The New Texas Historic Preservation Tax Credit
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- Nigel James
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From this document you will learn the answers to the following questions:
Who approves the National Register application?
What process takes 1 year for new listings to be approved?
What is the goal of the National Register process?
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3 How do you apply? Tips for Part 1/A - Evaluation of Significance: Application processing takes 30 days, however new National Register listings generally can take 1 year for reviews and final approval by the State Board of Review and the National Park Service. Plan ahead. Hire a qualified consultant to write the National Register nomination. If the building is already listed on the National Register of Historic Places individually or as part of a district, this part of the application is more of a formality but do it early to confirm the property s status. The property s contributing and non-contributing features will be defined in Part 1/A.
4 How do you apply? Tips for Part 2/B Description of the Rehabilitation: Communicate with THC about the rehabilitation proposal early in planning stages, particularly if a change in use is proposed. Make sure to submit comprehensive photos of the interior and exterior before work takes place. An completed application is usually reviewed in 30 days, incomplete applications will delay the review process. Only work that was described in the text of the Part 2 narrative or amendments is approved. During construction, any changes to the design or scope will require submission of a Part 2/A Amendment. A review fee is calculated based on the estimated project costs. Fees range between $150 and $9,000.
5 Part 2 Example: It s all in the detail Describe what is there, what era it s from, and what the condition is. Describe exactly what work is proposed. (That includes materials, methods, etc.)
6 Part 2 Example: Not enough information
7 Part 2 Example: Clear, descriptive photos General view
8 Part 2 Example: Clear, descriptive photos Detail view
9 Part 2 Example: Unhelpful photos Above: architecture is obscured Right: photo is blurry and does not show architecture clearly
10 How do you apply? Tips for Part 3/C Certification of Completed Work: Part 3 is intended to show that the project is complete and follows the approved Part 2. Take photos in the same locations so we can clearly see the before and after. The Placed In Service date refers to when the project was completed. This could be but is not necessarily the date of the Certificate of Occupancy. Your tax credits will expire 5 years from this date.
11 Secretary of the Interior s Standards for Rehabilitation Standard 1: Choose an appropriate use. 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. Union Building, Fort Davis, pre-rehabilitation. Jeff Davis County Library, post-rehabilitation.
12 Standard 2: Preserve character-defining features. 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. Moore and Tyler Groceries, Tyler. Heavy timber framing left exposed in apartments.
13 Retaining Character- Defining Features Image source:
14 Image source:
15 Standard 3: Maintain true historical development. 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. One-room schoolhouse, ca After rehabilitation as a residence.
16 Standard 4: Consider later changes as potentially significant. Most properties change over time; those changes that have acquired historic significance in their own right shall be retained and preserved. Alamo Portland & Roman Cement Works, Converted to San Antonio Sunken Garden, People s National Bank Building, Tyler, Original design and later alterations by Alfred Finn.
17 Standard 5: Protect distinctive construction and craftsmanship. Distinctive features, finishes, and construction techniques or examples of craftsmanship that characterize a property shall be preserved. First City Building, Beaumont, Concrete screen wall. Socorro Mission, El Paso County, ca Hand-hewn beams, carved brackets, and adobe walls.
18 Standard 6: Repair rather than replace. 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.
19 Standard 7: Avoid destructive physical and chemical treatments. 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.
20 Standard 8: Protect significant archeological resources. Significant archeological resources affected by a project shall be protected and preserved. If such resources must be disturbed, mitigation measures shall be undertaken. Fort Davis, adobe ruins.
21 Standard 9: Make alterations and new additions compatible. 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. Rosales House, Austin. Rear addition. Arnold s Bakery (Shoehorn), East 11th St., Austin. Side addition.
22 Compatible Contemporary Design Above: contemporary, but not compatible Right: compatible AND contemporary
23 Compatible Contemporary Design Image source:
24 Standard 10: Make new additions reversible. New additions and adjacent or related new construction shall be undertaken in such manner that if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired.
25 How to avoid the top errors that can sink Tax Credit projects 1.Do not start work before consulting THC. Starting demolition, or ordering materials before approval can be an expensive mistake.
26 Any previous alterations by the current owner affect eligibility. This Texas building was ineligible for Tax Credits due to work that was done previously, before consulting THC. Brick was painted Vinyl windows and metal grilles were installed Openings were inappropriately bricked in
27 2. Do not expose structural materials or systems in a historically finished space, such as a retail space. This includes brick, stone, metal, concrete, or unfinished wood. We know it s popular, but it doesn t meet the Standards. Above: This project in Fredericksburg was unfortunately disqualified because of the exposed stonework.
28 However, a utilitarian or industrial space (such as a warehouse, barn, or factory), may be an appropriate place to have exposed structure and systems. If it was exposed when you got it, you can keep it that way.
29 3. You probably don t need to replace your windows. Window replacement is not approvable unless the window cannot be repaired. Repairing and adding storm windows are great options for continued use and efficiency.
30 4. Rooftop additions are rarely approved. There are only two cases where one might be accepted. First, if it is virtually invisible from the ground. Above: this addition completely overpowers the historic building. Right: The roof deck is still too visible, but with some edits it would likely pass.
31 Second, if there was historically a similar rooftop structure in that location. The Rogers Hotel building in Waxahachie once had a rooftop trellis. It would be appropriate to rebuild a similar structure in the same location.
32 5. Saving money does not trump historical and architectural concerns. (That s what the tax credit is for!) This project in Virginia converted a historic stable into retail, with loft apartments above.
33 The stable originally had wood flooring & wood windows. Developers used fiberglass windows and laminate floors without approval. They had to go through remediation or forfeit their credits.
34 6. Building code does not trump historic & architectural concerns. Bank building, looking in from main entrance View looking out main entrance
35 They needed an elevator for code, but the integrity of the building comes first.
36 THC and the developer worked out a less intrusive location for the elevator.
37 This electrical access panel on a Virginia property almost cost these owners their tax credit.
38 7. Local historical review is not the same as tax credit review. CLGs have different priorities than we do. THC and NPS use a whole building approach that prioritizes the interior, exterior, and all sides of the building. Just because something passes local review, doesn t mean it will pass tax credit review. This addition in an alley was approved by the local review board, however the design must be edited to qualify for tax credits.
39 The Moral of the Story: We want everyone to qualify for this opportunity! Work with us as soon as possible, and keep us in the loop throughout your project.
40 Now let s preserve Texas!
41 Resources Valerie Magolan, Tax Credit Programs Coordinator at THC Greg Smith, National Register Coordinator at THC Information about the Texas Historic Rehabilitation Tax Credit: Information about the Federal Rehabilitation Tax Credit:
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