The National Register Process in Pennsylvania

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Wise Preservation Planning LLC
      1480 Hilltop Road
      Chester Springs PA 19425
      Phone (484) 202-8187
 

Wise Preservation Planning LLC is a full-service historic preservation planning firm. We research, document, analyze and ultimately help protect historic resources and our cultural landscape. Our firm serves a variety of clients, including municipalities, engineers, architects, historical societies, and owners of historic resources.

The firm was founded in 1997 by Robert J. Wise Jr., who has 20 years of experience in the historic preservation field. He is assisted by Seth Hinshaw, Senior Planner, who has been with the firm since 2001. Both planners have M.S. degrees in historic preservation from the University of Pennsylvania and exceed the 36 CFR 61 Professional Qualification Standards established by the National Park Service for architectural historians.

Overview

Historic properties are listed on the National Register of Historic Places through a multi-part process outlined below. The property owner(s) must be involved in the process in order for a property to be listed, though many owners choose to hire a consultant because of the complexity of the process. Local governments sometimes choose to pursue the listing of historic districts, though again property owners must be involved. The Pennsylvania Historical and Museum Commission (PHMC) oversees the nomination process statewide. The following narrative assumes that no work has been completed on the property; parts of the process may not be needed if the early portions of the process have been completed in prior work.

 

— 1. Pennsylvania Historic Resource Survey Form —

The Pennsylvania Historic Resource Survey Form (HRSF) was developed to document the appearance of historic resources and the history of the property. It is a 6-page form with many cells for various types of information including architectural style, construction date, address, and building materials. The HRSF is sometimes used by counties or municipalities for their own purposes. The form includes two important essays: one that provides a detailed architectural description and one that provides a property history (usually with a chain of title).

 

— 2. Determination of Eligibility —

Staff at the Pennsylvania Historical and Museum Commission (PHMC) grant a "determination of eligibility for the National Register", usually called a "DOE", based on information supplied in the HRSF. Technically, the PHMC staff decision is tentative, but in 99% of cases the staff decision to grant (or not grant) a DOE is very difficult to challenge. If the staff believes that a property meets significance requirements for the National Register, they will send a letter to the property owner outlining their decision and give guidelines for how to proceed to the next step.
 
Note: PHMC staff have decided that DOEs granted in the 20th century need to be reviewed again if the owner chooses to pursue a National Register nomination.

 

— 3. National Register Form —

The next step involves the completion of the National Register nomination form. The form, provided by the National Park Service, provides consistency among nomiations nationwide. It is more detailed than the HRSF, though it similarly has two important essays: architectural description and significance.
 
Completion of the NR form begins with the letter from PHMC staff when they grant the DOE. Their letter includes information that outlines what additional research is needed and provides guidelines for drafting the significance essay. Most NR nominations do not need a lot of additional historic research if the research for the DOE was exhaustive.
 
The National Register form is usually completed by a consultant. The first draft addresses the information mentioned in the letter by PHMC staff following their decision to grant the DOE. After the owner approves the draft, it is sent to PHMC for the staff to read it. PHMC staff have read hundreds of NR forms and have a good sense of ways to improve the form. They will issue a response to the first draft, including additional work that they believe is warranted.
 
Once the letter with the staff review of the first draft is received, the consultant can address the outstanding issues mentioned in the letter. The result is the second draft, which is returned to PHMC staff. If acceptable, PHMC staff will place the nomination on the agenda for the Preservation Board meeting. They will also send a formal letter to the owner(s) of the property to make sure that they are aware of what is happening. Owner(s) may either support the nomination, object to the nomination, or take no action. Letters by property owners who object to listing the property must be sent by certified mail. The process will not move forward if half or more of the property owners object.

 

— 4. Pennsylvania Preservation Board —

The Preservation Board is a group of people from different professions around the Commonwealth who gather at specified times each year to review National Register nominations that have been approved by PHMC staff (the Board also has other responsibilities). Board members read each nomination form before the meeting and then discuss them together. Some discussions are short, while others are quite involved in the details of the property being nominated. During the discussion of a particular nomination, any letters of support or objections from property owners are read. At the end of the discussion, the Board has three general choices: (1) formally nominate the property to the National Register; (2) ask for more information or clarification; or (3) turn down the nomination. If it chooses (1) above, the process continues.

 

— 5. Listing by the National Park Service —

If the Preservation Board chooses to nominate a property, PHMC staff sends the nomination to the National Park Service (NPS). NPS staff read through the nomination, identify any technical issues that may be resolved easily, and then discuss whether to list the property. Pennsylvania has a rigorous process itself, which means that few nominations from Pennsylvania are turned down once they have been sent to the NPS. After any technical issues are resolved, NPS staff send a letter to the property owner(s) stating that the property has been listed on the National Register of Historic Places.