A blog post by Virginia Harness
Listing a property in the National Register of Historic Places is an intensive process. National Register nominations are part collegiate-level research paper and part cultural resources survey. Navigating the forms, instructions, and approvals can be a challenge, but the National Register co-coordinators at the State Historic Preservation Office (SHPO) are here to guide you on your way to a successful nomination. Although the National Register is a federal program, and the listing of properties ultimately falls to the National Park Service (NPS), the SHPO shepherds nominations through most of the listing process.
Preliminary Information Form
Nominations require a lot of time and effort, so many people want to know if a property is eligible for listing before they take on the challenge of writing a nomination. We encourage anyone thinking about trying to list a property to start with a Preliminary Information Form (PIF). The only exception to this would be if the property was already determined eligible for listing in the National Register, such as in a historic resources survey. Even then, if significant time has passed or the property was altered, it is always a good idea to get a fresh opinion.
If staff believe the property is eligible, we notify the preparer via email and provide them with the blank form, instructions, and example nominations. When we don’t think a property is eligible for listing, we write a letter to the preparer to let them know and explain our reasoning.
Baseline Review
When a draft nomination comes in, staff let the preparer know it was received and begin the review process. We recently developed a checklist of Submittal Requirements for National Register Nominations to help preparers know what is required of them and make staff reviews more efficient. When we receive a new nomination, we review it against this checklist first to make sure the nomination is complete. If any item on the checklist is not complete, we let the preparer know and request a revised nomination. At this level of review we are only looking for completeness and not taking a hard look at the substantive content of the nomination.
Left: Front cover of National Register Bulletin 16A. Right: First page of the National Register nomination form.
Substantive Review
Once a nomination is complete (per the checklist), SHPO staff conduct an in depth review of the content, especially Section 7 (Narrative Description) and Section 8 (Statement of Significance). Typically, the draft is reviewed by both National Register coordinators, though it may also be reviewed by additional SHPO staff members. A redline draft of the nomination and SHPO comments are emailed to the preparer. Staff comments will address any outstanding technical issues, but primarily focus on improving and refining the text to help the preparer make the best possible case for listing the property in the National Register. Sometimes staff may need to request multiple rounds of revisions. We work with the preparer to iron out as many wrinkles as possible in the hopes of ensuring the nomination sails smoothly through the rest of the listing process.
State Review Board
When the review process is complete, the nominations are scheduled to be heard by the State Review Board. The Review Board meets three times per year, typically in March, July, and November. SHPO staff set Review Board agendas about sixty days before the meeting. Staff consider nominations received at least ninety days in advance of the meeting and only select drafts that require little to no revision, which typically means nominations that have already been through one or more rounds of review. In order to keep the length of the meetings reasonable, the agenda does not usually exceed seven nominations. Staff will consider both a nomination’s overall completeness and submittal date if there is not room on the agenda for all drafts received before the consideration deadline.
When a nomination is selected for Review Board, SHPO staff let the preparer know and provide detailed instructions for the meeting. The National Register co-coordinators will put the nomination through a final round of polishing up before the meeting and combine all the elements (nomination form, maps, photographs, and figures) into a single PDF.
Chairman Bill Kinney opens the November 17, 2017 meeting of the State Review Board
Two weeks in advance of the meeting, staff post the draft nominations to our website and send them to the Review Board members. The meeting, which is open to the public, is run by the chairman of the Review Board, but staff are responsible for many of the logistics. Staff set up (and clean up) the meeting room, procure refreshments, switch PowerPoints between presenters, keep time for the presenters, and take minutes. We are also sometimes called upon to answer questions, either about a specific nomination or the technical aspects of the National Register. If there are extenuating circumstances, staff members may also need to present one or more nominations. The extensive review process typically pays off at Review Board, where the vast majority of nominations are approved and move forward in the listing process.
Submittal to the National Park Service
After Review Board, staff go over the nominations one last time to make sure everything is complete and correct. We then burn the nominations and images to a CD or DVD and ship them to NPS, usually in groups of two or three. The goal is for NPS to receive the nominations no more than forty-five days after Review Board. Once the nominations are received by NPS, they have forty-five days to act on it. The vast majority of the time, the property is listed. On occasion, nominations are returned for substantive or technical reasons. The nomination preparers and/or SHPO staff are usually able to address these issues and resubmit for successful listing.
After Listing
NPS actions related to the National Register are cataloged in the Weekly List, which SHPO staff receive via email. There is usually several days lag time between the actual listing of a property and its appearance on the Weekly List. Once staff are notified of the listing, we prepare notification letters for the property owner(s) and chief elected official.
National Register listing for McCoy Farmstead on SCHPR.
Once a property is listed, we print a hardcopy of the nomination and include relevant research materials and correspondence in the official nomination file. Storage of photographs is now entirely digital and we transfer them to the listed nomination image files on our network. SHPO staff write a summary for the new listing. The summary, nomination, maps, and select photos, are uploaded by our Electronic Records Archivist to the South Carolina Historic Properties Record (SCHPR). Staff also map the property in SC ArchSite.
What happens next is up to the owner! Listing in the National Register offers only limited protection for historic properties, so many listed properties will never come across a SHPO desk again. If the owner of a listed property wants to take advantage of available tax incentives, or order a National Register plaque, SHPO staff are ready to help.
Want to know more about the National Register? Check out our website.