New Guidance Released for HTC Functionally Related Buildings Separate Project Treatment

The new guidance, released by the National Park Service, gives examples of when buildings functionally related historically can be treated as separate projects for the purpose of certification. The first recommendation NPS makes is that owners discuss the project with their State Historic Preservation Officer prior to submitting a Part 1 Application.

The guidance provides ten examples to illustrate possible circumstances allowing for the separate project treatment. The examples relate to several topics. The following list briefly summarizes some of those topics but those interested should read the guidance in its entirety.

  1. A “Gap” Between Projects

At least one year exists between the completion of one project and the commencement of work on another portion of the related buildings. No rehabilitation work should occur during the year gap, and the work completed in the second portion may affect the certification on the first portion.

  1. Large and Diverse Historic Properties

Typically this exception applies to a larger number of buildings and a historically diverse use amongst the buildings. Military bases, and university or school campuses are some provided examples. Failure of one project to meet standards generally will not affect certification of another project.

  1. Owner acquires another building after beginning a project and had not originally planned on acquiring additional building.
  2. Functionally related complexes under common ownership where the rehabilitation involves multiple buildings and will extend well beyond a 60-month phased-project time period.
  3. Large housing complexes consisting of many separate or semi-attached houses or buildings, multiple streets, and shared land area under common ownership.
  4. Situation in which all buildings were originally planned for rehabilitation, but later, due to financing or other reasons, work was never initiated for some of the buildings.