Historic Tax Credits Preparation & Application


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Judith Kitchen, of the Ohio State Historic Preservation Office, presented this presentation at the Heritage Ohio Historic Tax Credit Workshop in Springfield, Ohio on May 6, 2011. Event sponsored by PNC Bank.

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  • I will provide an introduction to the Secretary of the Interior’s “Standards for Rehabilitation.” You will find a copy in your booklet. The “Standards” have been adopted across the country -- by federal agencies, state offices, local commissions, and others -- as a preservation philosophy that can guide the successful rehabilitation of historic buildings.
  • Rehabilitation is defined as returning a property to a state of utility through repair or alteration, making possible an efficient, contemporary use, while preserving features significant to the building’s history, architecture and culture.
  • The Standards are ten common sense principles that emphasize preservation of historic character, repair over replacement, and compatibility of alterations. They apply to all types of historic buildings and over interior and exterior spaces and features, including landscapes.
  • I used the term “historic character” -- it refers to all the visual aspects and physical features of a historic building including its: size, scale, materials, details, craftsmanship, spaces, structure, shape, site, and environment.
  • Standard 1 - Be sure to find a compatible use for the building. Here we have a classroom in a vacant school building -- with a contemporary use that retains and reuses its character-defining features yet allows for open office space. Standard 1 is basic preservation philosophy -- it underscores the importance of ensuring a “good fit” between the old and the new.
  • Standard 2 states that the historic character of a property should be recognized and preserved. Here, in Cincinnati’s Over the Rhine Historic District, a row building was deteriorated and neglected before re-use. Its rehabilitation carefully preserves the painted masonry, storefront and window openings, architectural detail, projecting cornice, dormers, chimneys, and mansard roof. The new work respects and preserves the building’s historic character.
  • Standard 3 warns against attempting to create an earlier or false historic appearance. On the left is the Sycamore Café in German Village, Columbus. It has survived for decades with few alterations and maintains its character as a late-19 th century commercial building. Down the street, however, a similar building has been altered. The window grids, shutters, and coach lamps are typical elements of a style that pre-dates the building. These added details create a false historic appearance and diminish the building’s character.
  • Standard 4 recognizes that buildings change over time and that some additions may be significant. For example, the early 20 th century storefront applied to this 19th century building has gained significance in its own right. The storefront demonstrates a high level of craftsmanship – note the Carrara glass, metal trim and neon sign – and is a good example of Art Deco design on a small scale commercial building, worthy of preservation.
  • Standard 5 asks that we treat distinctive stylistic features with sensitivity. Here we have before and after views of the Old Holzer Hospital in Gallipolis. The distinctive entrance portico, although deteriorated, was carefully repaired and preserved as part of the overall rehabilitation.
  • Standard 6 is a fundamental part of the Standards. It asks that we repair deteriorated historic features whenever possible, rather than replacing with new. It is important to retain as much historic fabric as possible. When too much is replaced, historic character is lost. If replacement is necessary due to the severity of deterioration, match the existing “in kind,” which means using the same materials to achieve the same appearance. These two Pennsylvania buildings used to be identical twins, until one was altered with aluminum siding, new windows, and other obvious changes. No doubt, its neighbor needs work, but repairing the wood siding, windows and trim will preserve its character and significance.
  • Standard 7 - “Thou shall not sandblast.” Here we see sandblasting taking place at a home in German Village. Permanent damage to the brick is being caused. If cleaning historic materials is necessary, always use the gentlest means possible. We’ll offer some “how-to” information later this evening.
  • Standard 8 - Protect archeological resources. What we do not see can be as important, or even more important, than what we do see. On the left is a beehive cistern that was found under several layers of later construction – a brick foundation, a brick walkway, and a concrete slab parking lot. These cisterns often yield important information about the occupants of the homes nearby as everyday articles were often discarded inside. On the right are materials from cisterns in Cincinnati’s Betts-Longworth Historic District, discovered in an archeological excavation.
  • Standard 9 – Any new additions must be compatible with the historic property. Here is an urban streetscape example. The center building is new, infill construction between two historic buildings in Cleveland’s Warehouse District. The new construction is compatible with but does not duplicate the neighboring buildings. The materials, massing, storefront and window sizes are contemporary yet compatible in their design.
  • Finally, Standard 10 says that any additions or new construction should also be reversible. They should be able to be removed and not cause harm to the original structure or significant historic fabric. Here is an example of an interior vestibule added in a manner that does not significantly alter the appearance of the historic lobby while in place nor will it cause damage to historic features if removed in the future.
  • Historic Tax Credits Preparation & Application

    1. 1. Technical Preservation Services Department Ohio Historic Preservation Office Ohio Historical Society 1982 Velma Avenue Columbus, Ohio 43211-2497 614/298-2000 2011
    2. 2. The 20% Federal Historic Rehabilitation Tax Credit: The Basics
    3. 3. Federal Historic Rehabilitation Tax Credit <ul><li>Federal Tax Credit for the Rehabilitation of Historic Buildings. </li></ul><ul><li>Income-Producing Use. </li></ul><ul><li>Substantial Rehabilitation. </li></ul><ul><li>Credit=20% of Qualified Rehabilitation Expenditures. </li></ul><ul><li>Certified Historic Structure (Application). </li></ul><ul><li>Certified Rehabilitation (Application). </li></ul>
    4. 4. Applying for the Federal Tax Credit <ul><li>Preliminary meetings with Technical Preservation Services Department staff during the project planning stage, before any rehabilitation work is undertaken, are encouraged. We are here to assist you and we want your project to be successful. Reviewers are Mariangela Pfister, Rachel Krause, Scott McIntosh and Judith Kitchen. </li></ul><ul><li>Applications are submitted to the Ohio Historic Preservation Office for review and recommendations. Following state review, applications are submitted with state recommendations to the National Park Service in Washington, D.C. for final review and approval. The Internal Revenue Service administers the process of claiming the credit. </li></ul>
    5. 5. Federal Tax Credit Application Procedures Applications are available online but must be submitted in paper form <ul><li>Part 1—Evaluation of Significance—Determines Whether the Building Is or Is Likely to Be a Certified Historic Structure (Listed on the National Register of Historic Places). </li></ul><ul><li>Part 2—Description of Rehabilitation—Determines Whether the Proposed Rehabilitation Work Will Meet the Secretary of the Interior’s Standards for Rehabilitation. </li></ul><ul><li>Part 3—Request for Certification of Completed Work—Determines Whether the Completed Project Meets the Standards for Rehabilitation. </li></ul>
    6. 6. Part 1 Submission Requirements <ul><li>Descriptions of appearance and significance </li></ul><ul><li>Labeled before-rehab (and current) photographs </li></ul><ul><ul><li>Photo number, building name and address </li></ul></ul><ul><ul><li>Brief description of view being shown </li></ul></ul><ul><ul><li>Month and year photo was taken </li></ul></ul><ul><li>Photo key </li></ul><ul><li>Historic district map with building located </li></ul><ul><li>Two copies of everything </li></ul>
    7. 7. Part 1 Tips <ul><li>Carefully check the National Register status of the property. Don’t rely on assumptions. </li></ul><ul><li>Each building (or functionally-related group of buildings), unless it is a single building listed individually on the National Register, requires a Part 1 application. </li></ul><ul><li>If your building is not yet listed on the National Register, a draft nomination form must be submitted with the Part 1 application and the normal nomination and listing process should be started. </li></ul><ul><li>Use National Register information to prepare the Part 1 narrative. </li></ul><ul><li>Submit the Part 1 application as early as possible. </li></ul><ul><li>When we receive your application (Part 1, Part 2, Part 3 or Amendment) you will be sent an acknowledgement form. Make sure you receive this form and check it for accuracy. Also read the helpful notes at the bottom. </li></ul>
    8. 8. Part 2 Submission Requirements <ul><li>Narrative that clearly and completely describes before-rehab conditions and all intended work to the exterior, interior and site (photos and drawings are subordinate to the written narrative) </li></ul><ul><li>Labeled “before” photographs of all areas of the building and site, keyed to the pre-rehab drawings </li></ul><ul><li>Drawings (pre-rehab and after rehab) </li></ul><ul><li>Other necessary information such as specifications, product data, window survey, sightline study, tenant guidelines </li></ul><ul><li>Two copies of everything </li></ul>
    9. 9. Part 2 Tips <ul><li>The Standards for Rehabilitation do not require you to take certain actions. They come into play only when you are proposing to do something physically to the building. </li></ul><ul><li>The Ohio Historic Preservation Office and National Park Service do not design projects. We may suggest solutions based on our experience, but we do so in reaction to the information we receive. </li></ul><ul><li>Provide an introductory paragraph or two to summarize the project. </li></ul><ul><li>Submit everything at once and in the same package, if possible. Our 30-day review period does not start until an application is complete. </li></ul><ul><li>Complete and submit the federal fee payment form with the Part 2 to expedite National Park Service review. </li></ul><ul><li>Submit an Amendment form for any changes to approved Part 2 work prior to doing the work. </li></ul>
    10. 10. Part 3 Submission Requirements <ul><li>Labeled “after” photographs of all areas shown in the Part 2 “before” photographs </li></ul><ul><li>Evidence that all Part 2 Conditions were met </li></ul><ul><li>Two copies of everything </li></ul>
    11. 11. Part 3 Tips <ul><li>Take the Part 3 photos from the same locations and number them the same as the Part 2 photos. That will make our review much easier. </li></ul><ul><li>Submit additional photos to show that any conditions placed on the Part 2 approval were met. </li></ul><ul><li>Submit an Amendment form with the Part 3 describing any work that was not undertaken. </li></ul>
    12. 12. The 25% Ohio Historic Preservation Tax Credit (OHPTC): The Basics
    13. 13. Ohio Historic Preservation Tax Credit <ul><li>State Tax Credit for the Rehabilitation of Historic Buildings. </li></ul><ul><li>Administered by the Ohio Department of Development, with Assistance from the Ohio Historic Preservation Office (OHPO) of the Ohio Historical Society and the Ohio Department of Taxation. </li></ul><ul><li>Credit=25% of Qualified Rehabilitation Expenditures, up to $5 million. </li></ul><ul><li>Competitively Awarded Based on Potential Economic Impact and Regional Distributive Balance (Application). </li></ul><ul><li>Historic Building Requirement (Application). Preliminary certifications are not permitted, but buildings designated by Certified Local Governments qualify. </li></ul><ul><li>Approved Rehabilitation Work (Application). For combined federal/state tax credit projects, the federal Part 2 data will automatically apply to the OHPTC project, so no separate rehabilitation description is required. Work on OHPTC projects cannot start prior to approval recommendation from OHPO. </li></ul>
    14. 14. Applying for OHPTC <ul><li>Preliminary meetings are encouraged. We are here to assist you and we want your project to be successful. </li></ul><ul><li>Applications are submitted within the established application periods or Rounds to the Ohio Department of Development, which sends a copy to the Ohio Historic Preservation Office for determinations of historic building status and whether the rehabilitation work meets the Secretary of the Interior’s Standards for Rehabilitation. </li></ul><ul><li>Program status, applications, program policies and the scoring system are available online. </li></ul>
    15. 15. The Secretary of the Interior’s Standards for Rehabilitation <ul><li>Helpful guidance for the successful rehabilitation of historic buildings </li></ul>
    16. 16. Rehabilitation: Returning a property to a state of utility through repair or alteration, making possible an efficient contemporary use, while preserving features significant to its history, architecture and culture.
    17. 17. Standards for Rehabilitation The Standards for Rehabilitation are ten common-sense principles emphasizing the preservation of historic character, repair rather than replacement and compatibility of alterations. They apply to all types of historic buildings. They pertain to exterior and interior features and spaces.
    18. 18. Historic Character Environment Size Scale Materials Craftsmanship Details Spaces Shape Site Structure
    19. 19. Standard 1 - Find a compatible use.
    20. 20. Standard 2 - Preserve historic character.
    21. 21. Standard 3 - Don’t create a false sense of history.
    22. 22. Standard 4 - Preserve additions that have gained significance.
    23. 23. Standard 5 - Preserve distinctive features.
    24. 24. Standard 6 - Repair rather than replace. Match closely if repair is not possible.
    25. 25. Standard 7 - Do not cause damage to historic building materials.
    26. 26. Standard 8 - Protect significant archeological resources.
    27. 27. Standard 9 - Ensure that additions are compatible.
    28. 28. Standard 10 - Ensure that additions are reversible.
    29. 29. Making A Good Program Better/ Planning Successful Rehabilitation Projects, the two goals of which are: Making the requirements of the federal historic tax credit program clearer and Making the interpretation of the Secretary of the Interior’s Standards for Rehabilitation more understandable. In addition to Preservation Briefs and the Guidelines for Rehabilitating Historic Buildings, the most up-to-date information on the federal historic rehabilitation tax credit program and applying the Standards for Rehabilitation is provided by
    30. 30. Ohio Historic Preservation Office Ohio Historical Society