Navigating Florida SHPO Requirements
Understanding State Historic Preservation Office requirements for tax credits, Section 106 review, and historic building projects in Florida.
Types of SHPO Review
Different project types trigger different SHPO review processes.
| Review Type | Triggered By | Timeline | Fee |
|---|---|---|---|
| Federal Historic Tax Credit Review Part 1, Part 2, Part 3 applications through SHPO to NPS | Seeking 20% rehabilitation tax credit for income-producing properties | 30-45 days per part at SHPO; 30 days at NPS | NPS fee based on project cost; no SHPO fee |
| Section 106 Review SHPO consultation on effects to historic properties | Federal funding, permits, or licenses involved | 30 days for determination; longer if adverse effects | No SHPO fee; project may need cultural resource surveys |
| State Tax Credit Review Application through SHPO; similar to federal but state-specific | Seeking Florida historic tax credit | 30-60 days for review | Application fee varies by project cost |
| State-Owned Property Review Consultation similar to Section 106 | State agency undertaking affecting historic properties | 30 days standard review | No fee for state agencies |
| Survey & Inventory Updates SHPO reviews survey forms; determines eligibility | Properties being evaluated for historic significance | 30-60 days depending on complexity | No SHPO fee; survey costs $500-5,000+ |
Historic Tax Credit Application Process
The three-part application process for federal historic tax credits.
Part 1 - Evaluation of Significance
30-45 days at SHPO; 30 days at NPSConfirm property is listed or eligible for National Register
- Photos of all elevations and significant features
- Description of property history and significance
- National Register nomination or eligibility argument
- Location maps and site plans
Tip: Submit Part 1 early; can be filed before ownership
Part 2 - Description of Rehabilitation
30-45 days at SHPO; 30 days at NPSApproval of proposed work under Secretary of Interior Standards
- Detailed description of all proposed work
- Drawings showing existing and proposed conditions
- Material specifications
- Photos of all areas to be affected
Tip: Get Part 2 approval BEFORE starting work; amendments OK but delay
Part 3 - Request for Certification
30-45 days at SHPO; 30 days at NPSConfirm completed work meets approved Part 2
- Photos documenting completed work
- Description of any changes from Part 2
- Final cost certification
- Owner certification
Tip: Must file within 30 months of placed-in-service date
Secretary of the Interior's Standards
The 10 standards that govern historic rehabilitation for tax credit eligibility.
1. Use as Historic Purpose
Use property for historic purpose or compatible new use
Common Issue: Most rehabilitations qualify; document historic use
2. Retain Historic Character
Preserve the historic character of a property
Common Issue: Don't remove or alter distinctive features
3. Recognize Property as Record
Property is a physical record of its time
Common Issue: Don't create false historic appearance
4. Recognize Significant Changes
Changes over time may be significant
Common Issue: Later additions may have acquired significance
5. Preserve Distinctive Features
Preserve distinctive features and craftsmanship
Common Issue: Keep original windows, trim, ornament
6. Repair Rather Than Replace
Repair historic features rather than replace
Common Issue: Document why replacement is necessary
7. Gentle Cleaning Methods
Avoid treatments that damage historic materials
Common Issue: No sandblasting; use gentlest method effective
8. Protect Archaeological Resources
Protect significant archaeological resources
Common Issue: Survey before ground disturbance
9. Compatible New Additions
New additions shall not destroy historic materials
Common Issue: New work should be differentiated but compatible
10. Reversible New Work
New work shall be reversible
Common Issue: Don't make changes that can't be undone
Common Mistakes to Avoid
Pitfalls that can jeopardize your tax credits or project approval.
Starting Work Before Approval
Consequence: Ineligible for tax credits; may need to undo work
Prevention: Get Part 2 approval before construction; document existing conditions
Replacing Instead of Repairing
Consequence: Standards violation; denial of certification
Prevention: Document condition; get SHPO buy-in on replacement necessity
Incompatible New Additions
Consequence: Standards violation; may need to modify or remove
Prevention: Differentiate new work; maintain proportions; use compatible materials
Ignoring Section 106
Consequence: Federal permits/funding delayed or denied
Prevention: Identify federal involvement early; initiate consultation promptly
Missing Deadlines
Consequence: Delays; may lose tax credit eligibility
Prevention: Track all deadlines; file Part 3 within 30 months of placed-in-service
Frequently Asked Questions
Need Help with SHPO Requirements?
FCS has experience guiding projects through SHPO review and tax credit certification. We coordinate with preservation consultants and agencies to keep your project on track.