H32(2280)

March 25, 2001

Dear Colleague:

Overall the quality of National Register nominations is high. Although the number of technical errors remains low, we have had to return significant numbers of photographs because of the use of a new generation of products with limited archival stability. This letter provides updates on the current state of technology related to black and white photographs and the increasing popularity of digital images. We are also including some reminders concerning existing technical and regulatory requirements.

Color Processed Black and White Films
Recent changes in the commercial processing of black and white photographs have caused a reduction in the stability of photographs. At issue are new types of black and white film that have been on the market for about three years, the chemical process used to develop this film, and the type of paper on which the photographs are printed. The newer types of black and white films are developed using the chemical method originally designed for color negatives and prints. Black and white films can now be processed on automated equipment that is preloaded with color photographic paper. Even though many photographs often appear to be archivally stable black and whites, they are in fact color-processed and developed on color papers. Color-processed black and white photographs on color paper are not archivally stable and do not meet the requirements outlined in How to Complete the National Register Registration Form and How to Improve the Quality of Photographs for National Register Nominations.

There are often visual clues if black and white film has been color processed. Photographs with hues of green, blue or brown are an indication that the film has been color processed. Color-processed black and white film is also printed on color photographic paper, indicated by the company name and paper type on the back of the photograph. To avoid this problem, film designed exclusively for black and white processing should be used. Many specialty camera stores can advise what films are suitable. When photographs are commercially processed, the film must be developed using a chemical process designed only for black and white film and on black and white photographic paper. Commercial development businesses, which use automated processing equipment, will often send the film to an outside facility that specializes in black and white film development.

Digital images as primary documentation
The continuing rise in the popularity of digital images has raised some questions. Current inks, dyes, and papers used in printing digital photos do not have long-term stability; therefore the National Register is not accepting digital photographs to meet the requirement for stable photographs. Digital images may only be included as supplemental information if they are printed on continuation sheets or black and white photographic paper.

Photo Labeling
Photographs should always be labeled with at least the property name, county, and State. Mark in pencil on the back of the photograph if the paper will accept it (a #1 pencil works best), or in a permanent audio-visual marking pen or pencil. Merely numbering photographs with a key on a continuation sheet is not adequate; if the photos become separated from the nomination file, it may be impossible to determine where they belong.

USGS maps and UTMs
By using the Internet and a color printer, USGS maps can be generated at the desktop. However, the National Register is not accepting printer-generated maps because the scale can be distorted or altered and other information is not always identifiable. Also, as with digital images, these documents do not meet National Register stability standards. Nominations must include original USGS quad maps with the appropriate UTMs plotted. The United States Geological Survey (USGS) offers a website where UTMs can be generated for any point in the world (www.usgs.gov). Software is also available to assist in calculating UTMs.

Nominations Signed by Persons Other than the SHPO or FPO
The National Register must have on file a letter from each state and Federal agency designating persons with the signature authority to sign nominations. When a nomination is signed by someone other than the SHPO or FPO, the National Register must have on file a letter, from the SHPO or FPO, delegating to that person or persons nominating authority. Authorized persons should sign their own name on the nomination form; we cannot accept the SHPO's or FPO's name signed by someone else with their own initials added, even if they have authority to sign on their own.

Nominations of Federal Properties
The process for nominating Federal properties is outlined in 36 CFR 60.9. Regarding comments from the SHPO and notification of the chief elected official, the regulations state:

Completed nominations are submitted to the appropriate State Historic Preservation Officer for review and comment regarding the adequacy of the nomination, the significance of the property and its eligibility for the National Register. The chief elected local officials of the county (or equivalent governmental unit) and municipal political jurisdiction in which the property is located are notified and given 45 days in which to comment.

After receiving the comments of the State Historic Preservation Officer, and chief elected local official, or if there has been no response within 45 says, the Federal Preservation Officer may approve the nomination and forward it to the Keeper of the National Register of Historic Places, National Park Service, United States Department of Interior, Washington, D.C. 20240. The comments of the State Historic Preservation Officer and chief local official are appended to the nomination.

When Federal properties are nominated to the National Register-regardless of the source of the nomination (the State Historic Preservation Office or the Federal agency)--the registration form should include the original signature of both the FPO and the SHPO, if the SHPO has responded in the 45 days. An accompanying letter from either party with an original signature is acceptable, although it is preferable to have the signature on the nomination form.

Inclusion of Federal Building in a Historic District
When historic districts include a federally owned building, the National Register nomination file must include a copy of a letter from the SHPO notifying the appropriate FPO of the nomination and providing the FPO the opportunity to comment. The FPO must be the individual recognized by the Federal agency as authorized to sign nominations. Even if the resource is noncontributing or previously individually listed, the FPO must have the opportunity to comment on the new nomination.

Authorizing Changes to Documentation
Since the nomination form is a legal document, requests for any changes, corrections or additions to the documentation must be signed by the SHPO, FPO, or a designated signer to be valid. This includes any technical changes, such as correcting an address; adding a Multiple Property name, or changing the resource count, as well as any substantive changes or additions. These requests should be printed on continuation sheets that are signed and dated by the SHPO, FPO or a designee.

Boundary Increases/Decreases
Boundary increases and decreases are treated as new nominations, as noted in 36 CFR Part 60.14. Documentation for them is filed separately, and information from them is coded into a separate record in the National Register Information System (NRIS) database. Therefore, when this information is submitted on a nomination form, it is important to specify the information relating only to the boundary increase or decrease area, particularly for the physical characteristics of the resource, e.g., the resource count, functions, verbal boundary description, acreage, and UTM points. (UTMs should relate to the area of increase or decrease -only). If the boundary increase or decrease is submitted as part of an overall nomination amendment intended to supersede the old nomination, which also includes new information relating to the original nomination, information that relates only to the boundary increase or decrease area should be described separately from additional documentation for the originally listed area (if possible, on separate continuation sheets for filing purposes). For example, if a resurvey finds more resources in the original listing as well as the addition of those in the boundary increase area, please provide a new resource count for the original listing and a separate resource count for the boundary increase area. Acreage and UTMs should be provided for the boundary increase area only.

In addition, according to the National Historic Preservation Act of 1966, as amended [Section 101(a)(1)] and National Register regulations [36 CFR 60.15(b) and 15(a)(1)], properties listed prior to December 13, 1980, can be removed from the Register only if they have ceased to meet the Criteria for Evaluation because the qualities which caused them to be originally listed have been lost or destroyed. In this connection, no portion of these "grandfathered" National Register properties can be removed from the National Register as part of a boundary reduction unless it has lost the qualities that caused the properties to be originally listed.

Previously-listed Resources
When a nomination includes resources previously listed in the National Register, it is helpful to list those properties separately, either on a separate continuation sheet for Section 5 or at the beginning of the Section 7 text. Each previously listed property should be identified by the name under which it was listed, the Multiple Property Submission name if applicable, and the resource count for each property. This will help in verifying our records and ensuring that resource counts for all the properties are accurate in the NRIS database.

Listing a Previously Determined Eligible Historic District
For the National Register to list a district previously determined eligible because a majority of private owners objected, the SHPO must obtain a list of current owners to determine who has a right to concur or object and what number constitutes a majority of private property owners. The state must then send owners individual written notices informing them that the state is polling property owners to determine if the status of the doe/owner objection designation should be changed to listed in the National Register. The letter must inform those owners who had previously objected by notarized letter that their original objection stands unless another notarized letter is received removing their objection. The letter should include the same statement outlining the effects of National Register listing as is required for all pending nominations. The state should send a draft of this letter to the National Register for review and approval before notification begins.

Defining Property Owners
The National Register regulations [36CFR Part 60.3(k)] define owner or owners as "those individuals, partnerships, corporations, or public agencies holding fee simple title to the property." The owners of individual units in a condominium hold fee simple title to their property and therefore are considered owners under the notification provisions of the National Register regulations. Those individuals participating in a co-operative are part of a corporation and do not hold fee simple title. Owners of record must be shown in the official land recordation or tax records, as required under 36 CFR Part 60.6. Each owner of private property in a district has one vote regardless of how many properties or what part of one property that party owns and regardless of whether the property contributes to the significance of the district [36 CFR Part 60.6(g)].

Restricting Address Information
To restrict information on the location or character of a resource, place an "X" in the "Not for Publication" box in the Location Section of the National Register standard registration form. At the beginning of the Description Section, briefly explain the reason for the restriction, including the nature of the threat, and specify what, if any, information about character is to be restricted in addition to location.

These procedures apply to both nominations and determinations of eligibility submitted on standard registration forms. Determinations of eligibility that are not submitted on standard registration forms should include the phrase "Not for publication" near the resource's address. An explanation of the restriction and whether it applies to character as well as location and ownership should be included in the resource's description.

When preparing National Register forms, bear in mind that all references to sensitive information will be omitted from reproductions, including photocopies and microfiche. Information intended to be restricted should be compiled on a separate Continuation Sheet and marked with a heading "Restricted Information." Addresses and specific locations should also not appear in the Resource Name (for example, "House at 604 Main St.") since the Resource Name must be published in the Federal Register. Following these suggestions will not only make it simpler and quicker to exclude restricted information from reproductions, but it will ensure that all the appropriate, and only the appropriate, information is withheld from general distribution.

In practice, most information restrictions for National Register documentation are initiated by the nominating authority. The Keeper of the National Register, however, can restrict information under the conditions listed above, even if the nominating authority has not checked "Not for Publication" on the registration form. This policy applies to all National Register documentation, including that recorded on pre-1974 registration forms, which did not have "Not for Publication" indicators. For all incoming nominations, the nominating authority will be notified of the Keeper's decision to restrict information before the resource is listed in the National Register, by means of a Supplementary Listing Record.

Miscellaneous Technical Issues

• Please provide a cover or transmittal letter with all nominations and related actions. The cover letter should specify all relevant information, whether it is a nomination, owner objection, resubmission, boundary increase or decrease, removal or additional documentation. A checklist of transmitted items is also acceptable in lieu of a cover letter.
  
  
• The use of labels on maps and photographs is not acceptable. Labels are not stable and will eventually fall off, and the glue is acidic, which may damage documentation.
  
  
• Site maps and other information should fit in a standard 8 ½ x 11 file folder. Excessively large maps are difficult to use, copy and store. These maps also take a large amount of room, and since the National Register is continually expanding, file space has become a major issue.
  
  
• For districts containing resources that fall under the Criteria Considerations (e.g., churches, moved buildings, etc.), it is not necessary to check the Criteria Considerations if the resources are not predominant features of the district. For example, a large district with a handful of churches does not need Criteria Consideration A; however, a district established as a religious community with a dominant church still extant would have to meet the exception requirements. (See National Register Bulletin: How to Apply National Register Criteria for Evaluation, pp 25-41, for examples under each Criteria Consideration.)
  
  
• When recording historic and current resource functions in Section 7, be sure to include functions and subfunctions for all significant contributing resources such as outbuildings for farms, plantations, and similar resources.
  
  
• It is easy to overlook the small boxes in Section 3. The recommended level of significance of the resource, which is one of these items, is frequently missing from nominations. Often a nomination becomes a determination of eligibility request after the receipt of a majority of private property owner objections, yet the box for nomination remains checked. Please ensure that these boxes, as well as all of Section 3, are accurately completed.
  
  
• Presentation is always important. Please be sure to check for spelling and editing errors. Since the nominations are frequently copied and sent out to a wide variety of individuals and organizations, it is important to catch these and correct them. Sometimes seemingly minor typographical errors make substantive changes in meaning.

We appreciate the overall high quality of National Register nominations. We hope the information in this letter will make listing faster and more efficient, as well as improve the value of the documentation for future use. If you have any questions or if we can provide further information, please contact your National Register reviewer.

Sincerely,

Carol D. Shull
Keeper of the National Register of Historic Places
National Register, History and Education

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