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March 25, 2001
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
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.
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
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.
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.
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:
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.
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 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.
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.
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
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.
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)].
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.
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.
- 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.
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.
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.
Keeper of the National Register of Historic Places
Register, History and Education
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