ESHPF Elevation Guidance

Additional Resources

• ESHPF HPF Online User Guide
• Florence, Yutu, Michael Grant Program
• Harvey, Irma, Maria Grant Program
• Disaster Technical Assistance
• Guidelines on Flood Adaptation

Guidance for Using Emergency Supplemental HPF Grants to Elevate Historic Properties

The use of Emergency Supplemental Historic Preservation Fund (ESHPF) funds to elevate a property is one that requires additional information. In general, other sources of funding may be available for property owners to elevate properties in Federally declared disasters through hazard mitigation grants managed by HUD and FEMA. Depending on the historic character of the property and the proposed change in elevation, elevating the building may be determined to be an adverse effect on the property and could result in its delisting or loss of eligibility for National Register (NR) listing.

Most elevation projects tend to involve buildings and, in order to meet the Secretary's Standards, projects will need to follow the Guidelines on Flood Adaptation for Rehabilitating Historic Buildings.

The National Park Service recognizes that in certain, limited circumstances it may be appropriate to use ESHPF grants to elevate a property as part of a larger rehabilitation project, provided that the work meets the Secretary of the Interior’s Standards for the Treatment of Historic Properties. If grant funding is available from other agencies (HUD or FEMA) for elevating a property, that agency’s funding should be used prior to any ESHPF funding being allocated. If a historic property is not eligible for any other sources of federal assistance for elevation/lifting because the property is in a disaster-declared county where hazard mitigation funds were not made available, the State Historic Preservation Office (SHPO)/Tribal Historic Preservation Office (THPO) should determine if raising the building is the best treatment and is critical for the preservation of the resource, preserves the historic character of the property, meets the Secretary’s Standards, and will retain National Register listing or eligibility.

Review Criteria for Elevating a Historic Resource

The NPS has developed the following criteria/requirements to determine when ESHPF funds may be used to elevate a property.

• There must be a clearly identified threat to the historic property where raising the historic resource is the only option to prevent the complete destruction of the property.
• The historic property must be located in a community that has not received hazard mitigation funds or is not eligible to receive hazard mitigation funds (i.e., there are no other available federal funds to complete this undertaking).
• The change in elevation must be occurring in conjunction with a larger rehabilitation project, it cannot be the only project work the ESHPF grant is funding.
• All project work including raising or elevating must preserve the historic character of the property and the district, if located in a district, and comply with the Secretary of Interior’s Standards for the Treatment of Historic Properties.
• National Register requirements are:
  • If the property is determined ineligible for listing or removed from the National Register of Historic Places (NRHP) as the result of any proposed project work, the grant would not be approved.
  • If a structure listed in or determined eligible for the NRHP is proposed to be elevated, the SHPO/THPO must provide the NPS with advance written notification of the property owner's intention to elevate the building or structure and must request prior written approval from the National Register staff to confirm that the property will retain eligibility as a result of the elevation change. The SHPO/THPO must send the National Register staff all information relating to how the changed elevation will affect the property's integrity and significance, as well as the district if so located. (Additional information, such as photographic mock-ups can be sent along with a description of the new height.)
• In addition to the requirements of the NPS ESHPF grant program and consistent with the prime grant agreement between the SHPO or THPO and the NPS, the project must comply with the typical selection and monitoring requirements that are associated with hazard mitigation grants typically administered by FEMA or HUD. Below are the minimum compliance criteria identified:
  • Elevating or raising a property should only be considered when properties have had repetitive loss issues, which are defined by FEMA as: 1) Two National Flood Insurance Program (NFIP) claims of $1,000 or more in a 10-year period; or 2) Two claims that have resulted in a 25% of market value property loss due to storm damage and an increase in an NFIP compliance coverage;
  • Properties are in the 100-year flood plain;
  • An engineer or architect must certify that the building can be lifted and elevated and a contractor must sign a certificate of completion that the work is in compliance with FEMA’s standards;
  • The ground-floor use must be restricted;
  • The alteration of raising a structure to a new elevation must consider Americans with Disabilities Act and/or Architectural Barriers Act compliance issues (because Federal funds are being used to pay for the project);
  • Flood insurance must be maintained for the life of the structure; and
  • Additional reviews and requirements for any work conducted in a wetland, river area, or a regulated floodway.

Project Documentation and Submission Requirements to the NPS

If a SHPO/ THPO proposes that ESHPF funds be used to elevate a historic property, the following documentation should be submitted in HPF Online prior to the award of any subgrant:

Project Documentation for Properties Listed in the NRHP

• Outline the reasons for elevating the structure, including clearly identifying the threat and document why no other federal assistance is available to this property;
• Discuss the effect of the change in height on the property's NRHP integrity;
• If the work will involve ground disturbance the applicant must note if the area has undergone previously ground disturbance, or if there is the potential to find archeological resources in places where ground disturbance is proposed; and
• Provide photographs showing the proposed location/change to location.

Project Documentation for Properties Deemed Eligible for NRHP Listing

If a SHPO/THPO submits a proposal to elevate a property eligible for listing in the NRHP, they should be prepared to support the determination. Note that the determination of eligibility must have occurred after the disaster event, and consider the current condition of the property. If the building was previously determined eligible by a SHPO/THPO or by a Federal Agency, the current post-disaster condition must be assessed to conclude whether disaster-related damage has diminished the building’s integrity or affected its eligibility for listing in the NRHP.

For properties that have not yet been listed in the NRHP, but have been determined as NRHP-eligible and retain sufficient integrity to be eligible for the NRHP, the SHPO/THPOs should provide the following:

• A brief description of the funded scope of work;
• A brief description of the current condition of the building and surround area and how it will be affected by the project;
• If the project involves a building, the approximate date of construction and dates of alterations (if any). If the building is determined NRHP-eligible, please list the pertinent criteria for eligibility (be sure to include criteria considerations if these are applicable). If the building is considered a contributing resource within a potential NRHP-eligible historic district, define the boundaries of the proposed district (an electronic map or topographic map with the district’s boundaries outlined on the map) and a brief statement of significance. Also, include the district’s Period of Significance (date range);
• A short developmental history of the area should be provided (an encyclopedia-type history) in order to provide some context about the district;
• Identify the Area of Project Effect (APE) for the project by outlining the APE boundary on a map;
• Photographs of the property in question. Should include views of all visible exterior facades or sides of the building (minimum of two images); and
• Photographs of the property’s surroundings such as “streetscape views” to illustrate the property’s geographic context.

As previously stated, for NRHP-listed properties the SHPO/THPO must provide the NPS with advance written notification of the property owner's intention to elevate the building or structure, and must request prior written approval from the Keeper of the National Register to confirm that the property will retain eligibility as a result of the elevation change. To receive this approval, the SHPO/THPO must send the Keeper of the National Register all information relating to how elevating the resource will affect the property's integrity and significance, including the proposed height of the elevation and the foundation materials to be used.

Section 106 of National Historic Preservation Act (NHPA) and National Environmental Policy Act (NEPA) Compliance

In general, HPF grants are not used to fund projects that will result in adverse effects on historic properties pursuant to Section 106 of NHPA. An adverse effect determination under NHPA will require that the SHPO/THPO also perform an Environmental Assessment (EA) pursuant to NEPA (in general, projects that result in adverse effects cannot claim the NEPA “categorical exclusions” under current NEPA guidelines), and enter into a Section 106 Memorandum of Agreement (MOA) to mitigate the adverse effects on historic properties.

Project submission requirements for determining compliance with The Secretary of the Interior’s Standards for the Treatment of Historic Properties

For all projects, whether listed in the National Register or determined eligible for listing, the following items must be made available to SHPO/THPO and NPS staff. Some of these items may have already been provided for the National Register eligibility determination. If already provided, there is no need to provide a second copy.

• A site plan with the North direction clearly marked.
• A map showing the location of the property within the City or County. If the property is located in a district, we would require the district to be delineated on the map.
• Photographs of the property from 4 elevations showing a full view of every façade, streetscape views showing the building in context with nearby structures including detail views showing the foundation. If the property is within a district representative photographs of the district streetscape. Interior photographs of all basement or first floor rooms focusing on the areas related to the grant application, must be included. Photographs must be 3x5 or larger, photographic prints or clear digital images. Digital images must be submitted using the Project Activity Database in HPF Online
• Documentation of the elevation proposal:
  • Existing height of the first floor
  • Narrative description of the work and all proposed changes caused by elevating the structure the proposed new height
  • Elevation drawings showing before and after conditions, photographs marked with new foundation heights, and existing floor plans
  • The treatment of the foundation and how it will be severed and then attache Be sure to include information about materials, finishes, and design details. For example, if a house is currently supported by brick piers and the proposed work includes an enclosed brick foundation, will the design include retention of the visual rhythm of the piers with the foundation wall set along the back edge of the piers or would the foundation appear to be continuous and flat?
  • Note any proposed new entryways and their orientation. We will also require information on the materials to be used for access, for example, if there will be metal or wood stairs, or if there will be a new elevator or ramp.
  • Explain how the new under-story will be utilized or accessed in relationship to the property. With the area be enclosed, and if so with what materials?
  • Any additional information that will better enable a technical review to be completed.