Thematic Nomination Offers Alternative Way to Create Historic Tax Credit Projects

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Tax Credit Advisor, January 2010: There are two common approaches to making an old building eligible for the federal historic rehabilitation tax credit. One is to get it listed on the National Register of Historic Places as a certified historic structure. The other is to get it approved as a “contributing” building in a designated historic district.

A third, little-known method is a “thematic” approach, under which multiple buildings within a specified geographic area that share certain common characteristics can be made eligible for nomination for listing on the National Register.

This method provides developers an opportunity to seek National Register listings for multiple buildings at once rather than individually, and to create a pipeline of historic tax credit projects using properties they already own or that they acquire in the future.

In addition, “It provides an opportunity to list buildings that might not otherwise be listable,” says Boston historic preservation consultant Albert Rex, Director of the Northeast Office of MacRostie Historic Advisors, LLC.

Special Documentation

To go this route, a sponsor must complete a special National Park Service form, called the Multiple Property Documentation Form (MPDF), and get it approved by the Park Service and state historic preservation office (SHPO).

Once it has been approved, all buildings that match the theme and traits described in the MPDF become eligible for nomination to the National Register. A Park Service Part I form must still be submitted for each building to get it listed on the Register.

In the document, the sponsor:

  • Describes the particular type of older building that is being nominated and the common historic characteristics of such buildings (e.g. architectural style, construction type, time period of construction, original purpose);
  • Delineates a specific geographic area that the nomination covers;
  • Identifies specific buildings within this area that fit the defined theme; and,
  • Provides historical information regarding the proposed theme and buildings and why they are significant.

This document establishes future National Register registration requirements for buildings of this type located within the designated geographic area. This geographic area can vary, such as a particular neighborhood, entire city, or entire state.

Rex says a completed MPDF nomination form can be quite lengthy, say 75 to 80 pages. But once it has been approved, the Part I form subsequently submitted for each building is brief.

“This form creates an outline in which individual buildings can then be listed on the National Register,” says Rex.

There is substantial flexibility regarding the proposed theme for buildings in an MPDF. One approved MPDF, for example, covers working- and middle-class apartment buildings throughout Kansas City, Mo. These buildings (circa 1885 to 1959) are typically multi-story masonry structures with mostly studio and/or one bedroom apartments originally targeted to lower- and middle-income renter families.

As with buildings listed by traditional process on the National Register, and approved contributing buildings within an historic district, rehabilitation plans for buildings listed through a thematic nomination must still be approved by the Park Service and SHPO before any rehabilitation expenditures can qualify for the federal historic tax credit.

Advantages of Approach

The advantages to developers and owners of the thematic nomination approach include:

  • The ability to get buildings listed on the National Register that might have difficulty qualifying individually on their own merits or because they aren’t located within a designated historic district.
  • The ability to nominate a group of buildings at once, including those dispersed geographically.
  • Speedier future nominations and approvals of historic rehabilitation projects involving buildings that match the approved theme.
  • Greater predictability regarding the National Register listing requirements for a specific building type.
  • An already-approved document that can be used by other developers to register their own properties that fit the theme, in order to rehabilitate them with the historic tax credit.
  • Less likelihood of opposition from owners of other local historic buildings that fit the theme, since a thematic nomination doesn’t force other owners to get their properties listed on the National Register.

One drawback is the significant time to research and prepare a thematic nomination submission, and discuss it with the SHPO and Park Service to win approval. This can stretch out to a year or so, says Rex. But he also pointed out that most states offer survey and planning grants that municipalities can access that might help pay for the historic building survey done for a MPDF nomination.

Rex advises developers thinking of considering the thematic approach to look for multiple buildings of similar type in a community that they might combine into a single, economically viable historic tax credit project. These might be apartment buildings in a particular district, or warehouse- or mill-type buildings in an industrial area, for example.

Rex said apartment buildings, which are common nationwide, can be good candidates. One approved large-scale MPDF, for instance, covers garden apartments in Virginia of similar architecture built during the 1920s and 1930s that were originally financed with federally insured mortgages.