Form 10-2061 National Park Service Cumulative Baseline Questionnaire

NPS Form 10-2061 (Rev. 11/2020)
National Park Service

OMB Control Number 1024-0038
Expiration Date: xx/xx/xxxx

USE THIS FORM: 1) IF YOU HAVE NOT PREVIOUSLY COMPLETED A BASELINE FORM, 2) IF
YOUR PRIOR BASELINE FORM NEEDS CORRECTIONS, OR 3) IF YOU DID NOT SUBMIT AN
ANNUAL FORM FOR EACH OF THE YEARS SUBSEQUENT TO YOUR MOST RECENTLY
SUBMITTED CUMULATIVE BASELINE QUESTIONNAIRE.

National Park Service
Heritage Preservation Assistance
Programs State, Local, and Tribal
Plans and Grants Division

National Park Service Multi-Year Cumulative Baseline Questionnaire for
CLGs

LOCAL GOVERNMENT NAME:
PERSON WHO CAN ANSWER QUESTIONS
ABOUT RESPONSES To THIS FORM:

BASELINE FEDERAL FISCAL YEAR:

20

STATE:

TELEPHONE:
E-MAIL:

Please read Guidance for Completing the National Park Service Cumulative Baseline Questionnaire for
CLGs. This guidance defines terms, explains what to count, answers frequently-asked questions, etc., a) the
definition of "cumulative" for each question below and b), the "Baseline Federal Fiscal Year" usually is the year
before the most recently completed Federal Fiscal Year.

1. CLG Inventory Program
What is the net multi-year cumulative number (or your best estimate of the number) of historic properties in
your CLG inventory as of September 30th of the Baseline Year?

2. Local Landmarks and/or Historic Districts (a.k.a. Local Register) Program
a. During the Baseline Year, did your local government have the legal authority to
create/amend local landmarks/local historic districts (or a similar list of designations
created by local law)?
Yes
No
b. If the answer to question 2a is "No," please leave question 2b's blank empty and
proceed to question 3a. If the answer is "Yes," what is the net multi-year cumulative
number (or your best estimate of the number) of historic properties (i.e., contributing
properties) in local historic districts/landmarks as of September 30th of the
Baseline Year?

3.

Local Tax Incentives Program
a. During the Baseline Year, did your local community have a tax incentives program/process
under local law that could be used to benefit (directly or indirectly)
historic properties?
Yes
No

LOCAL GOVERNMENT NAME:

STATE:

(Cumulative Baseline Questionnaire -- Continued from the previous page)
b. If the answer to question 3a is "No," please leave question 3b's blank empty and
proceed to question 4a. If the answer is "Yes," what is the multi-year cumulative
number (or your best estimate of the number) of historic properties that the local
government assisted through those incentives as of September 30th of the
Baseline Year?

4.

5.

6.

Local "Bricks and Mortar" Grants/Loans Program
a.

During the Baseline Year, did your community have a local government-funded grants/loans program
that could be used for rehabilitating/restoring/preserving historic properties? Yes
No

b.

If the answer to question 4a is "No," please leave question 4b's blank empty and proceed to question 5a.
If the answer is "Yes," what is the multi-year cumulative number (or your best estimate of the number)
of historic properties assisted by these Grants/loans as of September 30th of the Baseline Year?

Local Design Review/Regulatory Compliance Program
a.

During the Baseline Year, did your local government have a historic preservation regulatory law(s) (e.g.,
an ordinance requiring Commission/staff review of 1) local government activities and/or 2) changes to or
impacts on properties within a local historic district)?
Yes
No

b.

If the answer to question 5a is "No," please leave question 5b's blank empty and proceed to question 6a.
If the answer is "Yes," what is the multi-year cumulative number (or your best estimate of the number)
•of historic properties that your local government has reviewed under that process as of September 30th
of the Baseline Year?

Local Property Acquisition Program
a.
b.
c.

During the Baseline Year, aside from eminent domain, did your local government have a program that
could be used to acquire (and/or help others to acquire) historic properties in whole or in part through
purchase, donation, or other means?
Yes
No
If the answer to question 6a is "No," please leave question 6b's blank empty. You have finished the
questionnaire. If the answer is "Yes," what is the multi-year cumulative number (or your best estimate of
the number) of historic properties that your local government acquired and/or helped other to acquire as
of September 30th of the Baseline Year?

Notes/Comments:

Thank you for filling out this form. Please send it, no later than January XX, 20XX, to:
Historic Preservation Grants Division Attention: John Renaud
Heritage Preservation Assistance Programs
National Park Service
1201 Eye Street NW (Organization Code 2256)
Washington, DC 20005
Alternatively, feel free to send the report to John Renaud by fax at 202-371-1794 or by e-mail at [email protected]. If you want
an electronic (Word) version of this format and accompanying guidance, please contact John by e-mail. If you have any questions,
please contact John by telephone at 202-354-2066, by fax, or by e-mail.
Because of its long-term uses, it will never be too late to provide this report’s information.

NOTICES
PRIVACY ACT STATEMENT
Authority: 54 U.S.C. 300101 et. seq., the National Historic Preservation Act and 36 CFR 61, Procedures for State,
Local, and Tribal Government Historic Preservation Programs.
Purpose: The National Park Service collects this information as part of the process for reviewing the procedures and
programs of State, Local, and Tribal governments participating in the National Historic Preservation Program and the
Historic Preservation Fund grant program.
Routine Uses: The information collected will be used to evaluate programs and procedures for consistency with the
National Historic Preservation Act, as amended, (54 U.S.C. 300101 et. seq.) and compliance with government-wide
grant requirements.
Disclosure: Your response is required to obtain or retain a benefit under these programs. Failure to provide the
information requested may impede the processing of your form.
PAPERWORK REDUCTION ACT STATEMENT
We are collecting this information subject to the Paperwork Reduction Act (44 U.S.C. 3501) to provide Historic
Preservation Program managers the information needed to administer program participation and grant management. All
applicable parts of the form must be completed in order for your request to be considered. You are not required to
respond to this or any other Federal agency-sponsored information collection unless it displays a currently valid OMB
control number. OMB has approved this collection of information and assigned Control No. 1024-0038.
ESTIMATED BURDEN STATEMENT
The public reporting burden for the collection of this information is estimated to average 6 hours per response, including
the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and
completing and reviewing the collection of information. Send comments regarding this burden estimate or any other
aspect of this collection of information, including suggestions for reducing the burden, to the Information Collection
Clearance Officer, National Park Service, 112201 Sunrise Valley Drive, Reston, Virginia 20192; or by email to
[email protected]. Do not send your completed form to this address.

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NPS Form 10-2061 (Rev. 11/2020)
National Park Service

National Park Service
Heritage Preservation Assistance Programs
State, Local, and Tribal Plans & Grants Division

OMB Control Number 1024-0038
Expiration Date: xx/xx/xxxx

GUIDANCE FOR COMPLETING
THE NATIONAL PARK SERVICE
CUMULATIVE BASELINE QUESTIONNAIRE
FOR CERTIFIED LOCAL GOVERNMENTS (CLGs)
1.

What is the purpose of this questionnaire?
The data that you provide contribute to establishing and maintaining a multi-year cumulative baseline on
those achievements of the national historic preservation partnership that CLGs accomplish. The data that we
request all relate to key program elements for every CLG; i.e., the designation and protection of historic and
prehistoric properties. Except for the CLG inventory (which is a Federal requirement), this questionnaire
focuses on CLG accomplishments under local laws and programs. We have information from other sources
concerning CLG contributions to historic preservation under Federal and State law and programs. The
responses to this questionnaire provide critical information and documentation for the Administration's and
the Congress' budgetary decision-making process. For your use and perusal, we will post on the web the
results from the questionnaire and the annual report (http://www.nps.gov/history/clg -- click on the "Find a
CLG (CLG Database)" button on the right hand column). For data entered on-line, the posting should be
almost instantaneous once the system is fully updated for the current year. In this way, we can share
information about your program and achievements with your colleagues and with the public. We also expect
that this information will be useful to you and to your colleagues in your State Historic Preservation Office.
This information can be helpful in explaining to your local and State government decision-makers what your
program has accomplished for historic preservation over the years. We are seeking this information because
it is not available anywhere else on a national basis.

2.

Will I have to fill out the Cumulative Baseline Questionnaire every year?
No. Once you have provided us with the cumulative baseline figures, we will update the cumulative figures
based on the information on each year's annual report that you send us. After you complete the baseline
questionnaire, you only will need to revise it 1) if you discover an error in a previous questionnaire/report, 2)
if (subsequent to your last completed Cumulative Baseline Questionnaire) you miss an annual report, or 3) if
changes in your historic preservation program authorities mean that an answer needs revision.

3.

In the categories that you ask about (even over multiple years). we have done nothing (or very
little). Do you want us to send you a response to the Baseline Questionnaire with such low
numbers?
Yes. Your response to the multi-year cumulative Baseline Questionnaire is valuable to us no matter how little
you have to report. The multi-year cumulative Baseline Questionnaire only asks six questions seeking
numbers. Many CLGs respond to the questions by answering "0" or "l " because 1) one of their programs is
just getting staffed, 2) they had other historic preservation priorities over the years, 3) the level of public
demand was low for the program, or 4) because of a myriad of other reasons. We make no judgements of the
quality of your historic preservation program based upon the numbers that you supply in your multi-year
cumulative Baseline Questionnaire. Don't worry about not having much to report for a given category. We
think that it is a big deal for any local government to commit in writing to historic preservation by

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enforcing appropriate laws for the designation and protection of historic and prehistoric properties. We
recognize that the categories that we ask about do not cover all of the CLG's activities.
Finally, it is useful to know which kinds of historic preservation programs your community has the legal
authority to carry out. This helps NPS to describe the national CLG program as a whole

4.

We only just became a CIG. Do you still want us to send you a Baseline Questionnaire?
If your local government only recently became a CLG, and thus was not a CLG during the reporting period for
the Baseline Questionnaire, you have options.
Let's take as an example a local government that became a CLG during FY 2014. You may wait a year to
submit the FY 2014 Baseline Questionnaire during its normal schedule, you may submit a partial FY 2013
Baseline Questionnaire, or you may submit a FY 2014 Baseline Questionnaire ahead of schedule. Except for
questions 1, 2, and 6, the multi-year cumulative Baseline Questionnaire asks for data on activities that
occurred subsequent to a local government becoming a CLG (see the definition of "Cumulative" in guidance
question 10 below). Thus, for most of the Baseline Questionnaire, there is nothing to report until a full year
after the local government becomes a CLG (i.e., FY 2014 in our example). If despite this situation, you wish
to submit a partial questionnaire (for FY 2013 in our example), please feel free to do so, but please
understand that we will ask for a complete Baseline Questionnaire for the following year. If you choose to
submit a complete Baseline Questionnaire ahead of schedule (i.e., for FY 2014 in our example), please
change the "Baseline Year" dates on the form or otherwise make clear what you are doing. Otherwise, we
might inappropriately include your (FY 2014) cumulative data with the Baseline Questionnaires for the
wrong year (e.g., FY 2013).

5.

In each year's set of two forms, why is the Baseline Questionnaire designed for the year prior
to the year that the Annual Report covers (e.g., the FY 2014 Annual Report form was issued
with the FY 2013 Baseline Questionnaire)?
By issuing the Annual Report and the Baseline Questionnaire for successive years, NPS has ensured that no
State or CLG is required to report the same information twice; i.e., as a part of multi-year cumulative totals in
the Baseline Questionnaire and by itself in the Annual Report. To obtain multi-year cumulative figures as of
the current year, all that an individual has to do is add the numbers from the most recently completed Baseline
Questionnaire to the figures from each of the successive Annual Reports.

6.

Who can use the on-line data entry option for submitting this report?
Right now, other than National Park Service staff, only each State's CLG Program Coordinator has the option
of using the on-line data entry option for this reporting. We will reexamine this policy within the next few
years. There is a data security issue at play. With NPS' limited staffing available for this purpose, it is a lot
easier to assign and administer passwords for 50 State CLG Coordinators than it would be to handle
passwords for more than 1,900 CLGs. As the technology gets better and we gain more experience with the
use of the system, we will reexamine the issue of on-line data entry. Any State CLG Coordinator or official
CLG contact can use the Google forms option because that information does not go automatically into our
secure database.

7.

The on-line form has a different appearance than the hard-copy form which looks different
than the Google Forms version. Why is that?
The differences are due to creating an on-line data entry option and how that system works. A hard copy or email version of the form needs instructions on where to send the completed form; guidance that is clearly not
needed for the on-line version or the Google forms version. The fringe benefit of these revisions is that a
CLG no longer needs to send in a new Cumulative Baseline Questionnaire merely to report a change in its

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local government historic preservation-related program area offerings. To preserve the ability to add a
narrative note, on all versions of the form we have included a notes/comments box.
For similar structural reasons, the Google forms version looks different than the other versions.

8.

Do we have to use the form that NPS has provided?
For the on-line version and the Google forms version of the form, the answer is "Yes." For the hard copy,
downloaded, or e-mailed version of the form, the answer is "No." We care more about the content of the data
that you provide than we care about the format in which you provide it or the medium by which you transmit
it to us. As long as NPS can clearly tell which data relate to which question on the form and you provide
information corresponding to every blank on the form, we are satisfied. E-mail messages, spread sheets, State
report pages, etc., are all acceptable.
If you choose to report to NPS using a different format, please be explicit about which parts of your format
(e.g., in your State-required report) match with each of the NPS form's questions. Also, please ensure that the
guidance for completing the alternative form is consistent with the guidance in this document.

9.

What definitions or special instructions do I need to know to properly complete this
questionnaire?
"Baseline Year" as used in this document means the last year inclusive of the multiple years contributing to
the cumulative information reported in the Baseline Questionnaire. For example, the FY 2013 Baseline
Questionnaire seeks multi-year cumulative information through (or as of) September 30, 2014. "Baseline
Year" usually refers to the fiscal year immediately before to the most recently completed fiscal year. For
example, in March 2015, the Baseline Year normally would be Federal FY 2013 because FY 2013 was the
year before the most recently completed fiscal year (FY 2014) which ended on September 30, 2014.
"Baseline Year" can also refer to any year for which the respondent chooses to provide multi-year cumulative
data to NPS. This usually happens when there are missing Annual Reports or errors have been discovered in
prior Baseline Questionnaires or Annual Reports.
"Cumulative" means, depending upon the question either a) since your local government historic preservation
program began or b) since the community became a CLG. For the CLG inventory question (question 1), the
local landmarks/historic districts question (question 2b), and the acquisition question (question 6b),
"cumulative" includes the time before your local government became a CLG. For the CLG inventory question
and the local landmarks/historic districts question, this also means the net multi-year cumulative number of
properties in the category as of September 30 of the baseline year. For example, the local landmarks/historic
districts figure would be the sum of all contributing properties ever added to your community's list of
landmarks/historic districts minus the sum of all properties ever removed from the list of landmarks/historic
districts because of demolition, etc. The multi-year cumulative baseline is a snapshot of what is in your CLG
inventory and your community's list of local landmarks/historic districts as of September 30. Properties
formerly but not currently on the CLG inventory or your list of local landmarks/historic districts are useful to
know about for historical reasons but not as a historic preservation baseline.
For the local tax incentives question (question 3b), the local grants/loans program question (question 4b), and
the local design review/regulatory compliance question (question 5b), include only those properties protected
since your government became a CLG.
This baseline questionnaire and the accompanying annual report aim to gather data on CLG
accomplishments. Prior successes, though important for historic preservation, are not a part of CLG
accomplishments or workload.

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"Designation" as used in this document means that the local government has officially identified the
property as historic. Most CLGs have two levels of designation. That is, one level of designation is an
evaluation of significance that carries no consequences. CLGs often refer to this as "the inventory" or "the
survey." The other level of designation carries consequences such as eligibility for benefits or some level of
protection/restriction such as being subject to design review for proposed changes. CLGs often refer to this
second level of designation as 'the local register," "the landmarks list”, “local historic districts," etc.
The "Federal Fiscal Year" extends from October 1 st of one year through September 30ül of the following year.
For example, FY 2021 lasted from October 1, 2020, through September 30, 2021.
"Historic Property" means a property that, regardless of government action (i.e., whether it is listed or not),
meets the eligibility criteria l) for creating a local landmark and/or local historic district (a.k.a., "Local
Register") or 2) for listing in the National Register of Historic Places. A historic property can include
archeological as well as above-ground resources. Other properties are outside the purview of this
questionnaire. In some communities, this term is equivalent to "historic resource," "historic landmark," or
some other similar term.
Notes, Paradoxes, and Anomalies. If you wish to, please feel free to use the "Notes/Comments" section to
explain your answers, paradoxes, or anomalies. For example, it would be very unusual for a CLG to have a
design review program or a local tax incentives program or a "bricks and mortar" local grants/loans program
without also having the legal authority to create/amend a local landmark/local historic district. In most
communities, a local designation is a prerequisite for a historic property to be eligible for/subject to the other
local programs.
Similarly, it would be very unusual for a CLG's accomplishments to produce identical, large numbers as the
answer for multiple questions. Finally, if a very large number is the answer to a question, it would be a good
idea to explain the accomplishment in the "Notes/Comments" section. Thus, NPS will feel confident that the
large number is not a typo and, more importantly, such information might merit explicit mention in a
State/NPS narrative report. Also, feel free to use the "Notes/Comments" section to identify noteworthy
accomplishments even if they are not large.
From a multi-year cumulative baseline perspective, it is impossible to have more historic properties locally
registered than are present on the CLG inventory. There are other relationships between questions.
There are other relationships between questions. For example, reporting a zero ("0") for the CLG inventory and
a number larger than zero ("0") for any of the "protection" questions generally would not make sense.
Number Blanks — Numbers Only. For the "how many properties" questions, do not use a check, an "X", or
words such as "same as last year, several," or "unknown." If your local government offered the program during
the reporting period, please insert "0" if the subject matter applies, but there was no activity during the last
completed Federal fiscal year. If you are not sure what the correct answer is, please make your best estimate.
If, since your local government's certification, it once offered a program but no longer does so and the
information on the cumulative number of historic properties protected by that program is readily available,
then, 1) answer "No" to the "do you offer the program" question (e.g., question 3a), 2) provide a number in
the "how many properties protected" question blank (e.g., question 3b), and 3) enter a note in the
"Notes/Comments" box explaining the situation (e.g., "the Tax Abatement ordinance sunset in 2006").
Number Blanks — When to Complete/Relationship to "Yes" and "No" Boxes. Sometimes in the
Cumulative Baseline Questionnaire, a "No" answer means that the CLG has never offered (since
certification) the local historic preservation program type in question. In this kind of situation, for questions
2b, 3b, 4b, 5b, and 6b, if the subject matter does not apply to your local government's historic preservation
programs/legal authorities/processes (i.e., you answered "No" to the "did you have the program" question),
leave the related "historic properties" question's blank empty. For example, you should leave the blank empty
for question 3b if your government did not have a local government tax incentives program that could benefit

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historic properties and thus you answered "No" to question 3a. Generally, for every local program question to
which you entered a "No" in question 2a, 3a, 4a, 5a, or 6a, we would expect to see an empty blank in
question 2b, 3b, 4b, 5b, or 6b. Conversely, if you entered a “Yes" for any "did you have a program" question,
we would expect to see a number in the corresponding "how many properties" question.
"Program" means the legal authorization/authority (created by legislation or by administrative action) to
conduct a series of activities. As long as the authorization/authority exists, the program exists regardless of
whether or not the authorization/authority has been exercised during the baseline year. A good example in
many communities is the authority to create/amend historic districts. Often, the legal authority to
create/amend local historic districts exists but has not been used in a number of years.
"Protection" as used in this document means that because of government action, a historic property retains
those elements that make the property historic.
"Yes" and "No" Boxes. For questions 2a, 3a, 4a, 5a, and 6a, please mark or circle the "Yes" or "No" box as
appropriate. If the program existed at any time during the reporting period, please answer "Yes," even if the
program no longer existed by September 30th. If you are not sure what to answer, please consult your State
CLG Coordinator.

10. We don't use the same terminology that appears on the form and in this guidance. Do we have
to change how we refer to things?
That decision is between you and your State Historic Preservation Office. A national report needs to use
national terms that follow Federal statutes and policy. For your own purposes, you should use terms that
make sense to you. All we ask is that you know how your terms relate to the national terms because we won't
understand the relationship. Therefore, for this questionnaire please make the conversion from your
terminology to the national terminology.

11. The fiscal year in my State and community does not match the Federal Fiscal Year. What
should I do in preparing this questionnaire?
Our first preference is that you convert your fiscal year's results to the Federal fiscal year. This is because we
are preparing information for Federal decision makers about accomplishments that coincide with the Federal
fiscal year. In the Baseline Questionnaire context because we are dealing with multi-year cumulative figures,
converting from your fiscal year to the Federal fiscal year probably means just adding three months of data to
the multi-year cumulative results as of the end of your last completed fiscal year. For example, if your Fiscal
Year FY 2013 ended on June 30, 2014, and you are reporting on a program that has been in existence for five
years, your data for the Federal FY 2013 Baseline Questionnaire would be the annual totals for your fiscal years
FY 2009, FY 2010, FY 2011, FY 2012, and FY 2013 plus the first three months of your FY 2014.
If our first preference is not readily achievable for you, please pro-rate/estimate your fiscal year's results for
conversion to the Federal fiscal year. An estimate of what was accomplished over the years adjusted to the
Federal fiscal year structure is better than no response at all.
If neither our first not our second preferences are readily achievable for you, provide the results in accordance
with your fiscal year. We would rather have data that is partially from the wrong fiscal year than have no
response at all.

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12. How do I report on historic properties whose protection is not carried out or monitored bv my
office/the Commission"
You don't have to. For the purposes of this inquiry, report only on those historic properties whose designation
or protection has involved your local government's historic preservation office/commission in some way;
e.g., through review, approval, project administration, covenant or easement oversight, etc. or for which your
office has the data.

13. We don't have anything called a "local inventory" or a "local register," but we do have other
lists and overlay zones that identify historic properties. Should I count those? Should I include
local government-owned properties?
Yes, as long as you can count the number of historic properties that those list or overlays include. Don't worry
about the titles given to the information that you have about historic properties. Use the guidance in the answer
to question 15 (below), to help you determine where in the report to include the number of historic properties.
In some cases, you should report the number in both the blanks for question 1 and question 2b and in some
cases just in the blank for question 1 about CLG inventories.
With regard to local government-owned properties, you should count them in the answer to question 2b only
if they are subject to local government historic preservation laws/policies. For the purposes of this
questionnaire, ownership of the property does not matter.

14. Is there a relationship between the local landmarks/local historic districts questions and the
other questions in this questionnaire?
Yes. If your CLG has a design review program, a local tax incentives program, and/or a local "bricks and
mortar" grants/loans program, it most likely also has the legal authority to create/modify local historic
districts/landmarks, even if no local designation has taken place for a while. This relationship is due to the
fact that most communities have a mechanism through which historic properties are made eligible for local
benefits and/or made subject to local restrictions.
In most situations, you can think of historic properties that are on your list of local landmarks/historic
districts as a subset of the historic properties that are included in your CLG inventory. Because of the
consequences under local law that often attend being added to a list of local landmarks/historic districts, in
the multi-year, cumulative baseline context, a CLG will always have at least as many historic properties in its
CLG inventory than it has on its list of local landmarks/historic districts. The annual additions to each will
vary.

15.

What is the difference between a "CLG inventory" and a list of local landmarks/historic
districts (a.k.a. "local register")?
As a CLG, under Federal law, you already have a CLG inventory, but you might not have locally created
local landmarks/historic districts which we will refer to collectively as a "local register." You have a "local
register" only if your State's CLG procedures require it and/or your local government has created a
registration/designation process under local law. Your community may have given your local register some
other name that means a list of locally registered historic properties. Another way of putting it is that your
"local register" is the sum of all contributing properties in all of your local landmarks and in all of your local
historic districts. In most situations, you can think of historic properties that are listed on your local register
as a subset of the historic properties that are included in your CLG inventory.
A CLG inventory encompasses everything that you know about the historic resources within the jurisdiction
of the local government regardless of how you got the information. It doesn't matter, for example, if the
inventory information was gathered as a part of a State or federally funded survey. For question I on the

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form, we are interested in the number of CLG inventory properties that are historic properties. Under Federal
law, there are no legal consequences when you add property to your CLG inventory. Your local register (or
whatever name you give it), on the other hand, usually has consequences under local law. In fact, if your
State's CLG procedures require a local registration/designation ordinance, there must be local consequences
under local law for properties newly added to the local register. Usually, when a historic property is added to
a local register, the property becomes subject to some kind of review process and/or becomes eligible for
some kind of local benefits. In other words, every historic property that is on the local register is also on the
CLG inventory, but not every historic property on the CLG inventory is on the local register.
If your local government has the legal authority to create/amend local landmarks/local historic districts, answer
"Yes" to question 2a even if that authority wasn't exercised during the baseline year.

16.

How should I count local historic districts?
Do not count a district as a single property. Count the total number of buildings, structures, sites, or objects
that contribute to the significance of the district. If you do not know the number of contributing properties,
please provide your best estimate of the number. NPS takes this position because historic preservation
decisions tend to affect individual properties within a district rather than the district as a whole.

17.

From time to time, due to demolition (or o(her reasons), we have had to remove some
properties from our CLG inventory and/or our list of local landmarks/historic districts (a.k.a.
"local register"). Do you want us to adjust our cumulative figures for the CLG inventory and
local register to reflect those losses?
Yes, if you have that information readily available. The multi-year cumulative baseline is a snapshot of what
is in your CLG inventory and local register as of September 30. Properties formerly but not currently on the
CLG inventory or your local register are useful to know about for historical reasons but not as a historic
preservation baseline. In such a situation, it would also be helpful to provide updated multi-year cumulative
baseline figures in the following year. For example, the impact of properties demolished during FY 2020
would be reflected in adjusted multi-year cumulative baseline figures in the FY 2020 cumulative Baseline
Questionnaire.

18.

For some of our local programs, the main purpose is not historic preservation. but the
programs protect historic properties as an incidental consequence. Housing programs are a
good example. Should I count those?
Yes. As long as historic properties are protected and your office is involved or has the data, count those
programs and the properties that they protect.

19.

Some historic properties are protected more than once (e.g., tax benefits achieved and permits
reviewed). Should I count a property only once or each time that it is reviewed. receives a
grant, etc.?
Count a property each time that it is reviewed, receives a grant, etc. This approach gives you credit for all the
protection that you give to a historic property, not just the initial instance. Note that for this reporting you do
not have to know or provide a list of what happened to each historic property. What you need to know for this
questionnaire are total multi-year cumulative figures for each category; (i.e., the total multi-year cumulative
number of properties designated, receiving tax benefits, etc.).

20.

8
There are some State laws that require local government legislative action (e.g., passing an
ordinance) for the law to go into effect. This sometimes occurs with regard to Tax Incentives
and sometimes with regard other programs. Would this situation count as a local program for
the purposes of this questionnaire?
It depends. See the analysis below.
The Situation. There is a State law that provides direct and/or indirect protection to historic properties. The
State law a) rewards historic property owners for the historic significance of their properties, b) helps them to
correct problems threatening the properties' significance, and/or c) requires the owners to maintain the
properties for a specified period of time. The State law requires some degree of local government
participation to implement the State legal authority. The State law might also require/authorize some level of
participation by the State Historic Preservation Office (SHPO) to implement the law.
The Question. The National Park Service (NPS) asks States to report on accomplishments under State law and
asks Certified Local Governments (CLGs) (either directly or through the SHPO) to report on
accomplishments under local law. Should a State law/program that requires local action for the protection of
historic properties be reported in the State Report, the CLG Report, or both?
Purposes and Principles. Some of the purposes for and principles behind the State and CLG reports will help
answer the question.
a. Both the State and the CLG reports are designed to help measure the success of the national historic
preservation partnership. As official partners, both States and CLGs carry out historic preservation activities
that are not paid for by Historic Preservation Fund (HPF) and matching funds. We want to give full credit
to the historic preservation work that our partners do and avoid (where possible) the underreporting of
accomplishments.
b. The partnership work carried out outside of the HPF grant program is not reported on a national basis
anywhere else. Therefore, the answer to the question must be one that does not lose the ability to get credit
for the protection made possible by such a hybrid State law.
c. NPS asks only for information that is (or should be) readily available. No record-keeping should be done
solely for the purposes of these two NPS reports.
d. Although the unit of measure for both the State and the CLG reports is the number of historic properties,
what we are really counting is the number of times a historic property is protected. For example, if during
the reporting period a historic property both is awarded a Certificate of Appropriateness and a local tax
incentive, that situation counts as "two" (one in the Design Review category and one in the local tax
incentives category). Thus, if the answer to the question is to count the properties protected in both the State
and CLG reports, that would not be double counting.
e. Often in historic preservation, there is not a clear division of responsibility for the result of an owner of a
historic property receiving a local benefit/protection under a State authorization/mandate. For example, to
obtain a local protection, a sign-off on eligibility could be required from both the SHPO and the CLG
Commission.
f.

Nationwide (and sometime within a single State) there can be a great deal of variability in the role of the
State and the local historic preservation offices in the implementation of such a State hybrid law. It would
be overly cumbersome and nearly impossible for NPS to try to describe and provide an answer to every
possible fact pattern. Consequently, it makes sense to provide the range of possible answers and the criteria
that should be applied in arriving at the appropriate answer for the particular situation.

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The Answer. In the case of a hybrid law -- that is, a State law requiring some measure of local government
participation to confer a historic preservation benefit -- depending upon the situation, it could be appropriate to
report the resultant number of historic properties protected just in the CLG Report, just in the State Report, or
in both reports. Apply the criteria below to help determine the appropriate response in a given situation.
The Criteria.
1) Whose tax coffers are affected? For example, in a tax incentive situation, if the owner of a historic property
receives only a local tax benefit, then it could be appropriate to report the protection in the CLG report.
2) Does the local government have any options in whether or not (or how) to take advantage of the State law?
For example, if local government participation is mandatory and thus is acting solely as an agent of the
State government, it could be reasonable to treat the program as a State program.
3) Which level of government is best able to keep track of the number of historic properties that take
advantage of the property tax incentive? If only the SHPO or only the CLG has easy access to the
information, that is where the program should be reported. One of the principles behind the NPS reports
is that we are asking only for information that is (or should be) readily available. No record-keeping should
be done solely for the purposes of these two NPS reports. The flip side of this criterion is that SHPO and/or
CLG possession of the data is a good rationale to include the data in the State and/or CLG Report. We
don't want to miss out on the data altogether.
4)

Which level of government has to review the application to determine the property's eligibility to take
advantage of the historic preservation benefit? A reasonable argument could be made that whichever level
of government's historic preservation office makes the final decision regarding a historic property's
eligibility for the benefit should get credit for the protection. On the other hand, if both the State and CLG
historic preservation bodies are involved in the process, an equally good argument could be made that the
final protection/benefit would not take place without the participation of both the State and the CLG and
therefore the number of historic properties protected should be reported in both the State and the CLG
reports.

5) Other criteria? Depending upon the particular situation, there may be other criteria that would aid in the
decision of whether to report the number of historic properties protected in the State Report, the CLG
Report, or both.
6) How does your State CLG Program Coordinator recommend solving this issue? Please check with her/him.
Within every State, similar program questions should be resolved in a parallel fashion.

21.

Our historic preservation financial assistance programs (grants. loans. etc.) are not funded
every year. Should I report that we have the program. or not?
It is helpful to think of this question in terms of legal authorization for funding being separate from the actual
provision of funds.
Answer "Yes" to question 4a, if the ordinance authorizing the financial assistance was still in effect during
some portion of the Baseline Year. If the authorizing ordinance was no longer in effect, but the protective
agreements resulting from the financial assistance were still in effect after certification as a CLG, answer
"No," but include those properties in answering question 4b.
If no authorizing ordinance was involved in the financial assistance program, answer "Yes" to question 4a if
the financial assistance program was either in effect during the baseline year or any protective agreements
resulting from the program were still in effect during the Baseline Year. If no authorizing ordinance was
involved in the financial assistance program, answer "No" to question 4a but enter property numbers for
question 4b in the following circumstances. Follow this approach if the financial assistance program was not
in effect for the Baseline Year but either was in effect since certification as a CLG or any protective
agreements resulting from the program were still in effect after certification.

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Please use the "Notes/Comments" section to explain any situation that merits entering "No" for question 4a
and a number for question 4b.
For the purposes of the local historic preservation grants/loans blank, count a historic property if rehabilitation,
restoration, preservation, etc. work (a.k.a. "bricks and mortar") is involved. Report elsewhere (e.g., under
Acquisition) those properties that your local grants or loans assisted in other ways (e.g., to help a nonprofit
organization purchase a preservation easement).
22.

We administer some grants from the State and the staff of the State Historic Preservation
Office helps us with some of our locally funded programs. Similarly, in some Federal financial
assistance programs, the Federal funds are legally transformed into local government funds.
How should I treat these situations in responding to question 4 on grants and loans?
Count only historic properties protected through grants supported by funds coming from local government
sources. Do not count l) grants from Federal (or matching) funds administered by State or local agencies or
2) State government grants. For example, don't count historic properties that you protect through Historic
Preservation Fund CLG subgrants. These are counted elsewhere on State or Federal Government forms.
However, if the funds are local, count the benefiting properties in this questionnaire even if you receive
technical assistance from other sources. See question 13 above for additional guidance in related situations.
Count in this report those few Federal (or State) programs that award funds to local governments and for
which, as a matter of Federal (or State) law, those funds legally become transformed from Federal (or State)
to local funds. This is a rare situation. The best-known Federal example is the Community Development Block
Grant program.

23.

Many of the historic preservation accomplishments in our community are achieved through
the financial support of the private sector or through non-profit organizations such as the
National Main Street program. Should we include these achievements in our reporting 011 the
number of historic properties that we protect through grants or loans?
No. Although we recognize that a large percentage of current historic preservation would not take place
without the financial support of non-profit organizations and the private sector, this questionnaire is focusing
on the achievements of local government historic preservation programs. However, action by one of these
organizations does not prevent the counting of a property/protection if it simultaneously receives a local
government benefit. One example would be a simultaneous Main Street and local historic district
designation.

24.

What should I count in the "Local Design Review/Regulatory Compliance Program" blanks?
What does "review and compliance" mean?
For the purposes of the "Local Design Review/Regulatory Compliance Program" blanks, include only those
activities for which local laws have provided protection in a regulatory setting; e.g., through a review,
permitting, or certificate of appropriateness process. This type of program is often referred to as "review and
compliance." "Review and compliance" refer to the review of permits, plans, applications, etc. to help ensure
compliance with local regulatory laws related to the protection of historic properties. In many communities,
there is a review of proposed changes to locally designated landmarks and properties within locally
designated historic districts. In some communities, the CLG Commission also reviews local government
activities that might have an effect on historic properties. This is sometimes called a "local Section 106" after
the parallel provision (for Federal agency undertakings) in the National Historic Preservation Act.
Do not count (in these blanks) historic properties that local laws have protected through financial incentives
(e.g., tax laws) or financial assistance (e.g., bricks and mortar grant programs). Report that information
elsewhere in the questionnaire answers.

25.

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Sometimes we review/approve requests for demolition or make other
decisions/recommendations that do not result in the protection of properties. These reviews
are a legitimate part of our workload. Should we count these for question 5b?
No. If it is easy for you to separate out those reviews/recommendations that are likely to result in a historic
property's destruction or loss of significance, don't include them in this multi-year cumulative baseline
questionnaire. We are trying to get an estimate of the multi-year cumulative number of historic property
reviews where preservation is a likely result. If it is difficult to separate your regulatory reviews by result,
don't worry just give us the multi-year cumulative total figures.

26.

What does "Acquisition" include? What about eminent domain? Doesn't every generalpurpose unit of government have this power?
"Acquisition" refers to any legally-binding, title-related interest in the historic property that the local
government has obtained (or has helped others to obtain) thereby making the property subject to your local
historic preservation laws and policies. The interest in the property's title could be anything ranging from fee
simple absolute (i.e., complete title) to an easement (e.g., facade or preservation easements). With the
exception of eminent domain, the method of acquisition is not important here.
Do not consider eminent domain in your answer to question 6a. Because every general-purpose local
government (with few exceptions) has the power of eminent domain, to include it in answering question 6a
would obscure the presence or absence of other kinds of acquisition programs. For answering question 6b,
include in your count any historic property that has come into local government ownership (even through
eminent domain) as long as local government ownership made the historic property subject to local
government historic preservation laws/policies.

27.

Where do I report on publications, brochures. public education. site interpretation. historic
preservation plans, historic plaques and markers. and other historic preservation
accomplishments?
These are not part of the Cumulative Baseline Questionnaire. While important, for purposes of this
questionnaire we have limited the questions to products that more directly affect individual historic properties.
This reduces the burden in gathering and reporting this data. However, you may include your other
accomplishments as part of your periodic reporting to your State Historic Preservation Office (in some States
this is required) or, if you wish, report directly to us by use of the "Notes/Comments" section.

28. Why do you have separate questions on "designated" and "protected" historic properties
throughout this questionnaire? Why not just ask for the number of properties in our CLG
inventory? In that way, with one question, you could account for all historic properties that
have been designated and protected. All of our locally "listed" properties are included on our
CLG inventory. All of our properties that have been "protected" in one way or another are
also "designated" properties.
Reporting separately on "designated" historic properties and "protected" properties better represents the
historic preservation work that you do. Each time the local government designates a property. or (for
example) provides financial assistance to a property, that action adds to the protection inherent in being part
of your CLG inventory. We wish to give you full credit.
Also, this is the kind of information that citizens in your CLG and your colleagues in other CLGs or local
governments want to know. Folks living in a CLG or thinking about moving there may want to know what
kinds of historic preservation opportunities exist. Communities that are considering whether to create new

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historic preservation programs/legal authorities want to know who else has the programs so that wheels don't
have to be re-invented. We will make this information available on the Web and upon request.
29.

The questions that you ask relate primarily to CLG workload. Wouldn't it be better to ask
how many of our historic properties are still in good condition? In the final analysis.
preserving our irreplaceable resources is the true test of our success as historic
preservationists.
If funding and staffing were no object, we would want both workload information and data on the condition
of historic resources. One of the aims of this multi-year Cumulative Baseline Questionnaire is to make use of
readily available information rather than to create a new workload in gathering and tracking data. Especially
for larger CLGs, data on the condition of historic and prehistoric properties often are not readily available.
Another purpose of this questionnaire is to gauge the contribution that CLGs make to historic preservation. In
assessing a property's condition, without asking the property owner it is difficult to distinguish which parts (if
any) of a property's good condition are due to local, State, and/or Federal historic preservation program
efforts. CLG workload data on the other hand usually are readily available, readily assignable to CLG efforts,
and can be used to draw reasonable inferences about the condition of historic properties.

30.

What should I do if my office missed a report or in retrospect, we discover that we made a
mistake in an earlier report?
Because of the long-term uses for this information, it will never be too late to provide the Cumulative
Baseline Questionnaire's information. We hope that you take advantage of opportunities to update the
information that we have about your program. You have a choice as to how to accomplish this. You may
either provide/correct the earlier report or you may prepare a new multi-year cumulative baseline report for a
more recent year. For example, if your local government became a CLG during FY 2010 but your office had
not responded to any of the subsequent requests for information as of the end of FY 2014, you would have
had the following options. Your first option would have been to prepare and send us a FY 2010 cumulative
baseline response plus an annual report for FY 2011, FY 2012, FY 2013 and FY 2014. You could have used
the current year's forms by changing the dates. Your second option would have been to provide questionnaire
answers and baseline data through FY 2013 plus the annual report for FY 2014. Other combinations of
baseline questionnaires and annual reports are also possible.