Frequently, PA SHPO staff receive inquiries regarding a homeowner’s historic property and their wish to list it in the National Register of Historic Places.
Many times, interesting family stories passed down from one generation to the next are tied to the property. As fascinating as most of the stories are, not all will hit the threshold of the National Park Service required criteria to qualify the property as significant at the local, state or national level.
However, before the level of review needed to make that call, there are numerous documents and items that PA SHPO staff need to verify the eligibility of a resource. Unfortunately, since there is a degree of deeper research required and the process may seem daunting, many homeowners stop after the first phone call or email.
Hopefully, this post about the Determination of Eligibility process and next week’s post about what we need to evaluate a historic resource will help make it all seem a little less scary.
What is a Determination of Eligibility (DOE)?
A determination of eligibility, or DOE, is an opinion by PA SHPO staff that the property either meets or does not meet the National Register Criteria for Evaluation to be listed in the National Register of Historic Places.
The William and Elisabeth Edwards House (PA-SHARE Resource #2018RE02690), listed in the National Register of Historic Places in February 2024, was an owner led nomination. The property was listed at the local level for its significance in the area of architecture.
Like most things procedural in life, there are sometimes misconceptions. Before deciding to start the DOE process, it is important to understand what the National Register of Places truly is and what it means to be listed.
PA SHPO has helpful information on our website worth reviewing to grasp a better understanding if National Register (NR) listing is the right path for your historic resource. You can find National Register fact sheets here on our Commonwealth website as well as on the National Park Service website.
Why consider listing a property?
National Register listing honors a property’s history and recognizes its significance at a local, state or national level. It is important to understand it is NOT a regulatory program.
It helps to educate the community and encourages preservation of Pennsylvania’s historic resources. It may also open the possibility of incentives for future preservation work (like historic tax credits or grants) on the property as well as consideration in the planning for state and federal projects or projects that are assisted by state or federal agencies.
How do I know what I need to do?
The first thing to do is check to see if the property you are interested in listing can be found in PA-SHARE, Pennsylvania’s online database of older and historic places.
In this image, the resource was found using the known resource name in a particular county (at left). A search may also be completed using the street address (center top).
A search may be done using the property address but may also be found using the historic or current name associated with the resource. If you are unsure how to search in PA-SHARE, National Register staff are available to assist you. There is also a tutorial for searching in PA-SHARE on our website: Searching for Resources and Other Information in PA-SHARE.pdf.
If the resource has been previously surveyed, there may be a record and a National Register status noted. Status may range from undetermined, not eligible, eligible, and listed. It may also provide information if the property is in an eligible or listed historic district.
The second thing to be aware of is when a DOE is required to start the National Register listing process. There are typically three scenarios that will require a new DOE:
- The first is when a resource has not yet been evaluated for its eligibility
- the second is for a resource that was previously evaluated but the evaluation date is over five years old, and
- the final is for a previously evaluated resource that has experienced significant changes since its last eligibility review.
The level of information that needs to be submitted for evaluation will depend on which of these three scenarios the resource falls under.
This example of the evaluation information page available in PA-SHARE shows that the master eligibility for the Kauffman Property is “eligible”. Note the green banner at the top of the page that indicates the eligible status.
Scenario #1: Your property isn’t recorded in PA-SHARE or it is recorded but never evaluated
In scenario #1, PA SHPO has never evaluated the historic resource to determine its eligibility for listing in the National Register. We may have no record of the property in PA-SHARE or have a record with very little information.
In this scenario, you’ll need to request a DOE through PA-SHARE, enter or update the resource, and upload information. Be sure to read next week’s post for instructions on how to do that.
Scenario #2: Your property has a DOE but it is 5 years old or older
When reviewing a resource that was previously evaluated, less documentation may be required. For instance, if the resource had extensive documentation submitted to our office from the previous evaluation the new DOE may only need an updated narrative addressing any changes to the resource, an updated plan, and current photos. Any new information discovered about the resource should also be included.
However, if the previously evaluated resource lacks insufficient documentation or an incomplete narrative, a full DOE submittal will be required.
Scenario #3: Your property has a DOE that is less than 5 years old but there have been significant changes since the last date of evaluation.
This scenario typically occurs when extensive construction work, which can include but is not limited to additions, material replacement, and interior room reconfiguration, has been recently completed and may impact an eligibility status.
It may also apply in a situation where non-historical alterations have been recently removed resulting in the visibility of original fabric and features which can reinstate integrity.
NR staff are available to meet with the public to discuss which of these scenarios will be relevant to their resource and are happy to walk preparers through the submittal process.
The image on left shows unsympathetic alterations which include the addition of a second-floor over the mezzanine area in the main interior public space. The image on right shows the same area after the removal of non-historical material, revealing original features and opening the public space back to its original condition, thus restoring integrity and resulting in a change in eligibility status.
How do I send PA SHPO the information needed to evaluate my property?
Several years ago, PA SHPO has moved to an online submittal for all DOE requests through PA-SHARE. Although there are different subscription levels available, our free Basic account is ideal for property owners who are non-preservation or planning professionals but are interested in listing their property. You will need to be a registered user to submit materials to us – anonymous Guest users don’t have the ability to submit a DOE.
The second part of this National Register series will provide some basic instructions for submitting a DOE request. Our website includes additional information and tutorials to walk an applicant through the online submittal process. Our triage team is also available to answer questions and provide guidance as well. They can be reached at pashare@pa.gov.
What happens after I submit all the information?
Once the DOE submittal has been accepted the NR staff will create an official DOE team, which typically includes four members of the SHPO staff who are chosen for their various expertise based off the type of resource under review.
The team will conduct a complete review of the materials submitted, applying the National Park Service (NPS) National Register Criteria for evaluating resources. The team lead will respond to the applicant within 30 days of the initial submittal with the determination.
The Pennock Sharpless House (PA-SHARE Resource #1999RE00774) was recently listed in the National Register of Historic Places as an owner/historical society-led nomination.
Now that I understand the basics, what do I need to send to PA SHPO?
Next week’s blog post will cover PA SHPO’s recently updated guidance on what information property owners need to compile to request a DOE.
The process and requirements for determining a property eligible for listing in the National Register can be scary and easily spook you if you are not familiar with this preservation tool. PA SHPO’s National Register staff are available to answer questions and provide guidance about DOEs. Next week’s post will provide even more information to demystify the DOE process in Pennsylvania.
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