HPCA SHPO Review & Recommendation Sheet Rehabilitation Part 2

National Park Service
U.S. Department of the Interior
Technical Preservation Services

NPS Form 10-168i (Rev. 6/2023)
OMB Control No. 1024-0009

Historic Preservation Certification
Application 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 (SHPOs). 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 across the country have been returned
to useful life in a manner that maintains their historic
character. The program supports economic development,
community revitalization, affordable housing, job creation,
sustainability, and resilience. It helps preserve the nation’s
heritage and the historic places that give our cities, town,
and rural areas their special character.

The Historic Preservation Certification Application
(HPCA) 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.

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.
The Internal Revenue Code (IRC), Treasury Regulations,
and related IRS guidance govern Federal tax matters
relating to the rehabilitation tax credit and the tax
deduction for easement donations. Links to general
information prepared by the IRS about the tax aspects
of these incentives are available from the program website
and IRS.gov. 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 for Federal income tax purposes.

AT A GLANCE
P. 2 Federal Tax Incentives for Historic Preservation
P. 2 Before Applying
P. 2 Application Process

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.

P. 4 Part 1—Evaluation of Significance

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. Applicants
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

P. 11 Part 3—Request for Certification of Completed Work

P. 4 The Secretary of the Interior’s Standards for
Evaluating Significance Within Registered
Historic Districts
P. 7 Part 2—Description of Rehabilitation
 he Secretary of the Interior’s Standards
P. 8  T
for Rehabilitation
P. 11 Amendments / Advisory Determinations

P. 12 Photographs
P. 13 Review Fees
P. 13 For More Information
P. 13 Contact Us

Historic Preservation Certification Application Instructions | Page 1

Federal Tax Incentives for
Historic Preservation
• 20% income tax credit (allocated ratably over five
years) for the “certified rehabilitation” of a “certified
historic structure.”
•

 “certified historic structure” is a building that
A
is listed individually in the National Register of
Historic Places or is 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.

• 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.

• Income, gift, or estate tax deduction for a qualified
conservation contribution (commonly called an
“historic preservation easement donation”) on a
“certified historic structure.”
• Please note: the 10% income tax credit for
rehabilitation of non-historic buildings built before
1936 was repealed by P. L. No. 115-97 (2017).
Only depreciable properties can qualify for the
rehabilitation tax credit. The property need not be
depreciable to qualify for the tax deduction for an
easement donation.

Before Applying
• Consult an accountant, tax attorney, or other tax
advisor to determine whether these incentives apply
to your own tax and financial situation.
• Make sure the project meets the “substantial
rehabilitation” test and other requirements of the IRC,
Treasury Regulations, and related IRS guidance.
• Contact the SHPO for information and technical
assistance.
• Review the program website, which includes program
regulations, application forms, Standards and
Guidelines, technical guidance, and much more.

Application Process
For the purposes of both the 20% rehabilitation income
tax credit and the easement donation, a Part 1—Evaluation
of Significance application is not required if the historic
property is a single building individually listed in the
National Register of Historic Places, as it is already a
“certified historic structure.” A Part 1 application is required
for all other properties, including individually listed
properties that include more than one building.
For the purposes of the 20% rehabilitation income tax
credit, a Part 2—Description of Rehabilitation and a Part 3—
Request for Certification of Completed Work application are
required. A Part 2 and Part 3 application are not required for
the easement donation.

Who May Apply
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 rental residential property or 39
years for nonresidential property.
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)).

How to Apply—Electronic Submission of
Applications and E-Signatures
All applications are submitted electronically through the
SHPO. Applicants must sign the application electronically
with one of the accepted types of electronic signatures
listed on the following page.
The application forms are available as fillable PDFs on the
program website. Submit the application and accompanying
materials electronically to the SHPO. See the SHPO’s website
or contact the SHPO for more information on how to electronically transmit the application to the SHPO office. See
additional information on the program website on how to
format, name, and organize electronic files for submission.

Historic Preservation Certification Application Instructions | Page 2

Accepted types of electronic signatures
(e-signatures) are:

Scanned PDFs of actual, original wet-signed application
cover sheets

Scanned or digitized versions of actual, original
handwritten signatures

Digitally signed
by Matilda J Baker
Date: 2023.06.25
13:10:41 -07’00’

Matilda J. Baker

Matilda J. Baker

Digital signatures using a digital ID (e.g., using
Adobe software), that include a digitally-signed stamp

A typed name in a different font and other types of
generated signature images are not accepted

When to Apply

Review Times

• 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.
Applicants may request actual, original handwritten
signatures on NPS decisions. Otherwise, all NPS decisions
are issued electronically using the Department of the
Interior’s authorized digital signature method.

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:
• a signed and dated cover sheet (the first page of the
Part 1, Part 2, Amendment / Advisory Determination,
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
• 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.
Incomplete applications may be placed on hold for
additional information or returned to the applicant for
resubmission. Older versions of the application form are
not accepted.
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 13).

Historic Preservation Certification Application Instructions | Page 3

Part 1—Evaluation of Significance
Applicants are strongly encouraged to submit
applications and receive approval from the
NPS prior to the start of work. Applicants who
undertake rehabilitation projects without prior
approval from the NPS do so at their own risk.
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 an
easement donation.
• does not contribute to the significance of a
historic district.
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 that district.
• of whether a building outside the period or area of
significance of a registered historic district would
contribute to the significance of the district if the
period or area of significance was expanded.
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 individually listed
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
applicant 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.
Late submissions. Applicants should not wait until after
all work is complete and the building is placed in service
before they file a Part 1 application and, where applicable,
request that the SHPO nominate the building or district
to the National Register. For information about the tax
implications of late submission of a Part 1 application, see
Topical Tax Brief—Late Submission of Historic Preservation
Certification Applications on the IRS website.

The Secretary of the Interior’s Standards
for Evaluating Significance within
Registered Historic Districts (36 CFR 67.5)
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.
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. O
 rdinarily 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.

Evaluating Part 1
Part 1 decisions for the rehabilitation tax credit are made
on the appearance and condition of the property prior
to rehabilitation. Part 1 decisions for the purposes of
easement donations are made on the “as is” appearance
and condition of the building at the time of submission of
the application.
For buildings in historic districts, the information furnished
with Part 1 applications must include a brief description
of the appearance and a brief statement of significance
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 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.

Historic Preservation Certification Application Instructions | Page 4

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). Applications must contain substantially
the same level of documentation as National Register
nominations.

Completing Part 1 Form
First page of form. This page must be the official cover
sheet, must bear an accepted form of the applicant’s
e-signature, and must be dated (see Application Process,
page 2). Other sections may be expanded as needed or
continued on blank paper.
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
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—Part
1, Multiple buildings and buildings functionally related
historically, page 6) Discuss how the building relates to
others in the district or neighborhood in terms of siting,
scale, material, construction, and date.
Provide the construction date and date(s) of alterations
that occurred after the building was constructed. Give
the source of the date. Check the appropriate box if the
building has been moved.
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).
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.
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 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.

Historic Preservation Certification Application Instructions | Page 5

Send with the Part 1 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 fee simple
owner indicating that they are aware of the application
and have no objection to the request for certification (see
Who May Apply, page 2).
Photographs and photo key. For a Part 1 for the
rehabilitation tax credit, send photographs of the property
as it appears before rehabilitation. For a Part 1 for an
easement donation, send current photographs of the
property at the time of submitting the Part 1 application.
Include photographs of the building’s site and environment,
all sides of the building, all major interior spaces and
features, and representative secondary spaces and features.
See page 12 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 functionally related historically, page 6).

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. 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
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.

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 a building
individually listed in the National Register, the procedures
in 36 CFR Part 60 must be followed before the move or the
building will be removed from the National Register, will
not be considered a certified historic structure, 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.
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 or are not owned by the applicant.
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 historic 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 historically and are under common or overlapping
beneficial interests, management, or control, NPS decisions

Historic Preservation Certification Application Instructions | Page 6

regarding the certification of the rehabilitation will be
based on the rehabilitation of the entire historic property
and not on each individual component, pursuant to 36
CFR 67.4(e) and 36 CFR 67.6(b)4. If an applicant intends to
acquire or otherwise acquires additional building(s) that
are part of the historic property after submission of the
Part 1, that information should also be submitted.
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.

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. Applicants who undertake rehabilitation
projects without prior approval from the NPS do
so at their own risk.
Evaluating Part 2
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
economic and technical feasibility. Certification of
rehabilitation is based on whether the overall project (the
“cumulative effect”) 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.

Historic Preservation Certification Application Instructions | Page 7

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. A project
is determined to meet the Standards based on the overall
effect of all work (the “cumulative effect”) on the historic
character of the building.
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. M
 ost 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. D
 eteriorated 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. C
 hemical 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.

Completing the Part 2 Form
First page of form. This page must be the official cover
sheet, must bear an accepted form of the applicant’s
e-signature, and must be dated (see Application Process,
page 2). Other sections may be expanded as needed or
continued on blank paper.
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.
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. Include the
photograph or drawing numbers that show the feature,
and the photographs or drawing numbers showing the

Historic Preservation Certification Application Instructions | Page 8

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, outline
the work to be done in each phase in the Part 2.
Fully describe the scope of the overall rehabilitation project
and 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.
Examples - Part 2 Description of Work

Number 1

Siding
ca. 1900
Feature _________________
Date of Feature__________________________

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.
1–7, 10, 18
N/A
Drawing numbers _______________________
Photo numbers __________________________
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

Windows
mid-1800s
Feature _________________
Date of Feature__________________________

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.
12, 19–23
5.2 thru 5.5
Drawing numbers _______________________
Photo numbers __________________________
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.

Send with the Part 2 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 fee simple
owner indicating that they are aware of the application
and have 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.

Photographs and photo key. Send photographs
showing the interior and the exterior before rehabilitation.
Include the building’s site and environment, all sides of
the building, all major interior spaces and features, and
representative secondary spaces and features, including
areas where no work is proposed. See page 12 for
instructions on preparing and labeling photographs for
electronic submission of applications.

Historic Preservation Certification Application Instructions | Page 9

Architectural drawings or sketches. Send architectural
drawings 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. Dimensions and notes
must be clearly legible. For small projects, sketches may
suffice. Drawings must be numbered and keyed to the
application narrative. Architectural plans and drawings
must be flattened and submitted as PDFs to reduce file
size and facilitate faster uploading and downloading. See
additional information on the program website on how to
format, name, and organize electronic files for submission.

Special Rehabilitation Concerns
Some treatments to historic properties 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.
Exterior masonry cleaning. Applicants 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.
Exterior masonry repair. Applicants are strongly
encouraged to repoint only those portions of the masonry
that require 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.
New windows. Applicants are strongly encouraged
to retain and repair historic 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. 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.
See the documentation requirements for proposed window
replacement on the program website.
Storefront alterations. Applicants 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. 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.
Interior partitions, trim, and finishes. Applicants
are strongly discouraged from changing historic floor
plans unnecessarily and from exposing masonry surfaces
unless this condition is supported by historical evidence.
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.
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.
New additions and new construction. Applicants
are strongly encouraged to obtain NPS approval before
undertaking projects involving new additions or 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.

The Secretary of the Interior’s

Historic Preservation Certification Application Instructions | Page 10

Amendments / Advisory
Determinations
Use an Amendment / Advisory Determination form to:
• 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 or submit information after Part 3
certification for proposed or completed work.
• 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 / Advisory
Determination Form
First page of form. This page must be the official cover
sheet, must bear an accepted form of the applicant’s
e-signature, and must be dated (see Application Process,
page 2). Other sections may be expanded as needed or
continued on blank paper.
To amend a previously submitted application. List
and briefly describe changes to the original application on
the cover sheet. Describe in detail on the second page or
continue on blank paper as needed.
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.
The estimated rehabilitation costs of the phase must
be reported on the form and are defined as the phase’s
estimated “Qualified Rehabilitation Expenditures,”
or “QREs,” pursuant to section 47 of the Internal
Revenue Code.
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 / Advisory
Determination 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 fee simple
owner indicating that they are aware of the application
and have 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. See page 12 for instructions on preparing
and labeling photographs for electronic submission of
certification applications. Architectural plans and drawings
must be flattened and submitted as PDFs to reduce file
size and facilitate faster uploading and downloading. See
additional information on the program website on how to
format, name, and organize electronic files for submission.
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 12 for instructions on preparing
and labeling photographs for electronic submission of
certification applications.

Part 3—Request for Certification
of Completed Work
Use the Part 3 form to request approval of an entire completed rehabilitation project. For a completed phase of a
project, use an Amendment / Advisory Determination form.
Projects involving multiple buildings that were determined
by the NPS to be functionally related historically and under
common or overlapping beneficial interests, management,
or control will be treated as one project for the purposes of
certification, pursuant to 36 CFR 67.4(e) and 36 CFR 67.6(b)4,
and certification will be issued on the overall rehabilitation,
rather than the rehabilitation of each individual building.
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.

Historic Preservation Certification Application Instructions | Page 11

Completing Part 3

Photographs

First page of form. This page must be the official cover
sheet, must bear an accepted form of the applicant’s
e-signature, and must be dated (see Application Process,
page 2). Other sections may be expanded as needed or
continued on blank paper.

Photographs must be clear and must have sufficient
resolution to show the details required for review of
rehabilitation work. Photographs must be in color and
taken at a high resolution.

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

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 fee simple
owner indicating that they are aware of the application
and have 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 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.
Late submissions. For information about the tax
implications of late- or non-submission of a Part 3
application, see Topical Tax Brief—Late Submission of
Historic Preservation Certification Applications on
the IRS website

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.
Number of photographs. Applicants must use their
judgment as to how many photographs adequately “tell
the story” of their building. Large or complex projects
require more photographs to illustrate the various
elements and areas the building and site.
Format of photographs. The property name, address,
date of photos, and application part (i.e., Part 1, Part 2,
Amendment / Advisory Determination, Part 3) must be
listed at the top of each page. The photo number (labeled
according to a photo key) and caption must be listed under
each photo. The caption must include the view shown
(e.g., north side) and a description of the view (e.g., plaster
damage in dining room, north wall).
The NPS will accept a maximum of 20 individual
photographs per submission. Only JPG and TIFF files are
accepted; no other photo file formats are accepted. Photos
must be saved into one folder.
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
LOBBY

92
96

STOCK/STORAGE ROOM
93

94

91
UP

94
LOOKING UP

22

See additional information on the program website on how
to format, name, and organize photographs for submission.

Historic Preservation Certification Application Instructions | Page 12

Review Fees

Contact Us

The NPS charges a fee for reviewing Part 2 and Part 3
applications according to the fee schedule published in
the Federal Register and 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.

National Park Service
(202) 513-7270
e-mail: [email protected]
www.nps.gov/tps
www.nps.gov/subjects/taxincentives/index.htm

The NPS sends a bill for the review fee electronically upon
receipt of the application. Fees are paid electronically
through the Federal Pay.gov website.

Internal Revenue Service
Maria Blake
(954) 991-4132
e-mail: [email protected]
Rehabilitation Tax Credit — Real Estate Tax Tips
State Historic Preservation Offices
State Historic Preservation Offices websites

Review of Part 2 and Part 3 applications by the NPS does
not start until payment has been received.

For More Information
See the program website for more information on the
historic preservation tax incentives, including:
Program regulations:
• Department of the Interior/NPS regulations, 36 CFR
Part 67
• Internal Revenue Code Section 47, Rehabilitation tax
credit
• IRS Regulations—26 CFR 1.48-12, Qualified
rehabilitated buildings
• IRS Regulations—26 CFR 1.47.7, Rehabilitation tax
credit allocated over a 5-year period
The Secretary of the Interior’s Standards for Rehabilitation
and accompanying Guidelines, including the separate
Guidelines on Sustainability and Guidelines on Flood
Adaptation
Planning Successful Rehabilitation Projects
Interpreting the Standards Bulletins
Information on the IRS aspects of the program
An online database for application status checks
Preservation by Topic index, which provides links to all the
applicable NPS guidance and information on a specific topic
Contact the SHPO for information regarding state
incentives for historic preservation.

Historic Preservation Certification Application Instructions | Page 13

HISTORIC PRESERVATION CERTIFICATION
APPLICATION INSTRUCTIONS
NOTICES
Privacy Act Statement

Paperwork Reduction Act Statement

Authority: 26 U.S. Code § 47 - Rehabilitation credit; 26 U.S. Code §
170 - Charitable, etc., contributions and gifts.

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 preservation 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.

Purpose: To enable the Secretary of the Interior to evaluate the
historic significance of structures and whether the rehabilitation of
such structures preserves their historic character. The primary use
of this information by the Secretary of the Interior will be to certify
to the Secretary of the Treasury that the applicant is eligible for Federal tax incentives for historic preservation. This application is used
by the Internal Revenue Service to confirm that applicants for the
tax incentives have obtained the certification concerning historic
structures and historic rehabilitations that are required by law.
Routine uses: The information will be used by the National Park
Service and the State Historic Preservation Offices and disclosed to
the Internal Revenue Service to determine if the applicant is eligible
for Federal tax incentives.
Disclosure: Voluntary, however, failure to provide the requested information may prevent or impede you from receiving consideration
for the requested benefit.
Information Regarding Disclosure of Your Social Security Number
Under Public Law 93-579 Section 7(b): Your Social Security Number
(SSN) is needed to identify records unique to you. Applicants are
required to provide their social security or taxpayer identification
number for activities subject to collection of fees and charges by the
National Park Service. Failure to disclose your SSN may prevent or
delay the processing of your application. The authority for soliciting
your SSN is 31 U.S.C. 7701. The information gathered through the
use of the SSN will be used only as necessary for processing this
application and collecting and reporting any delinquent financial
obligations. Use of the SSN will be carried out in accordance with
established regulations and published notices of system of records.

Estimated Burden Statements
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 15 hours per response for Part
1; 58 hours per response for Part 2; 7 hours per response for an
Amendment / Advisory Determination request; and 14 hours per
response for Part 3. Direct comments regarding these burden
estimates, or any aspects of this form, to the Information Collection
Clearance Officer, National Park Service, 13461 Sunrise Valley Drive,
Mail Stop 244, Reston, VA 20192. Please do not send your form to
this address.

Records Retention Statement
Permanent. Transfer all permanent records to NARA 15 years after
closure. (NPS Records Schedule, Resource Management and Lands
(Item 1.A.2) (N1-79-08-1))

National Park Service
U.S. Department of the Interior

Technical Preservation Services
(202) 513-7270
[email protected]
www.nps.gov/tps
www.nps.gov/taxincentives

Historic Preservation Certification Application Instructions | Page 14