Tax Credit Guidance And Application Process

• Part 1 photographs are used for making eligibility determinations and to identify character defining features which must remain. A comprehensive documentation of the building is required.   
• Part 1 photographs should be numbered, properly labelled, and keyed to an existing floorplan of the building.  
• Part 1 photographs should capture character-defining features of the building.  
• Photographs submitted for Part 1 should document the entirety of the building, its site, and environment as it exists prior to any rehabilitation work being undertaken. 
• Site and Surrounding Environment: Streetscape photographs showing the buildings on either side of the subject building are recommended for urban buildings. All outbuildings and secondary resources must be photographed, even if they are not historic or not part of the rehabilitation project  
• Exterior Elevations: Capture all exterior elevations/facades. Where elevations are partially blocked by adjacent buildings, trees, landscaping, etc., it may be necessary to take several photographs from different angles to show the whole elevation. When elevations are covered or boarded up, remove coverings/boards to take photographs. Without seeing the entirety of the building, the project cannot be properly evaluated. 
• Exterior Features: Typical features include but are not limited to: Siding, Window sashes, Foundations, Roofing, Shutters, and Doors 
• Interior Spaces: Must include spaces where rehabilitation work is proposed as well as spaces where no work is intended to take place. Wide-angle photographs are recommended. Photographs of rooms can be oriented corner-to-corner from opposite corners. It the areas are too large or at too difficult an angle, multiple photographs should be taken to ensure full coverage of the space. Spaces include but are not limited to: hallways, stairways, and principal rooms. 
• Interior Features and Finishes: Photographs should provide an overview of the rooms throughout the building. Buildings with multiple, near identical spaces may not need photographs of every room. In such cases, representative photographs of the typical spaces may be acceptable. Please reach out to THC_Rehab@tn.gov if you have any questions. Features include but are not limited to: staircases and balustrades, mantelpieces and surrounds, woodwork and trim, ceilings, fireplaces, windows, doors, walls, ceilings, moldings.

• Photographs submitted for Part 2 should comprehensively document the building. Photographs should especially document any areas where rehabilitation work is proposed and illustrate information provided in the Part 2 textual descriptions.  
• Photographs must be numbered, properly labelled, and keyed to a floorplan and the Part 2 description of proposed work.  
• Photographs should document details of deteriorated interior and exterior features. Examples: peeling paint, rotten wood, cracked plaster, previously altered features, window deterioration. It is not necessary to take multiple photographs of every deteriorated detail. Representative photographs are sufficient to demonstrate conditions.  
• If the building is individually listed on the National Register of Historic Places, and a Part 1 Application is not required, the Part 2 photographs should also adequately capture all features and elevations that would be captured in Part 1 photographs.  

• Photographs for Part 3 should show all areas of the building, including where work was completed and where it was not. 
• Photographs for Part 3 should follow the locations and angles where the Part 2 Photographs were taken, as much as possible.  
• Detail images should be provided for any specific technical work. Examples: masonry repointing, window restoration, or in-kind replacement of distinctive historic fabric and features.

• Photographs should be contained in a PDF with no more than two photographs per page, and with a size of 4”x6” per photograph.  
• The property name, address, date of photographs, and application part (i.e., Part 1, Part 2, Part 3, Amendment) must be listed at the top of each page.  
• The photograph number (labeled according to a Photo) and caption must be listed under each photograph.  
• The Photo Key must be submitted as a separate PDF.
• NPS guidance on the requirements is available or reach our to our office for assistance. Additional NPS guidance provides samples.  

When I can begin the application process?

Apply at any time during the year. Apply before starting rehabilitation work whenever possible. We encourage you reach out the TN SHPO with any questions as soon as possible. As always, applicants who undertake rehabilitation projects without prior approval from the NPS do so at their own risk. 

Are electronic submittals required?

All applications submitted to the TN SHPO are required by NPS to be in electronic form, using the 2023 application forms labelled NPS Form 10-168 (Rev. 6/2023). This is the only form that will be accepted on and after August 15, 2023.  

How does the submittal process work? 

For Part 1, Part 2, Part 3 applications and amendments, you will submit files to the TN SHPO using our required process. Once the TN SHPO completes their review, and no additional information is required, the TN SHPO will forward the electronic application to NPS for review.  

If the application form is all digital, how do I sign the form? What types of e-signatures will be accepted?

E-signatures are required for the electronic submittals. Three types of e-signatures will be accepted:

1. a scanned PDF of an actual, original ink-signed application
2. a scanned or digitized version of an actual, original handwritten signature, and
3. a digital signature using a digital ID (e.g., using Adobe software).

A name typed in a different font and other types of generated signature images will not be accepted. Refer to the image below for examples of acceptable and unacceptable e-signatures. 

How will NPS electronically sign the cover page it the submitted cover page is printed, signed, and scanned?

NPS can add an e-signature to a PDF whether it’s a scanned hard copy or a digitally signed PDF.  

How long does it take for the NPS “Check Project Status” database to update once materials are uploaded to the NPS SharePoint site? 

The database typically takes about one (1) day to refresh.  

Is Adobe required to view the application?

Yes. The application forms are fully functional only in Adobe Acrobat and Adobe Reader (a free PDF reader that can be downloaded from Adobe). The forms cannot be opened, completed, or saved in a browser window, which is why clicking on the link for a form produces the Adobe 8 message.  

How do I open the application? I get the following message when I attempt to open it in the browser: “The document you are trying to load requires Adobe Reader 8 or higher. You may not have the Adobe Reader installed or your viewing environment may not be properly configured to use Adobe Reader.”

Follow these directions, also listed on the National Park Service website, to download, save, and then use the application forms:

• Do not open the forms in a browser tab or window 
• Download the forms and SAVE them to your computer. To download and save, right click on the link and choose "Save Link As..." 
• Open Adobe Acrobat or Adobe Reader
• Open the forms in Acrobat or Reader 

How do we sign up for the Technical Preservation Services newsletter? 

You can sign up by following the instructions on the “Keep in Touch with TPS” page. 

How can we continue to receive support through this process? 

Reach out to THC.Rehab@tn.gov with any questions you might have. 

Can I submit a Part 1 application (or Part 2 application) if all of the rehabilitation work is complete and the building is placed in service? 

It is not advisable. It is always advised to begin the application process before any rehabilitation work has taken place. There may be implications to eligibility as a result. Refer to the IRS Code and Regulations in Section 7. Additional Information for more on this late certifications. 

How does the applicant/project contact submit my electronic application materials to the TN SHPO? 

Contact Justin Heskew for access to submit the application with the Submittal Log (above)

What are the differences between the electronic submittals and the physical copies previously submitted?

For the most part, only the method of submission is changing, not the content. You will still submit the appropriate (Part 1/2/3/Amendment) application with the required supporting documentation. A new requirement with electronic submissions is the transmittal log. 

What is the transmittal log and what information should be included?

The transmittal log details what is being submitted electronically with each submission. The information that is included depends on the scope of the project and each application phase. Samples can be provided for reference. The transmittal log helps ensure that everything that you intended to submit to the TN SHPO and NPS was successfully transmitted. 

Can Part 1 and Part 2 applications be submitted at the same time?

Yes. Through the TN SHPO electronic submittal portal, you will complete one submittal for all Part 1 materials and a separate submittal for all Part 2 materials.

Can all of the materials for each application be submitted as a single PDF?

No. The NPS requires that each type of documentation is submitted as an individual PDF. Refer to the NPS’s Electronic File Format Standards and File Naming Conventions as well as the TN SHPO’s Photograph Documentation Guidance for the Rehabilitation of Historic Properties (below on this page). Please Note: The TN SHPO will accept photographs only in a PDF format. Individual photographs will not be accepted. This differs from NPS proposed submittal formats.

Can I begin the rehabilitation work on my building before the NPS reviewer has provided a decision on my Part 2 application? 

Applicants are strongly encouraged to submit applications describing proposed work and to receive approval from the NPS prior to the start of work. Applicants who undertake rehabilitation projects without prior approval from the NPS do so at their own risk.  

Can plans of existing and proposed conditions be submitted as a single PDF?

No. The plans must be separated into individual files and be properly named according to NPS’s naming conventions.

If the existing conditions, demolition, and proposed drawings are all initially one file, how can they be separated?

Adobe allows you to extract pages from a file and save them as a separate file.

Should the PDF plans still be 11” x 17”, or can they be larger?

The TNSHPO requires that floor plans be at least 11” x 17;” plans can be larger if preferred. All plans must be flattened.

What does it mean for a file to be “flattened?”

Some complex PDFs (for example, architectural drawings) can contain multiple layers, and for the purposes of electronic submittals, those layers must be flattened into a single layer. This makes it easier for the TN SHPO and NPS reviewers to zoom in and compare the different plans. To flatten an electronic file of architectural plans, select the “Print” function, then select “Adobe PDF” as the printer, and save the file. More information about how to flatten PDFs can be found in Adobe’s “Merge or flatten layers.”

What is the correct format for naming electronic submittal files?

The correct naming conventions can be found on the NPS’s Electronic File Format Standards and File Naming Conventions.

Does the TN SHPO have different naming conventions for electronic submittals?

No. The TN SHPO follows the same name conventions as the NPS. 

Is there a limit to the length of the file name?

Yes. File names should be limited to 75 characters. 

Can I use a dash in the naming convention if there are multiple numbers listed in the address? For example, 214-216E9thStreet?

No. In accordance with the NPS naming conventions, underscores should be used in place of dashes. 

Because the naming conventions don’t allow spaces, what is the best method for city names comprised of two words? 

As an example: Johnson City would appear as JohnsonCity.

How should we name supplemental information (e.g., correspondence between the SHPO and applicant)?

It should be saved as a separate PDF and named according to the NPS Naming Conventions.