply

A “certified rehabilitation” is a rehabilitation of a
certified historic structure that the Secretary of
the Interior has certified to the Secretary of the
Treasury as being consistent with the historic
character of the structure and, where applicable,
with the district in which the structure is located.

Send two copies of the application and accompanying
materials to the SHPO.

When to Apply

10% income tax credit for rehabilitation for nonresidential use of non-historic buildings built before
1936.
Income and estate tax deductions for an easement
donation on a “certified historic structure.”

Only depreciable properties can qualify for the tax
credits. For the tax deductions for easement donations,
the property need not be depreciable.

Consult an accountant, tax attorney, other tax
advisor, or the IRS to determine whether these
incentives apply to your own tax and financial
situation.



Make sure the project meets the “substantial
rehabilitation” test and other IRS requirements.



Contact your State Historic Preservation Office
(SHPO) for information and technical assistance.



Visit the program website, which includes program
regulations, frequently asked questions, Standards
and Guidelines, technical guidance, and much more.

Apply at any time during the year.



Apply before starting rehabilitation work whenever
possible.



The application parts may be sent separately or
together, but if they are sent separately, Part 1 must
precede Part 2.

Review Process
The SHPO reviews the application and forwards it to the
NPS with a recommendation. State recommendations
are given full and due consideration. By law all
certification decisions are made by the NPS on behalf of
the Secretary of the Interior. The NPS decision may differ
from the recommendation of the SHPO. The NPS notifies
the applicant of the decision and provides a copy of all
decisions to the IRS and the SHPO.

Before Applying




Review Times
The review time for a complete application is generally
30 days at the SHPO and 30 days at the NPS. A
complete application consists of the current version of
the application form, including:



an actual, original signed and dated cover sheet (the
first page of the Part 1, Part 2, Amendment, or Part 3
form), with all sections completed, including the
applicant’s social security number or taxpayer
identification number and all other requested
information; and

An applicant must be the owner of the property within
the meaning of owner set forth in 36 CFR 67.2: “Owner
means a person, partnership, corporation, or public
agency holding a fee-simple interest in a property or any
other person or entity recognized by the Internal
Revenue Code for purposes of the applicable tax
benefits.” For example, long-term lessees may also
apply for such tax benefits as allowed by the applicable
IRS provisions if their remaining lease period is at least
27.5 years for residential property or 39 years for
nonresidential property.



the other sections (Description of Physical
Appearance and Statement of Significance for Part 1
and Detailed Description of Rehabilitation Work for
Part 2) and required supporting information
(photographs, architectural drawings, etc.) for each
form as described in these instructions.

If the applicant is not the fee-simple owner of the
property, or is not the owner at the time of application
within the meaning of owner described above, “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 objection to the
request for certification” (36 CFR 67.3(a)1).

Review of Part 2 and Part 3 applications by the NPS
does not start until payment of the review fee has been
received (see Review Fees, page 10).

Application Process
Who May Apply

Incomplete applications may be placed on hold for
additional information or returned to the owner for
resubmission. Older versions of the application form are
not accepted.

—2—

Part 1—Evaluation of Significance

The Secretary of the Interior’s Standards
for Evaluating Significance within
Registered Historic Districts

Applicants are strongly encouraged to submit
applications and receive approval from the NPS prior
to the start of work. Owners who undertake
rehabilitation projects without prior approval from
the NPS do so at their own risk.

1. A building contributing to the historic significance
of a district is one which by location, design,
setting, materials, workmanship, feeling and
association adds to the district's sense of time
and place and historical development.

Use Part 1 to request certification that a building:



contributes to the significance of a registered historic
district or a National Register property with more
than one building and is thus a “certified historic
structure” for purposes of the 20% rehabilitation tax
credit or for easement donation purposes.



does not contribute to the significance of a historic
district for purposes of the 10% rehabilitation tax
credit for non-historic buildings.

2. A building not contributing to the historic
significance of a district is one which does not
add to the district's sense of time and place and
historical development; or one where the
location, design, setting, materials, workmanship,
feeling and association have been so altered or
have so deteriorated that the overall integrity of
the property has been irretrievably lost.
3. Ordinarily buildings that have been built within
the past 50 years shall not be considered to
contribute to the significance of a district unless a
strong justification concerning their historical or
architectural merit is given or the historical
attributes of the district are considered to be less
than 50 years old.

Use Part 1 to request a preliminary determination:



of whether an individual building not yet listed in the
National Register of Historic Places might meet the
National Register Criteria for Evaluation;



of whether a building in a potential historic district
contributes to the significance of the district;



of whether a building outside the period or area of
significance of a registered historic district
contributes to the significance of the district.

For buildings in historic districts, the information
furnished with Part 1 applications must be sufficient:
1) to document how the building relates to the district,
and 2) to evaluate the historic character of the building.
Applicants should consult the National Register historic
district nomination (on file at the SHPO or at the local
preservation commission). Such requests will be
reviewed for conformance with the Secretary of the
Interior’s Standards for Evaluating Significance within
Registered Historic Districts.

If the property is a single building listed in the National
Register of Historic Places, it is already a “certified
historic structure,” and a Part 1 is not needed. A Part 1 is
required for all other properties, including individuallylisted properties that have more than one building.
If the building is neither within a registered historic
district nor individually listed in the National Register, the
owner must submit a Part 1 and begin the separate
process of requesting the SHPO to nominate the building
or the district to the National Register.

Applications for preliminary determinations of individual
listing will be evaluated using the National Register
Criteria (36 CFR Part 60). For buildings that are in
potential historic districts or that are outside the period or
area of significance of a registered historic district,
applications will be reviewed for conformance with the
Standards for Evaluating Significance within Registered
Historic Districts. (36 CFR 67.5)

Late Submissions. Owners who wait until after all work
is complete, and the building is placed in service, before
they file Part 1 of the application and, where applicable,
request that SHPO nominate the building or district to
the National Register, do not qualify for the 20% tax
credit under IRS regulations. For additional information,
see Topical Tax Brief - Late Submission of Historic
Preservation Certification Applications on the program
website.

Completing Part 1 Form
First page of form. This page must be the actual,
official cover sheet, must bear the applicant’s original
signature, and must be dated. Other sections may be
expanded as needed or continued on blank paper.

Evaluating Part 1

Description of Physical Appearance. Describe the
major features of the building on both the exterior and
the interior. Describe the building in its present condition
(before rehabilitation), not as it was when first built nor

Part 1 decisions are made on the appearance and
condition of the property prior to rehabilitation.
—3—

variety of styles and types of architectural
ornamentation popular during this era. The district is
also significant as an early manufacturing and
distribution center, which led to the city's growth as
one of the largest cities in the state. Industrial growth
in the late 19th and early 20th centuries required the
construction of larger buildings, and several still exist
within the boundaries of the district (see
photographs). This modest three-story building is
typical in appearance and history of the majority of
the buildings in the district. It was originally built for
manufacturing buttons, but was converted into a
store with offices above during the 1880's when
wholesaling grew as an important new activity in the
district. The building is similar to its neighbors in
size, scale, materials, and style.

as it will be after rehabilitation. Note the architectural
style, exterior construction materials (wood, brick, etc.),
type of roof (flat, gable, hipped, etc.), number of stories,
basic plan (rectangular, irregular, L-shaped, etc.), and
distinguishing architectural features (placement and type
of windows, chimneys, porches, decorative interior
features or spaces). Describe changes made to the
building since its construction (additions, porch
enclosures, new storefronts, relocation of doors and
windows) and interior alterations. Describe other
buildings on the property such as carriage houses, barns,
and sheds. (See Special Considerations: Multiple
Buildings, page 5.) Discuss how the building relates to
others in the district or neighborhood in terms of siting,
scale, material, construction, and date.

Send with the Part 1 Form

Provide the construction date and date(s) of alterations.
Give the source of the date. Check the appropriate box if
the building has been moved.

Ownership statement, if applicable. If the applicant is
not the fee-simple owner of the property, or is not the
owner at the time of application within the meaning
of owner set forth in 36 CFR 67.2, the application must
be accompanied by a written statement from the feesimple owner indicating that he or she is aware of the
application and has no objection to the request for
certification. (See Who May Apply, page 2)

Example - Building within a registered historic district
This three-story, flat-roofed, unpainted brick
building, rectangular in shape, was constructed in
1850. It features regularly-spaced arched windows
on the second and third floors (6 openings on the
east elevation have been filled in over the years,
exact date unknown), 2-over-2 double-hung sash,
and a prominent bracketed cornice. The first floor of
the facade has been altered: the existing storefront
dates from ca. 1990. On the interior, the first floor is
divided into two principal spaces—a large
commercial space in front and a smaller office
behind. The front room was greatly altered in the
1990's and contains no surviving historic fabric
except for a simple wooden staircase running along
the party wall. A pressed metal ceiling is the most
prominent feature in the rear office; baseboards,
paneled doors, and window and door surrounds also
survive in this room. The upper floors have two
rooms each, identical in configuration to the first
floor; these rooms retain their original appearance,
although they contain no architectural detailing of
any kind (see photographs).

Photographs and photo key. Send photographs of the
property as it appears before rehabilitation. Include
photographs of the building’s site and environment, all of
the building’s sides, all major interior spaces and
features, and representative secondary spaces and
features. See page 9 for instructions on preparing and
labeling photographs for certification applications.
Map. Send a map of the historic district, with the building
location highlighted. If the application describes a
property with more than one building, the map must
show each building in the property. If the applicant does
not own or control the entire property, the map must
identify the portion under the applicant’s ownership or
control; this information may be provided on a second
map, if necessary. (See Special Considerations –
Part 1, Multiple buildings and buildings functionallyrelated historically, page 5)

Statement of significance. Summarize how the building
contributes to the significance of the district. This
summary should relate to the significance of the district
(including the district's period of significance) as identified
in the National Register nomination or district
documentation. This statement of significance should
also relate to the Secretary of the Interior's Standards for
Evaluating Significance within Registered Historic
Districts. Is it similar to other buildings in the district in
scale, building materials, style, and period of
construction? Note important figures from the past
associated with the building, any former uses, and the
name of the architect or builder, if known.

Special Considerations – Part 1
Certain situations may require applicants to do
additional research or provide additional information.
Certifications of non-significance. A certification of
non-significance is a determination that a building does
not contribute to the significance of a registered historic
district. This certification is needed when a building is
located in a historic district and the owner wishes to
claim the 10% tax credit for rehabilitation of non-historic
buildings. The application must demonstrate that the
building lacks or has lost the characteristics that
contributing buildings in the district possess. The
application must show how the building compares to
others in the neighborhood and the district. The

Example - Building within a registered historic district
The district is an intact grouping of architecturally
significant commercial and industrial buildings
constructed between 1850 and 1915 that display a
—4—

historically, NPS decisions regarding the certification of
the rehabilitation will be based on the rehabilitation of the
entire property, and not on each individual component,
pursuant to 36 CFR 67.4(e) and 36 CFR 67.6(b)4.

documentation must address changes since the
building’s construction. Good photographs are essential;
historic photographs should also be provided if possible.
When certification of non-significance is requested for
deteriorated or damaged buildings, it may be necessary
to submit a structural engineer's report and additional
information to document the deterioration or structural
damage.

Preliminary determinations. Applications for
preliminary determinations must contain substantially the
same level of documentation as National Register
nominations, as specified in 36 CFR Part 60 and NPS
instructions for completing National Register
nominations. An application for a preliminary
determination for individual listing must show how the
building meets the National Register Criteria for
Evaluation. An application for a building in a potential
historic district must describe the district and document
how the district meets the criteria and how the building
contributes to the significance of that district. An
application for a preliminary determination for a building
in a registered historic district that is outside the period
or area of significance of the district must justify the
expanded significance of the district and how the
building contributes to the significance of the district.
Preliminary determinations are not binding upon the
NPS, and become final only when the building or district
is listed in the National Register, or, for buildings outside
the period or area of significance of a registered historic
district, when the district documentation is formally
amended.

Moved buildings. Moving a building into or within a
historic district can jeopardize its ability to contribute to
the significance of the district. For a building that has
been moved or will be moved, the Part 1 must
document: 1) the effect of the move on the building's
appearance (any proposed demolition, proposed
changes in foundations, etc.); 2) the setting and
environment of the proposed site; 3) the effect of the
move on the historic and visual character of the district;
and 4) the method for moving the building. The
application must also include photographs of the
previous and proposed environments, including sites,
adjacent buildings, and streetscapes. For buildings
individually listed in the National Register, the
procedures in 36 CFR Part 60 must be followed before
the move, or the buildings will be removed from the
National Register, will not be considered certified historic
structures, and will have to be renominated for listing.
Properties less than 50 years old. Properties less than
50 years old are generally considered not to contribute
to the significance of a district and are ordinarily
excluded from individual listing in the National Register.
Standard 3 of the Secretary of the Interior's Standards
for Evaluating Significance within Registered Historic
Districts requires that to be certified as contributing to
the district such properties must have exceptional
historic or architectural merit or the district must
encompass significant qualities and characteristics that
are less than 50 years old. Documentation for these
properties must explain how the property meets the
requirements. (For information on the individual listing of
properties less than 50 years old, refer to National
Register Bulletin No.22, How to Evaluate and Nominate
Potential National Register Properties That Have
Achieved Significance within the Last 50 Years.)

Part 2—Description of Rehabilitation
Part 2 describes rehabilitation work to be undertaken on
the building, and must be completed by all applicants
seeking the Federal income tax credit for the
rehabilitation of historic buildings. Part 2 will not be
reviewed by the NPS until Part 1 has been filed and
acted upon.
Applicants are strongly encouraged to submit
applications describing proposed work and to
receive approval from the NPS prior to the start of
work. Owners who undertake rehabilitation projects
without prior approval from the NPS do so at their
own risk.

Evaluating Part 2

Multiple buildings and buildings functionally-related
historically. Some historic properties have more than
one building. In these cases, the Part 1 must describe all
the buildings on the property, even those that will not
undergo rehabilitation. This requirement applies to
properties listed individually in the National Register and
to properties in historic districts. The Part 1 must
describe each building and its significance and state
whether it is a candidate for certification of significance
or non-significance. The application must contain
photographs of each building and a map or site plan of
the entire property. If the applicant does not own or
control the entire property, the map must identify the
portion under the applicant’s ownership or control; this
information may be provided on a second map, if
necessary. If the buildings were functionally-related

Proposed work will be evaluated using the Secretary of
the Interior’s Standards for Rehabilitation and 36 CFR
67.7. Conformance with the Standards will be
determined on the basis of the application
documentation and other available information by
evaluating the property as it existed prior to the start of
the rehabilitation work, regardless of when the property
becomes or became a certified historic structure.
The Standards apply to both interior and exterior work,
and the NPS reviews the entire rehabilitation project,
including any attached, adjacent or related new
construction on the property. The Standards are applied
in a reasonable manner, taking into consideration
—5—

Examples - Part 2 Description of Work

Number 1

Feature

Siding

Date of Feature

ca. 1900

Describe existing feature and its condition

The current siding appears to have been installed at the time of the 1900 expansion. The weatherboard is in fair
condition except for those boards at the front of the house near the ground.
Photo numbers

1-7, 10, 18

Drawing numbers

N/A

Describe work and impact on feature

Most of the siding will be scraped, sanded, and repainted. Those boards that are in poor condition will be replaced
with cedar that will be cut to match the dimensions and profile of the existing weatherboard. All new siding will be
installed to match the overlap distance of the existing.
Number 2

Feature

Windows

Date of Feature

mid-1800s

Describe existing feature and its condition

The windows on the front and sides of the house are all matching 9/9 double-hung wood sash. Windows on the back
are a variety of 20th century styles.
Photo numbers

12, 19- 23

Drawing numbers

5.2 thru 5.5

Describe work and impact on feature

The historic windows on the front will be repaired, cleaned, and repainted. Windows on the back will be replaced with
wood windows in a 1/1 double hung configuration.

Detailed Description of Rehabilitation Work. Describe
all work that will be undertaken on the property, not
simply work for which the tax credit will be sought.
Describe each feature and the work that will be done on
it. Begin with site work, followed by the exterior,
including new construction, and then the interior. Give
the photograph or drawing numbers that show the
feature, and the marked photographs or drawing
numbers showing the proposed work. Describe
processes such as masonry cleaning in the application
narrative; do not attach specification books. Include
information relevant to the application of the Secretary of
the Interior’s Standards for Rehabilitation and 36 CFR
67.7. For phased projects: In the Part 2, outline the
work to be done in each phase; fully describe all work in
those phases for which detailed information is available.
Submit Amendments providing full details for work in
later phases as they become available.

economic and technical feasibility. Certification is based
on whether the overall project meets the Standards. To
be certified, a rehabilitation project must be determined
to be consistent with the historic character of the building
and, where applicable, the district in which it is located.
The Secretary's Standards for Rehabilitation take
precedence over other regulations and codes in
determining whether the rehabilitation project is
consistent with the historic character of the property and,
where applicable, the district in which it is located.

Completing the Part 2 Form
First page of form. This page must be the actual,
official cover sheet, must bear the applicant’s original
signature, and must be dated. Other sections may be
expanded as needed or continued on blank paper.

Send with the Part 2 Form

The estimated rehabilitation costs must be reported on
the form and are defined as the project’s total estimated
“Qualified Rehabilitation Expenditures,” or “QREs,”
pursuant to section 47 of the Internal Revenue Code.
For a project involving multiple buildings that were
functionally related historically pursuant to 36 CFR part
67, the costs reported on the form must be the total
estimated rehabilitation costs of the entire project. If the
rehabilitation project is to be phased pursuant to 36 CFR
part 67, the costs reported on the form must be the total
estimated rehabilitation costs for all phases.

Ownership statement, if applicable. If the applicant is
not the fee-simple owner of the property, or is not the
owner at the time of application within the meaning
of owner set forth in 36 CFR 67.2, the application must
be accompanied by a written statement from the feesimple owner indicating that he or she is aware of the
application and has no objection to the request for
certification. (See Who May Apply, page 2) If the
statement was submitted with a previous part of the
application, a duplicate copy is not required.
—6—

The Secretary of the Interior's Standards for Rehabilitation
Rehabilitation projects must meet the following Standards, as interpreted by the National Park Service, to qualify as
“certified rehabilitations” eligible for the 20% rehabilitation tax credit. The Standards are applied to projects in a
reasonable manner, taking into consideration economic and technical feasibility.
The Standards, codified in 36 CFR 67.7, apply to historic buildings of all periods, styles, types, materials, and sizes.
They apply to both the exterior and the interior of historic buildings. The Standards also encompass related landscape
features and the building’s site and environment as well as attached, adjacent, or related new construction.
1. A property shall be used for its historic purpose or be placed in a new use that requires minimal change to the
defining characteristics of the building and its site and environment.
2. The historic character of a property shall be retained and preserved. The removal of historic materials or alteration
of features and spaces that characterize a property shall be avoided.
3. Each property shall be recognized as a physical record of its time, place, and use. Changes that create a false
sense of historical development, such as adding conjectural features or architectural elements from other
buildings, shall not be undertaken.
4. Most properties change over time; those changes that have acquired historic significance in their own right shall
be retained and preserved.
5. Distinctive features, finishes, and construction techniques or examples of craftsmanship that characterize a
historic property shall be preserved.
6. Deteriorated historic features shall be repaired rather than replaced. Where the severity of deterioration requires
replacement of a distinctive feature, the new feature shall match the old in design, color, texture, and other visual
qualities and, where possible, materials. Replacement of missing features shall be substantiated by documentary,
physical, or pictorial evidence.
7. Chemical or physical treatments, such as sandblasting, that cause damage to historic materials shall not be used.
The surface cleaning of structures, if appropriate, shall be undertaken using the gentlest means possible.
8. Significant archeological resources affected by a project shall be protected and preserved. If such resources must
be disturbed, mitigation measures shall be undertaken.
9. New additions, exterior alterations, or related new construction shall not destroy historic materials that
characterize the property. The new work shall be differentiated from the old and shall be compatible with the
massing, size, scale, and architectural features to protect the historic integrity of the property and its environment.
10. New additions and adjacent or related new construction shall be undertaken in such a manner that if removed in
the future, the essential form and integrity of the historic property and its environment would be unimpaired.

Photographs and photo key. Send photographs
showing the interior and the exterior before
rehabilitation. Include the building’s site and
environment, all of the building’s sides, all major interior
spaces and features, and representative secondary
spaces and features, including areas where no work is
proposed. See page 9 for instructions on preparing and
labeling photographs for certification applications.

Dimensions and notes must be clearly legible. For small
projects, sketches may suffice. Drawings must be
numbered and keyed to the application narrative.

Special Rehabilitation Concerns
Several treatments can be problematic. The Guidelines
for Rehabilitating Historic Buildings accompanying the
Secretary of the Interior's Standards for Rehabilitation,
as well as information available on the NPS website,
provide further guidance on these and other treatments.
Applicants should address these concerns when
undertaking work in any of these areas and include the
information outlined below in the application.

Architectural drawings or sketches. Send
architectural draw8ings or sketches showing the existing
conditions and the proposed rehabilitation work and any
new additions or new construction. Include floor plans
and, where necessary, sections and elevations.

—7—

New heating, ventilation, and air-conditioning
(HVAC) systems. Indicate what effect the new
equipment and ductwork will have on the historic
building. New systems must not run across windows or
introduce an “unfinished” character to finished interior
spaces. Installation of systems that cause damage to the
historic building material or visual loss of character may
result in denial of certification.

Exterior masonry cleaning. Owners are strongly
encouraged to clean masonry only when necessary to
halt deterioration or to remove graffiti and stains.
Indicate the condition of each material to be cleaned.
Specify what the cleaning is intended to accomplish
(soot removal, paint removal, etc.) and what process is
to be used. When chemical systems are to be employed,
specify the product to be used and its application.
Information for cleaning involving chemical processes
should include products to be used and water pressure
in pounds per square inch (psi). Provide material to
show that the method selected will not harm the
masonry. Summarize results of test patches, and include
close-up color photographs of masonry surfaces before
and after cleaning as evidence.

New additions and new construction. New additions
may substantially alter the appearance and form of
historic structures, and may cause denial of certification.
Similarly, new construction, including site work, may
affect the relationship of a structure to its site, change
the historic landscape, or otherwise damage the historic
character of the property. Owners are strongly
encouraged to obtain NPS approval before undertaking
projects involving new additions or new construction.

Exterior masonry repair. Indicate deteriorated areas
and describe repair method proposed. Provide evidence
that repointing mortar will match the historic in
composition (ratio of lime, cement, sand and any
additives), color, texture, and tooling. Owners are
encouraged to repoint only those portions of the
masonry that require repair.

Amendments / Advisory Determinations
Use an Amendment form to:

New windows. If replacement is proposed, indicate the
condition of existing windows (sash, glazing, muntins,
etc.) and the reasons for replacement. Photographs
must be provided as evidence of severe deterioration;
provide data on the cost of repairing existing windows
versus installing replacements. Owners are strongly
encouraged to retain and repair historic windows. Tinted
glass often causes a change in character and may result
in denial of certification. Where replacement of existing
windows appears justified by supporting documentation,
and where the windows are an integral part of the
building's design and character, replacement sash must
match the original in size, pane configuration, color, trim
details, and planar and reflective qualities, and, in most
cases, materials. Scaled drawings comparing the
existing windows with the replacement windows must be
provided.



Submit information requested by the NPS for an
application under review and on hold



Inform the NPS of a change in ownership



Amend a previously submitted Part 1, 2, or 3
application.



Request an advisory determination as to whether a
completed phase of a phased rehabilitation project
meets the Secretary of the Interior's Standards for
Rehabilitation

Completing the Amendment Form
First page of form. This page must be the actual,
official cover sheet, must bear the applicant’s original
signature, and must be dated. Other sections may be
expanded as needed or continued on blank paper.

Storefront alterations. Justify changes to storefronts
and provide photographs of the areas to be altered.
Document the date of construction of the existing
storefront and its condition. If a historical treatment is
planned, provide the evidence on which the proposed
new storefront designs are based. Owners are strongly
discouraged from introducing a storefront or new design
element that alters the character of the structure and its
relationship with the street or that causes destruction of
significant historic material.

To amend a previously submitted application. Briefly
describe changes to the original application. Describe in
detail in attachments if necessary.
To request an advisory determination on a
completed phase of a phased project. List work items
completed in the phase, and give the phase completion
date. Continue in attachments if necessary. The phase
completion date is the date that all work related to the
phase was completed. If the phase completion date and
the date the phase is placed in service pursuant to IRS
regulations are different, the date the phase was
completed is the date that must be reported on the form.

Interior partitions, trim, and finishes. Document the
existing condition of the interior. Indicate both historic
and non-historic walls. Show walls to be removed or
altered. Note whether trim and wall and ceiling finishes
will be affected. Owners are strongly discouraged from
changing historic floor plans unnecessarily and from
exposing masonry surfaces unless this condition is
supported by historical evidence.

The estimated rehabilitation costs of phase must be
reported on the form and are defined as the phase’s
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estimated “Qualified Rehabilitation Expenditures,” or
“QREs,” pursuant to section 47 of the Internal Revenue
Code.

Both the estimated rehabilitation costs and the total
estimated costs, which includes the costs attributable to
the rehabilitation plus all other project costs, must be
reported on the form. The estimated rehabilitation costs
are defined as the project’s estimated “Qualified
Rehabilitation Expenditures,” or “QREs,” pursuant to
section 47 of the Internal Revenue Code. If the
rehabilitation project was phased or involved multiple
buildings that were functionally related historically
pursuant to 36 CFR part 67, the costs reported on the
form must be the total costs for the entire project.

IRS rules require phasing plans to be set forth before a
project begins. See the IRS regulations for information
on meeting this requirement. The NPS can issue
advisory determinations only on the phases of a project
that have been defined at the start of the project in the
approved Part 2 application and only for work completed
in the defined phase.

Send with Amendment Form

On page 2, list all additional owners with their addresses
and Social Security or Taxpayer ID Numbers; continue
on additional sheets as necessary.

Ownership statement, if applicable. If the applicant is
not the fee-simple owner of the property, or is not the
owner at the time of application within the meaning
of owner set forth in 36 CFR 67.2, the application must
be accompanied by a written statement from the feesimple owner indicating that he or she is aware of the
application and has no objection to the request for
certification. (See Who May Apply, page 2) If the
statement was submitted with a previous part of the
application, a duplicate copy is not required.

Send with the Part 3 Form
Ownership statement, if applicable. If the applicant is
not the fee-simple owner of the property, or is not the
owner at the time of application within the meaning
of owner set forth in 36 CFR 67.2, the application must
be accompanied by a written statement from the feesimple owner indicating that he or she is aware of the
application and has no objection to the request for
certification. (See Who May Apply, page 2) If the
statement was submitted with a previous part of the
application, a duplicate copy is not required.

Amendments to previously submitted applications.
Send photographs and architectural drawings or
sketches needed to illustrate the amendment for which
approval is requested.

Send photographs taken after completion of the
rehabilitation work showing the same views as in the
Part 2. See below for instructions on preparing and
labeling photographs for certification applications.

Advisory determinations on a completed phase of a
phased project. Send photographs equivalent to the
documentation required for a Part 3 application for that
phase. See page 9 for instructions on preparing and
labeling photographs for certification applications.

Late Submissions. If a taxpayer claims the
rehabilitation tax credit, but never receives Part 3
approval from the NPS, the taxpayer will be subject to
recapture of the credit. For additional information
concerning late submissions and the IRS regulations,
see Topical Tax Brief - Late Submission of Historic
Preservation Certification Applications on the program
website.

Part 3—Request for Certification of
Completed Work
Use the Part 3 form to request approval of an entire
completed rehabilitation work. For a completed phase of
a project, use an Amendment form. The completed
project may be inspected by an authorized
representative of the Secretary of the Interior to
determine if the work meets the Standards for
Rehabilitation.

Photographs for Certification
Applications
Applications with photographs that are not adequate for
review will be placed on hold, and applicants will need to
submit better quality photographs before the NPS can
complete review of the application.

Completing Part 3
First page of form. This page must be the actual,
official cover sheet, must bear the applicant’s original
signature, and must be dated. Other sections may be
expanded as needed or continued on blank paper.

Number of photographs. Applicants must use their
judgment as to how many photographs adequately "tell
the story" of their building. Large or complex projects
often require more photographs to illustrate the various
elements and areas the building and site.

The project completion date is the date that all work
related to the project was completed. If the project
completion date and the date the property is “placed in
service” pursuant to IRS regulations are different, the
date the project was completed is the date that must be
reported on the form.

Labeling photographs. Photographs must be labeled
with the following information:
 Building name (if applicable) and address
—9—





View shown (north side)
Description of the view (plaster damage in dining
room, north wall)
Date taken

Photographs must be numbered and keyed to both the
description of proposed work in the application and
photo key plans of the building and site.
Example of a photo key

Clarity of photographs. Photographs must be clear and
must have sufficient resolution to show the details
required for review of rehabilitation work. Photographs
must be:
 In color
 Taken at a high resolution
 Printed on photographic, not photocopy, paper.
Professional printing is recommended for best
results
 Printed at least 4” x 6” in size
Format of photographs. Photographs must be printed.
Photocopied photographs (black and white or color), and
photographs smaller than 4” x 6” are not accepted.
Applicants may submit disks of digital photographs, only
if printed photographs meeting all of the above criteria
are also included in the application materials submitted
for review.

Review Fees
The NPS charges a fee for reviewing Part 2 and Part 3
applications according to the fee schedule posted on the
program website. Review fees are based on the
estimated rehabilitation costs reported on the application
forms and defined as the project’s total estimated
“Qualified Rehabilitation Expenditures,” or “QREs,”
pursuant to section 47 of the Internal Revenue Code. If
the rehabilitation project is phased and/or involves
multiple buildings that were functionally related
historically pursuant to 36 CFR part 67, the costs
reported on the form are the total costs for the entire
project.

The NPS will bill you for the review fee upon receipt of
your application. Do not send payment until requested
to do so by the NPS.
Review of Part 2 and Part 3 applications by the NPS
does not start until payment has been received.

For More Information
See the for program website for more information on the
historic preservation tax incentives, including:



Program regulations
 NPS/Department of the Interior regulations, 36
CFR Part 67
 Internal Revenue Code Section 47,
Rehabilitation credit
 IRS Regulations—26 CFR 1.48-12, Qualified
rehabilitated buildings



The Secretary of the Interior's Standards for
Rehabilitation and accompanying Guidelines



Planning Successful Rehabilitation Projects



Applying the Secretary's Standards to Rehabilitation
Projects



Technical information on a variety of rehabilitation
issues



Information on the IRS aspects of the program



An online database for application status checks

Contact your SHPO for information regarding state
incentives for historic preservation.

Contact Us
National Park Service
www.nps.gov/tps/tax-incentives.htm
e-mail: NPS_TPS@nps.gov
202-513-7270
State Historic Preservation Offices
www.ncshpo.org/directory/

— 10 —

NOTICES
Privacy Act Statement
General: This information is provided pursuant to Public Law 93-579 (Privacy Act of 1974), December 21, 1984, for individuals completing this form.
Authority: The authority to collect information on the attached form is derived from one or more of the following:
Sections 47 and 170 of the Internal Revenue Code authorize the tax incentives program. Section 6109 authorizes collection of owners’ Social Security
Numbers or Taxpayer Identification Numbers. Department of the Interior regulations (36 CFR Part 67) require owners to provide this information on the
application.
Purposes and Uses: [LIST PURPOSES AND USES]
Effects of Nondisclosure: [LIST EFFECTS OF NON-DISCLOSURE]

Paperwork Reduction Act Statement
We are collecting this information subject to the Paperwork Reduction Act (44 U.S.C. 3501) through the State Historic Preservation Officer in order to
enable the Secretary of the Interior to gain the benefit of the State review of applications for Federal tax incentives for historic by owners of historic
properties. Information collected on this form, including names and all written comments, is subject to disclosure. All applicable parts of the form must
be completed in order to receive consideration for the requested benefit. A Federal agency may not conduct or sponsor, and a person is not required to
respond a collection of information unless it displays a currently valid OMB control number. OMB has approved this collection and assigned it control
number 1024-0009.

Estimated Burden Statement
Public reporting burden for this form, including the time it takes to read, gather and maintain data, review instructions, and complete the form, is
estimated to average 27 hours per response for Part 1; 51 hours per response for Part 2; 15 hours per response for an Amendment/Phase Advisory
request; and 17 hours per response for Part 3. Direct comments regarding this burden estimate, or any aspects of this form, to the Information
Collection Clearance Officer, National Park Service, 12201 Sunrise Valley Drive, Mail Stop 242, Reston, VA 20192. Please do not send your form to
this address.
Records Retention Requirements
The National Park Service has no requirements for how long applicants must retain these records. The National Park Service advises applicants to
retain these records in accordance with time periods established by the IRS.

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AuthorShiffer, Rebecca
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File Created2016-06-14

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