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Historic Preservation Review: Secretary of Interior Standards and the Architect's Role

How historic preservation review works - the four treatment approaches in the Secretary of Interior Standards, Section 106 review, SHPO and THPO processes, and how historic preservation is tested on the ARE PA exam.

December 28, 2025

Buildings in or Near Historic Districts Require a Different Kind of Design Review

Working with historic buildings and districts requires navigating a regulatory framework that is entirely separate from the building code and zoning systems that govern new construction. The federal, state, and local historic preservation review processes protect the character-defining features of historic resources and ensure that alterations and additions do not damage what makes those resources significant. Architects who work on projects involving historic buildings, historic districts, or sites that may contain significant historic resources must understand the preservation regulatory framework and the design standards that govern work on these properties. The ARE PA exam tests historic preservation as part of the code research and regulatory compliance content area.

The Four Treatment Approaches

The Secretary of the Interior's Standards for the Treatment of Historic Properties establish four treatment approaches that define how an architect may work on a historic building, based on the building's condition, significance, and the owner's program needs:

  • Preservation: The most restrictive approach; focuses on the maintenance and repair of existing historic materials and retention of the building's form. Preservation does not allow reconstruction of lost features or extensive rehabilitation. Appropriate for properties where the existing character-defining features are fully intact and the goal is to maintain them.
  • Rehabilitation: Allows alterations, additions, and new uses while protecting character-defining features. This is the most commonly applied standard for working historic buildings that must adapt to contemporary programs. The Standards for Rehabilitation (the "Standards") are the most frequently referenced and tested of the four approaches.
  • Restoration: Returns a property to its appearance at a specific period of significance, removing features from other periods. Requires documentation of the target period's appearance. Less common than rehabilitation.
  • Reconstruction: Re-creates non-surviving historic buildings or landscapes based on documentary evidence. Requires exceptional justification for the loss of historic fabric.

Section 106 Review

Section 106 of the National Historic Preservation Act (NHPA) requires federal agencies to consider the effects of their undertakings on historic properties before making final decisions. "Federal undertaking" includes projects funded, licensed, or permitted by a federal agency - which covers a very wide range of construction projects (anything with federal funding, federal land, or requiring a federal permit). Section 106 review involves identifying historic properties in the project's area of potential effect, assessing the project's effect on those properties, and consulting with the State Historic Preservation Office (SHPO) or Tribal Historic Preservation Office (THPO) to resolve any adverse effects.

Historic Tax Credits

The federal Historic Tax Credit program provides a 20% income tax credit for qualified rehabilitation expenditures on certified historic structures. This significant financial incentive drives substantial investment in historic preservation of commercial and income-producing properties. To qualify, the project must be on the National Register of Historic Places (or contribute to a National Register Historic District), and the rehabilitation must meet the Secretary of Interior's Standards for Rehabilitation as determined by the SHPO and the National Park Service. The tax credit program has incentivized billions of dollars in historic building rehabilitation across the country.

Key Exam Points

  • Four treatment approaches: preservation (most restrictive), rehabilitation (most common), restoration, reconstruction.
  • Standards for Rehabilitation: allow adaptation of historic buildings for new uses while protecting character-defining features.
  • Section 106: federal review process for undertakings affecting historic properties; involves SHPO consultation.
  • Historic Tax Credit: 20% credit for qualified rehabilitation of certified historic structures meeting the Standards.
  • SHPO: State Historic Preservation Office; primary state-level reviewer for historic preservation matters.

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