Using the Historic Tax Credit for Affordable Housing

The webcast above, presented by Elizabeth Rosin, Principal at Rosin Preservation was recorded on May 4, 2017. The following content was developed in association with the webcast and is accompanied by links and additional tools and resources.

 


NewTax Legislation Update

Public Law 115-97, the federal tax legislation enacted on December 22, 2017, retained the 20% Historic Tax Credit (HTC), but required that the HTC be taken over 5 years. The legislation also provided transition rules. As always, anyone interested in using the HTC is advised to consult an accountant, tax attorney, or other professional tax advisor regarding how the HTC and these recent changes may affect them.

Introduction

The 20% federal HTC is a financial incentive that supports investment in historic buildings. It encourages private property owners to rehabilitate historic properties for an income-producing use, such as rental housing, office, retail, manufacturing and entertainment space. It is an important tool for the redevelopment of historic Main Streets and can be a catalyst for neighborhood and downtown revitalization. It can also be an effective tool to create affordable housing, including mixed-use developments that have commercial space on the first floor and residences on the upper floors.

 

Noble Lofts, Bartlesville, OK

Noble Lofts, Bartlesville, OK: This $2.5 million rehabilitation project transformed a long-vacant commercial building in downtown Bartlesville into eleven apartments plus ground floor retail space, adding considerable activity to Main Street outside of business hours. Photo: f-stop Photography

 

Albert Pike Apartments, Little Rock, AR

Albert Pike Apartments, Little Rock, AR: The 1929 Albert Pike Hotel was converted into Section 8 apartments in the 1980s. In 2012, the owner used HTC and LIHTC to update finishes and fixtures. The $6 million project maintained the historic lobby and dining rooms as event spaces available to the community for rental. Photo: f-stop Photography

 

Clay Hall, Enid, OK

Clay Hall, Enid, OK: Built shortly after World War II as a women’s dormitory for Phillips University, Clay Hall was vacant for 30 years before being rehabilitated as affordable senior housing that was much needed in this small central Oklahoma community. Photo: f-stop Photography

Through HUD’s Rental Assistance Demonstration (RAD) program, Public Housing Authorities can partner with private investors interested in the HTC to rehabilitate historic public housing developments. Projects receiving Low-Income Housing Tax Credits (LIHTC) may raise additional equity if they also qualify for the HTC.

The HTC rewards owners for making an investment that extends the economic life of older buildings and helps to revitalize communities, and it becomes a source of project equity when syndicated to outside investors. A project can claim HTC equal to 20% of qualified expenses. The tax credit directly reduces income taxes owed. Each dollar of tax credit offsets one dollar of taxes due. A project with $1 million of qualified expenses will generate $200,000 of HTC to offset $200,000 of federal income taxes.

 

 

Iberville, New Orleans, LA: After

Iberville, New Orleans, LA 

 

Iberville, New Orleans, LA Exterior

Iberville, New Orleans, LA Exterior: Built in the 1940s as public housing, the Iberville Projects underwent a major redevelopment by the Housing Authority of New Orleans after receiving a HUD grant in 2011. As part of the project, the historic buildings in the complex were placed on the National Register and rehabilitated using HTC. The project adapted the seventy-year-old units for modern living while maintaining the historic character-defining features. Photo: HUD

 

 

Historic tax credits benefit a wide range of building types and communities throughout the United States – urban centers, small towns, rural areas. They include high-style architect-designed masterpieces as well as simple functional buildings. HTC projects can be catalytic for community revitalization. Many communities have a “white elephant” building that may qualify for the program. Vacant school buildings, for instance, are frequently converted to affordable housing.

 

Dierks Building, Kansas City, MO

Dierks Building, Kansas City, MO: This $30 million rehabilitation converted an early 20th century office building in Kansas City’s central business district into 134 affordable apartments. The project preserved historic elements dating to multiple periods of construction, including the historically significant 1959 renovation of the storefront, lobby and banking hall. Photo: f-stop Photography

 

Cass Plaza, Detroit, MI

Cass Plaza, Detroit, MI: This project rehabilitated two early 20th century apartment buildings in the Cass Corridor of Detroit to create 39 units of low and moderate income housing. Photo: Kidorf Consulting

 

Champlain Street, Burlington, VT

Champlain Street, Burlington, VT: While some historic affordable housing projects transform large commercial or industrial buildings for residential use, many use the credits to upgrade existing workforce housing. The $900,000 rehab of this small Victorian apartment building is a great example. The project removed non-historic vinyl siding and windows, preserved distinctive historic elements, and updated interior systems and finishes. It will continue to provide affordable housing in a working class residential neighborhood.

 

 

Poehler Lofts, Lawrence, KS

Poehler Lofts, Lawrence, KS: The industrial east side of Lawrence had long languished when rehabilitation of the 1909 Poehler Warehouse began in 2011. The $8 million historic rehabilitation created 46 affordable apartments. Marketed to artists as live-work space, the development was the catalyst for subsequent revitalization efforts that included rehabilitation of historic buildings and new construction. Photo: f-stop Photography

 

Baxter Springs Building

Baxter Springs Apartments, Baxter Springs, KS: When small towns build new schools, the vacated historic buildings are often threatened with demolition. Fortunately, historic classrooms are the ideal size for apartments. The historic Baxter Springs High School is typical of the many schools built nationwide before World War II. In the process of converting the 1918 building into 28 affordable senior apartments, the $5.5 million rehabilitation uncovered historic plaster walls throughout the building and replicated a long-missing monumental cornice. Photo: f-stop Photography

 

 

While large, high-dollar rehab projects attract a lot of attention, buildings of all sizes can take advantage of the HTC.

  • Roughly 50% of all HTC projects cost less than $1 million
  • Roughly 25% of all HTC projects cost less than $250,000

Since the HTC program was established in 1976, the program has impacted communities throughout the country. The statistics for the program are impressive:

  • 42,293 projects completed 1977-2016
  • Projects in all 50 states
  • $84.15 billion of private investment
  • Over $7 billion investment in 2016 alone
  • 2.44 million jobs created
  • 153,255 low and moderate income housing units created/rehabilitated

Value of Qualified Expenses on HTC Projects 2012-2016 Pie Chart

 

 

 
Map of federal historic tax credit projects by county

 

This map prepared by the National Trust for Historic Preservation shows the distribution of HTC projects nationwide between 2002 and 2016. You can see that projects have been completed in all 50 states.
 

 


Basic Criteria

Historic Tax Credits (HTC) are available through a non-competitive, open application process. If you meet the program requirements, you can claim the credit. The project must involve an “income producing” “certified historic structure”. The scope of work must meet the requirements of a “certified historic rehabilitation” and must make a “substantial investment” in the property, specifically in items that are considered Qualified Rehabilitation Expenditures (QRE). There is no cap on the amount of credits an individual project can claim nor on the amount of credits available for the program in any given fiscal year.

Definitions:

  1. Income-producing Properties include all buildings that generate income for their owners. Office buildings, retail stores, hotels, restaurants and rental apartments are the most common uses. Buildings owned by a for-profit owner but leased to a non-profit institution may also qualify, but check with your tax advisor. Owner-occupied dwellings are not eligible for the HTC, and buildings must remain income-producing for 5 years after rehab is complete.
  2. Certified Historic Structures are buildings listed in the National Register of Historic Places either individually or as contributing resources to a historic district. Buildings determined to be non-contributing to a historic district (because of age or alterations) are not able to use the HTC. While other types of resources (bridges, structures, objects, landscapes, etc.) can be listed in the National Register, they do not meet the Internal Revenue Service (IRS) definition of a “building” that is required to use the HTC. A building can apply for National Register designation while applying for the HTC.
  3. A certified historic rehabilitation meets the Secretary of the Interior’s Standards for Rehabilitation (Secretary’s Standards). The State Historic Preservation Office (SHPO) and the National Park Service (NPS) review photographs of the building, architectural plans, and a written scope of work to ensure that the project preserves the character-defining features of the historic building, site, and environment.
  4. QRE include depreciable construction costs as well as allocated soft costs. All permanent changes to the exterior and the interior of the building are QRE. A simple way to visualize QRE is to imagine turning the building upside down. Anything that falls out is NOT QRE. A general list of non-QRE expenses includes:
    • Acquisition
    • Enlargement of the building footprint or mass (although additions may be allowed if they meet the design guidelines). This includes structures and equipment required for new circulation towers, if those elements are outside the historic building footprint
    • Site improvements, including hardscaping and landscaping
    • Personal property, such as furniture, appliances, and signage
    • Marketing and lease-up
  5. Substantial Investment is defined by the IRS as QRE exceeding the greater of $5000 or the “adjusted basis” of the building. If the building is newly acquired the formula is:

Purchase Price
-Value of land
Adjusted Basis

If you previously made improvements to the building those need to be added to the equation, and any earned depreciation can be subtracted.

Purchase Price
- Value of land
+ Value of prior capital improvements
- Depreciation
Adjusted Basis

Commercial Building Lofts, Sedalia, MO (Before)

Commercial Building Lofts, Sedalia, MO (Before): Located just north of the courthouse square, the 1896-97 Commerce Building was rehabilitated to create 28 affordable apartments for families. The plan preserved a wide variety of historic fabric including pressed metal ceilings, cast iron columns, stair railings, mosaic floor tile, and glazed corridors. Photo: f-stop Photography

 

Commercial Building Lofts, Sedalia, MO (After)

Commercial Building Lofts, Sedalia, MO (After). Photo: f-stop Photography

 

Upside Down House

A simple way to visualize QRE is to imagine turning the building upside down. Anything that falls out is NOT QRE.

 

QRE must meet the substantial investment test in a 24-month period. The applicant has some flexibility in defining that window, but if needed the project can be phased to extend the 24-month window to 60 months (5 years). The application must present the phases, in both a narrative description and architectural plans, at the start of the project, although the phasing plan can be amended later in the project. Because the extended rehabilitation period may require recalculation of the adjusted basis for the later phases of work, check with your tax advisor if you are considering a phased project.


National Register of Historic Places

Projects that use the HTC must involve a building listed in the National Registrar of Historic Places. The National Register of Historic Places is the nation’s list of historic buildings, structures, sites and objects that merit preservation. The National Register was created by the National Historic Preservation Act of 1966, and it is administered by the National Park Service with input from the State Historic Preservation Offices (SHPOs).

Typically, resources must be at least 50 years old to qualify for National Register designation. There are exceptions for newer resources that can demonstrate exceptional significance. As mentioned above, only designated buildings are eligible for historic tax credits. To find out if a property is on the National Register contact your SHPO or visit the National Park Service (NPS) website.

In addition to its age, a National Register property must demonstrate that it has significance at the national, state or local level in at least one of four areas. These include association with historical events or patterns of history, association with important persons, and architectural or artistic distinction. The fourth criterion, the ability to yield information about history or prehistory, mainly applies to archaeological sites. A property that is on the National Register as part of a historic district can have less individual significance as long as it supports the significance of the larger whole.

Finally, the appearance of a property must be able to communicate its period of construction and its historic significance, a quality referred to as architectural integrity. Resources that have integrity appear much as they did when they were built or achieved historic significance. The National Register program defines seven types of integrity – location, setting, design, materials, workmanship, feeling, and association. Changes to a building that remove historic material or add new elements can weaken integrity in one or more areas. When alterations compromise integrity to the point that the building would not be recognizable to the people who knew it during its period of significance, it is no longer eligible for National Register listing.

One persistent myth about the National Register is that designation limits how a building can be changed or used and will impact future sale of the building. Listing in the National Register does not inherently impact how an owner uses a building or changes a building unless the owner chooses to use a federal incentive (such as historic tax credits or a federally-funded grant program) or if the property is subject to a federal permit or other action (such as licensing for a cell tower). Similarly, National Register listing offers a layer of protection to properties that may fall within the path of a federal undertaking, such as a highway construction project.

Some states and localities do require a review when changes are proposed to historic buildings to ensure that the changes are compatible with the property’s character. This review is often triggered by a building permit and usually focuses on the exterior facades. Check with your SHPO or local planning department to see if this type of review applies in your area.

Hollywood Bungalow Courts, Hollywood, CA

Hollywood Bungalow Courts, Hollywood, CA: The $11 million rehab of the Hollywood Bungalow Courts secured the future of a quintessential Southern California property type while providing housing for special-needs and low-income residents. The project preserved unique historic features of the apartments, such as built-in ironing boards and pull-down kitchen tables, as well as the open space and landscaping that are as essential to the property’s historic character as the buildings themselves. Photo: National Park Service

 

Riverside Plaza, Minneapolis, MN

Riverside Plaza, Minneapolis, MN: Although built in 1974, the Riverside Plaza housing complex in downtown Minneapolis was listed on the National Register in 2010. The nomination recognized the exceptional significance of the property as an example of a HUD program called “New Towns - In Town.” Based on European housing models, the varied massing of the Brutalist buildings aimed to create a diverse cityscape that integrated open space and other amenities. After an $85 million HTC rehab, Riverside Plaza continues to provide affordable housing to 4,400 residents, making it the largest affordable housing development in the Midwest. Photo: Sherman Associates

Secretary of the Interior’s Standards for Rehabilitation

The preservation guidelines that apply to HTC projects are the Secretary of the Interior’s Standards for Rehabilitation [36 CFR 67.7]. Rehabilitation encourages the retention of surviving historic material and features, but also accommodates modifications that enable a building to be adapted for a new function and that allow it to remain economically viable. An HTC project must meet all 10 standards as they apply to both the building’s exterior, interior, and site.
The 10 Standards for Rehabilitation can be summarized as:

  • Retain and repair historic materials, features and spaces;
  • Retain historic character, even if use changes; and
  • Design compatible, reversible additions or alterations

NPS Guidelines for Rehabilitation provide general advice in a recommended/not-recommended format. Each building is viewed as unique in its architecture, history, current conditions, and context for redevelopment. Reviewers consider the individual building history and circumstances to determine appropriateness of proposed treatments.

 

 

Bancroft School, Kansas City, MO (Before)

Bancroft School, Kansas City, MO (Before): The $14.3 million conversion of the long-vacant Bancroft School into affordable family housing took great care to preserve many of the building’s historic features. Glass-fronted cabinets, beadboard wainscot, chalkboard frames and other trim are among the elements that make the apartments distinctive. Finding creative uses for large-volume spaces (like the auditorium and gymnasium) can be critical to the success of a rehab project. At Bancroft the gym became the site of a mobile health clinic and the auditorium was preserved as community meeting space. Photo: f-stop Photography

 

Bancroft School, Kansas City, MO (After)

Bancroft School, Kansas City, MO (After). Photo: f-stop Photography

 

 

The NPS website features an array of technical guidance. Preservation briefs and technical case studies discuss how specific building elements and rehabilitation treatments will be reviewed. They illustrate successful solutions for a wide variety of common rehabilitation concerns, such as windows, masonry, building additions, corridors, large historically-open spaces (such as an auditorium), and adapting elements that do not meet modern building code (such as low railings).

There is no need to reinvent the wheel when completing a rehab project. If you encounter an issue, it is likely someone else encountered – and solved - it before you. In addition to the on-line guidance from NPS, SHPO staff are a resource for finding appropriate solutions. Often they are able to make a site visit to help explore options.

 

Rochester Hotel, Kansas City, MO

Rochester Hotel, Kansas City, MO: The Rochester Hotel was built in 1919 with 24 very small studio apartments and shared bathrooms. It was rehabilitated in 2013, along with six single-family houses/duplexes across the street, to provide affordable senior housing for Jazz musicians in Kansas City’s historic 18th & Vine neighborhood. Because the building footprint could not accommodate a modern stair and elevator without sacrificing apartment units, a new circulation tower was added to the exterior. It sits back from the façade and is clad in red brick to complement the historic building. Collaboration with the Missouri SHPO and NPS ensured that the design would meet the Secretary’s Standards. Photo: f-stop Photography

 

Murray Hill Sr. Apartments, Chanute, KS

Murray Hill Sr. Apartments, Chanute, KS: Murray Hill Elementary School was built with a unique window system that allowed day light and fresh air into classrooms, but used glass block to help eliminate distractions to students from outside. This window system was a character-defining feature of the historic building and could not be altered when the project converted to senior housing. The developer worked closely with the Kansas SHPO and NPS to find a solution that met the needs of residents, addressed local building codes, and satisfied the Secretary’s Standards. Photo: f-stop Photography

 

Mt. Washington Sr. Apts, Independence, MO

Mt. Washington Sr. Apts, Independence, MO: When the 1903 Mt. Washington School was converted into 45 affordable senior apartments, the project team was tasked with identifying new uses for two key large-volume spaces – the original auditorium and the library, which had served not only the school but the public as a branch of the municipal library system. The library became an informal lounge for building residents, while the auditorium was preserved as meeting space for the community. In addition to HTC and LIHTC, the $10.6 million project also used Neighborhood Stabilization and HOME funds. Photo: f-stop Photography

HTC Application Process

HTC applications are reviewed first by SHPO and next by NPS. The application has three parts.

The National Register (NR) status of your building at the start of the project determines where you enter the application process. If your property is not listed on the NR, you would start by preparing a draft nomination and filing this with your part 1 application. If your property is already contributing to a historic district, you file the part 1 to confirm that status. If your property is individually listed, you can go directly to part 2. The process for part 2 and part 3 is the same for all projects.

Typical HTC Application Process Flowchart

For buildings that are not already on the NR, the Part 1 provides detailed information about the building’s physical appearance, architectural integrity, history, and significance. The Part 1 documentation should be equivalent to a draft NR so that the reviewers can determine if the building is NR eligible. While the Part 1 approval is a preliminary determination, it provides developers, investors and lenders with a level of comfort before the project moves forward.

After the Part 1 is approved, the owner can apply for official National Register designation. This is a separate process from the HTC review and takes 6-9 months to complete. Rehabilitation can begin before the building has NR status, but the building must be officially listed on the NR within 30 months after the rehabilitation is completed. Tax credits can be claimed while the nomination is in progress, at the owner’s risk.

A critical piece of the Part 1 application is documentation of the building’s appearance before rehabilitation starts. “Before” photographs showing existing conditions on the exterior and interior are required to illustrate the configuration and relationship of spaces; the types and conditions of building materials; and the character-defining features and finishes that communicate the historic style, function and significance of the property.

The Part 2 application includes a detailed description of proposed treatments, including materials and techniques to be used, and presents architectural plans and pertinent construction specifications. Architectural plans should be sufficiently developed to show how historic features will be treated and/or altered and how new elements will be added. Additional photos documenting in detail the existing (“before”) conditions are submitted with the Part 2.

If SHPO or NPS feels that an element of the scope does not meet the Standards, they will place a condition on the approval. As long as the completed rehabilitation addresses this condition, the Part 3 application will be approved at the end of the project. The reviewers prefer to issue a “clean” approval with as few conditions as possible (preferably none), and will help applicants figure out how to revise the scope of work to meet the Standards.

Applicants can file an amendment to officially revise the scope of work to address any conditions. Approval of the amendment assures the applicant that NPS will approve the revised approach when the Part 3 is submitted. An amendment can also be filed if new information becomes available or if the scope of work evolves during construction.

Construction can start before NPS approves the Part 2 application, but at increased risk. If at the end of construction any element of the scope does not meet the Standards, the credits cannot be claimed.

  1. Part 1 confirms that the building is a certified historic structure eligible for historic tax credits. In other words, it must be contributing to a National Register historic district or determined eligible for NR listing. Part 1 is not required for individually listed buildings, unless the nomination includes more than one resource. In this case, as with a district, a Part 1 must be submitted to indicate which building(s) are contributing or non-contributing.
  2. Part 2 presents the scope of work for the rehabilitation and is reviewed to verify it will meet the Secretary’s Standards for Rehabilitation. Many investors and lenders require an approved Part 2 application before they will close on project financing.
  3. Part 3 certifies that the completed rehabilitation meets the Secretary’s Standards. The submittal includes “after” photos documenting the exterior and interior of the completed rehabilitation, estimated QRE and total project costs, and ownership information (for assignment of credits). The date of Part 3 approval must be attached to IRS documents in order to claim the credits. If a project is phased, the amendment certifying completion of that phase may be used to evidence of pending approval.

The NPS charges a fee to review the Part 2 and Part 3 applications. The fee has a sliding scale based on the project cost. The applicant pays half of the fee when NPS receives the Part 2 application and half when NPS receives the Part 3 application.


How do I use the HTC?

The owner of the historic property may claim the HTC after rehabilitation is complete and certified as meeting the Secretary’s Standards (Part 3 approval).
The owner must be a for-profit taxpaying entity, but that can take several forms.

  • A fee simple property owner of the property may be an individual, partnership or corporation.
  • A limited partnership can distribute the benefit to its members. In this scenario, an equity partner can invest in the project in exchange for rights to the credit. The investment helps finance rehabilitation. Historic projects typically sell for varying amounts, but in 2017, a typical project atrracts a net investment of $.70/$1 HTC that will be allocated. IRS Safe Harbor rules issued in 2015 require that the investor be a real partner with potential for both upside (gains) and downside (losses) in the deal.
  • Under some circumstances the lessee of a newly rehabilitated building can claim the credit if the lease term exceeds 80 percent of the depreciation period (39 years for non-residential property and 27.5 years for residential rental property). After a project is certified to receive the HTC (Part 3 approved), the owner can use the credit to offset income tax liability dollar-for-dollar, beginning the year the building is placed in service (rehab is complete). It can be carried back one year and forward for up to 20 years.

Always check with a tax advisor before starting a project to understand how the HTC will apply to your specific circumstances.

Claiming the credit is very straightforward. The taxpayer submits IRS Form 3648 along with the NPS project number with their annual tax documents. The amount of the credit calculated on Form 3648 is factored into final calculations and deducted from the bottom line of taxes owed. If your project has not yet received Part 3 approval you must complete that step within 30 months after the placed in service date.

If a project has multiple phases, partial credit may be claimed when one or more phases of work are ready to be placed into service and the substantial investment test is met. The partial credit drawdown will be subject to recapture if the project does not receive Part 3 certification.

HTC are also subject to recapture if the building ownership changes or non-compliant changes are made within 60 months after NPS certifies the rehabilitation (Part 3 approved). Recapture is pro-rated based on amount of time passed since issuance of credits.


Combining the HTC & Other Incentives

The HTC can be coupled with other local, state and federal incentives. State historic tax credits are currently available in 34 states, and nearly half of all federal HTC projects are twinned with this incentive. Many state HTCs can be directly transferred (i.e. sold) to other businesses or individuals who want to offset their state tax obligation. If your project is in a state that also has a state HTC, check with your tax advisor to see if these are transferable and by what means.

The two most common federal incentives used with the HTC are the Low Income Housing Tax Credit (LIHTC) and New Markets Tax Credits (NMTC). Other federal, state and local Incentives that developers often use to finance rehabilitation include HOME Investments Partnership Program (HOME) and (Community Development Block Grant) CDBG funds, United States Department of Agriculture (USDA) rural loan programs, Brownfields grants, tax abatement, and tax increment financing (TIF). Investment in an HTC project can also count toward Community Reinvestment Act (CRA) requirements for banks. Be aware that a federal grant may affect the amount of HTC a project receives. If your project is using additional sources of federal funds, be sure to consult with your tax advisor to understand how these funds may affect your project.

HTC & LIHTC:
HTC projects have rehabilitated over 150,000 units of affordable housing since 1976. Some of these projects were originally developed as affordable housing, while others adaptively reuse buildings constructed for other purposes. The HTC and LIHTC program guidelines are generally compatible, although there are some notable differences in how the credits are calculated, which costs are QRE, and when the credits are awarded. The HTC will reduce the eligible basis for the LIHTC, although the LIHTC does not affect the amount of HTC a project earns. Combining the HTC with the LIHTC is very attractive to affordable housing developers because it attracts additional equity to a project. View a detailed side-by-side comparison of the two programs.

Elm Terrace, Portland, ME

Elm Terrace, Portland, ME: A rehabilitated building is inherently very “green,” and HTC projects frequently achieve Leadership in Environment Energy and Design (LEED) status or recognition by other programs that encourage environmental sustainability in construction and operations. The $10.6 million Rehabilitation of Elm Terrace by Community Housing of Maine was certified for meeting the Secretary’s Standards and LEED Platinum standards. The project adapted a former Children’s Hospital to provide 38 affordable apartments using federal and state HTC, LIHTC, and federal and city HOME funds. Photo: Sandy Agrafiotis Photography

 

Elm Terrace. Photo: Sandy Agrafiotis Photography

Five Secrets for a Successful HTC Project

  1. Assemble a team of experienced, knowledgeable professionals to make your project run smoothly. These might include a preservation consultant who understands the application process, procedures, and Standards; an architect and structural and Mechanical, Electrical, and Plumbing (MEP) engineers who are experienced with historic buildings; and a real estate attorney and tax accountant who are familiar with the tax rules related to the HTC. Team members should have a track record of recent success on HTC projects similar to yours. Ask for references. Have they worked on projects similar to yours (e.g. conversion of a historic school to affordable housing)? Find out what kinds of obstacles they encountered on other projects and how they overcame those obstacles.
  2. Initiate contact with SHPO staff early in the process and maintain regular communication. SHPO staff are often able to visit the project site during the planning stage. They can help identify key historic elements that will be critical to retain during the project and can suggest appropriate rehabilitation strategies. If the situation is particularly complicated, SHPO can bring NPS into the conversation. Their wealth of experience can provide creative solutions and ideas.
  3. Allow ample time for the review process. At minimum the review period is 60 days (30 at SHPO + 30 at NPS). Once you build in administrative time to transmit and log application packages, it is not unusual for the review period to run 90 days, particularly at peak periods in the construction cycle. While these timeframes can sound daunting, they usually mesh well with the general development process if you anticipate them from the outset. A set of plans shared with contractors for pricing may be sufficiently developed to submit for Part 2 review. You will sleep better knowing the Part 2 has been approved before major expenditures have occurred and the hammers start swinging.
  4. Rehabilitation plans may evolve during construction. An unexpected condition might be discovered in the field, budgets can modulate, new tenants may make specific requests. If plans change, do not assume that the revisions will meet the Standards. Submit an amendment for SHPO and NPS to review.
  5. Throughout the process, address issues proactively before they become problems. Engage SHPO in addressing these situations whether they occur before, during or after construction.

 

Cherokee Terrace, Enid, OK

Cherokee Terrace, Enid, OK: Cherokee Terrace was built as a Public Works Administration project in 1937. The 80 apartments fill eight buildings on a landscaped 6.6-acre site. In 2016 the owners completed an $11 million rehab using HTC and LIHTC with a focus on updating building systems and refreshing finishes. The complex continues to provide affordable housing for families in Enid.

 

NSO Bell Building, Detroit, MI

NSO Bell Building, Detroit, MI: Detroit’s Neighborhood Service Organization (NSO) adapted the 1927 Art Deco Michigan Bell and Western Electric Warehouse to create a social service center and 155 units of affordable housing for the chronically homeless, using both LIHTC and HTC. Photo: Kidorf Consulting

 

Seven Oaks Ribbon Cutting, Kansas City, MO

Seven Oaks Ribbon Cutting, Kansas City, MO. Photo: Elizabeth Rosin

Additional Resources

National Register of Historic Places (NR)

Historic Tax Credits (HTC)

Guidance for Applying the Secretary’s Standards

Tax Issues

Distribution of HTC Projects

LIHTC and HTC