Agenda packet, regular meeting — San Mateo City Council, April 20, 2026 (part 2 of 3)

The 1989 survey was a methodical, citywide effort conducted in alignment with standard historic preservation practices, evaluating buildings based on criteria similar to those of the NRHP and the California Register of Historical Resources (CRHR). It involved fieldwork, archival research, completion of site forms, and assessments of architectural, historical, and cultural significance, resulting in a documented list of resources that has served as the de facto basis for project reviews, CEQA compliance, and planning decisions for over three decades.

Designating these results as the official inventory in the draft ordinance would:
 Establish a Clear, Actionable Baseline: The survey's findings provide a ready-made, vetted list that can be integrated into the ordinance's designation procedures. This avoids starting from scratch and aligns with the ordinance's goals of enabling authority, creating a historic preservation commission, and implementing appeals/enforcement mechanisms, as recommended in the May 2025 Historic Preservation Ordinance Research and Analysis Report by Rincon Consultants.
 Enhance Efficiency and Consistency: By codifying the survey as the inventory, the ordinance can streamline reviews for alterations, additions, or demolitions of listed properties, using tools like Secretary of the Interior’s Standards reviews. This builds on the city's existing practices, where the survey already informs evaluations of buildings over 50 years old.  Support Incentives and Public Engagement: An inventory rooted in the 1989 survey facilitates access to programs like the Mills Act for property tax relief, encouraging owners to maintain historic properties. It also promotes public awareness and tourism, as seen in other California cities (e.g., Los Angeles' Survey LA, which evolved from older surveys into a dynamic inventory).

This approach treats the survey not as a static document but as the core of a tiered system, allowing for future additions or refinements through nomination processes outlined in the draft. 398 of 605

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Flaws in Not Including Identified Resources in the Inventory Excluding the 200+ resources identified in the 1989 survey from the draft ordinance's inventory would undermine the city's preservation framework and expose valuable heritage to unnecessary risks. Key flaws include:
 Loss of Protection for Known Assets: Without formal inclusion, these buildings—many of which meet NRHP and/or CRHR eligibility criteria—could face unregulated alterations or demolitions, especially given new housing laws, such as AB 130 and SB 79(see below). Since 1989, some surveyed structures have already been lost, as noted in community discussions (e.g., letters in the San Mateo Daily Journal highlighting the disappearance of buildings and the need to reassess value). This creates gaps in coverage, particularly for underrepresented histories or architectural styles, leading to irreversible cultural erosion.  Inconsistency with Legal and Policy Obligations: The current ordinance (Chapter 27.66 of the San Mateo Municipal Code) already relies on the survey for applicability to individually eligible buildings and district contributors. Omitting it from the draft would create discrepancies, potentially violating CEQA requirements for evaluating impacts on historic resources during project reviews. It could also conflict with the General Plan's historic elements, fostering perceptions of arbitrariness and eroding public trust, as criticized in the 2025 Rincon report for the ordinance's outdated dependencies.
 Inefficient Resource Allocation and Missed Opportunities: Not incorporating the survey may mislead developers. Including the resources would result in evaluations on a case-by-case basis, when resources are threatened. Lack of a complete inventory risks losing resources, could delay developments, increase costs for property owners, and overlook incentives like tax credits, ultimately weakening the ordinance's effectiveness in balancing preservation with economic development.

In essence, exclusion would render the draft ordinance less protective than the existing ordinance.

Including the resources in the inventory is proactive, protecting tangible resources that have defined San Mateo's identity since the survey's adoption.

Why It Is Acceptable to Use the 1989 Survey Findings
While the 1989 survey is now 37 years old, its age does not invalidate its utility as a foundational inventory, especially in a resource-constrained environment. Historic preservation best practices, as endorsed by the National Trust for Historic Preservation and California's Office of Historic Preservation, emphasize that older surveys remain valid baselines because historical significance is enduring— buildings' architectural integrity, associations with events or persons, and cultural value do not "expire." Here's why proceeding with this data is not only okay but strategically sound:
 Better Than No Inventory at All: In the absence of funding for a full resurvey, including the historic resources identified in the 1989 survey provides immediate protections and a structured starting point. Many California municipalities, such as those in San Francisco County or smaller Bay Area cities, successfully rely on surveys from the 1970s or 1980s as inventories, updating them incrementally through project-driven evaluations or grants.  Flexible Mechanisms for Evolution: The draft ordinance can incorporate provisions for selective updates, such as staff-level reviews for minor changes, nomination processes for new resources, or periodic reconciliations (e.g., every 5-10 years as funds allow). The 2025 Rincon report supports this by recommending exemptions for minor work and alignment with CRHR 399 of 605

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criteria, allowing the inventory to adapt without a complete overhaul. For example, when a planning application triggers a review, targeted assessments can refine the survey's data at no extra city cost.
 Cost-Effective Prioritization: With limited budgets, focusing on high-priority resources (e.g., the 200 identified in 1989) maximizes impact. This avoids the "paralysis by analysis" of waiting for new funding, which could delay the ordinance's implementation. Incentives like the Mills Act can offset owner concerns, and community partnerships can support volunteer-driven updates, as seen in other jurisdictions facing similar fiscal challenges.  Precedent and Legal Soundness: State guidelines allow the use of existing surveys in local inventories, provided they meet basic evaluation standards. The 1989 survey's methodology, rooted in professional historic assessments, meets this threshold, and its integration into the General Plan since adoption reinforces its legitimacy. The 1989 survey was approved by the State Office of Historic Preservation in 1990. Delaying including the resources while waiting for a survey update risks further losses, as evidenced by post-1989 demolitions, making proactive use of available data the ethical choice.

Greater Risks from New Housing Laws
The biggest elevation in risk comes from recent laws exempting many urban infill housing projects from CEQA review:
 AB 130 (2025) creates a broad statutory CEQA exemption for qualifying infill housing (up to certain sizes, consistent with zoning/objective standards, etc.). CEQA is the primary mechanism for identifying and mitigating effects on historic resources.  Exemptions generally exclude projects demolishing historic structures listed on national, state, or local registers before the preliminary application (or specific dates like Jan 1, 2025, in SB 79).

If the city excludes the historic resources identified in 1989 (contrary to identification in the city’s General Plans and policies(, they would have no protection.  With SB 79, unlisted eligible resources (not yet designated or inventoried) would fall outside these safeguards. CEQA traditionally required assessing eligibility for California Register listing, even if not formally listed, and mitigating substantial adverse changes.  With CEQA bypassed, there's no mandatory environmental review to flag or mitigate impacts on unlisted historic buildings. Ministerial/streamlined approvals can proceed faster, increasing demolition/alteration risk for older structures not yet surveyed or designated.

Other laws (e.g., refinements to SB 9 lot splits in AB 1061) expand ministerial approvals but limit exemptions to contributing structures in historic districts or designated resources—again, unlisted/eligible ones may not trigger protections.

Conclusion
Designating the historic resources identified in the 1989 Historic Building Survey Report as the San Mateo Historic Resources Inventory is a pragmatic, defensible step that honors the city's heritage while accommodating fiscal realities. It transforms a valuable but aging document into a living tool for preservation, ensuring San Mateo's historic fabric endures for future generations. The historic resources in San Mateo, identified in 1989, may be lost through streamlined project reviews if the resources are not listed on the local inventory.
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Comments on Draft Historic Preservation Ordinance
Dear Planning Commissioners,
My understanding is that you will be reviewing the draft ordinance, and I wanted to share a few observations that may assist your review and recommendations to the Council. I expect to raise many of these points directly with the Council as well, but if you find merit in any of them, your perspective will carry greater weight than mine alone. I appreciate your time in reviewing this.

Before getting into specific sections, there are two broader issues that affect multiple parts of the ordinance and would benefit from clarification.

1. Consistency of Terminology: “Resource,” “Property,” and “District” The ordinance uses the terms “resource,” “property,” and “district” throughout, but they do not appear to be used consistently. This creates confusion in how different provisions apply.

At the federal level, the term “property” includes all resource types, including districts (i.e., buildings, structures, sites, objects, and districts). It is unclear whether the ordinance intends to adopt that same definition or use a narrower meaning. A few examples are noted below, but the entire document should be reviewed for consistency on how these terms are used.

2. Council Authority and Consent – Clarifying Policy Intent If the Council already has the authority to designate by resolution, then it is unnecessary to restate that authority in the ordinance? Doing so could create confusion by implying that the authority is limited to the parameters described in the ordiance.

Suggestion 1: Clarify if Council has the authority to create resources by resolution outside the ordinance.

Suggestion 2: Clarify if the Council wishes to retain the right to designate by resolution without consent.

Suggestion 3: Consider adding a consent requirement within the ordinance, for any resources designated by resolution.

3. Ambiguity in “Designation by Resolution”
Building on the terminology issue noted above, the ordinance provides that the City Council may include in the Historic Resources Inventory: “properties listed in the National Register of Historic Places or California Register of Historical Resources… by resolution.” (Section 27.66.030(c)).

If council already has this power, this provision can be removed.

Given the ambiguity mentioned above around the term “properties,” clarity would help whether this provision applies to a) Individual properties only, or b) Entire districts. Also clarify if consent is part of the resolution process.

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Point of reference: even if a majority of Baywood objects to its national listing, and it is found “eligible”, it will automatically be listed on the state register. If so, then Baywood could be determined to be part of the local inventory, by council resolution, under this provision of the proposed ordinance.

4. Landmark vs. District Pathway – Unintended Overlap
As noted above regarding terminology, the ordinance defines “historic resource” to include districts, while landmark designation procedures apply to “resources” (Section 27.66.060). This creates a potential overlap where a district could be designated through the landmark pathway.

Further, only a simple majority is needed for landmarks.

Suggestion 1: Clarify whether districts can be landmarked.

Suggestion 2: For landmarks in general, consider a 60% threshold for consent, for consistency with council guidance on districts.

5. Clarifying Scope: CEQA vs. Local Ordinance
The ordinance indicates that its provisions apply only to resources listed in the local Historic Resources Inventory, however it does not explicitly exclude other resources (state and federal).

Those other resources might be governed de-facto under the ordinance.

Suggestion: Consider clarifying that resources not included in the local inventory are governed under applicable state law (including CEQA), and not by this ordinance, to provide clarity for the public and staff.

6. Establishing Significance – Clarifying the Two-Step Framework Preservation practice, reflected in guidance from the National Park Service (National Register Bulletin 15), follows a two-step evaluation process, even if it is not always described in those exact terms. Bulletin 15 explains that properties must first be evaluated within a defined historic context and shown to be significant within that context. The criteria are then applied to determine how the property is significant, and integrity is evaluated to determine whether the property conveys that significance.

Step 1 – Establish Significance (Context): What is the historic context? Is the resource meaningfully important within that context?
Step 2 – Apply Criteria and Integrity: Does the resource meet one or more of the criteria (A, B, C, or D)? Does it retain integrity sufficient to convey that significance? The criteria are not intended to operate as a standalone checklist—they are applied after significance is established. The current draft appears to rely solely on whether a resource

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Comments on Draft Historic Preservation Ordinance
“satisfies one or more of the criteria,” without explicitly requiring a threshold determination of significance (Section 27.66.040). For a more detailed explanation, see addendum.

Suggested clarification: “The City Council shall first determine that the resource has significant historical, architectural, or cultural value to the community, and shall find that the historic resource satisfies one or more of the criteria outlined below, and retains its historic integrity.”
Note, there seems to be considerable confusion (including for me) on this fine point, please consider very clear language in the ordinance.

7. Time Limits for District Nominations
The ordinance does not establish a defined timeline for processing district nominations (Section

27.66.070). Open-ended processes can: a) Prolong uncertainty for property owners, and b) Allow consent efforts to extend indefinitely. Consider establishing a defined timeline (e.g., 6–12 months), including milestones and expiration if deadlines are not met.

8. “Eligible Historic Resource” Definition
The inclusion of “Eligible Historic Resource” may introduce ambiguity and expand review beyond formally designated resources (Section 27.66.020(h)). Not clear why this section is in the ordinance. Consider removing this definition or explaining its inclusion (not referenced elsewhere).

9. Application Requirements for District Nominations
There is currently little clarity regarding what constitutes a complete application—particularly for historic districts (Section 27.66.070). Given the significance of district designation, it is important that applications include: a) A clear historic context statement, and b) Property-level documentation sufficient to evaluate integrity and contribution The City may wish to consider referencing National Register nomination standards and forms as a baseline, at least until a local standard is developed, or until the consultant provides a comparable framework. The suggestion is not to require a rigid format, but to ensure a consistent and complete level of analysis is needed before council approves a district.

This concern is practical. How can the Council truly determine significance under the criteria guidelines (Section 27.66.040), and how will staff regulate a district under the Certificate of Appropriateness process (Section 27.66.090), without a complete nomination form.

It does concern me that Glazenwood may be approved without a complete nomination.

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10. Workability of District Regulations
It is important that the regulatory framework remains reasonable and workable in practice, otherwise no one will volunteer to become historic. For example, routine maintenance activities that would typically be ministerial may instead require a Certificate of Appropriateness (Section

27.66.090). Depending on how broadly this is applied, that may be overly rigid.

In addition, it has been suggested that requirements for contributors within districts may be as stringent as those for individually designated properties. The Commission may wish to consider whether that level of equivalency is intentional, or whether a more flexible approach is appropriate for districts.

I ask that the planning commission give significant thought to finding the right balance between preservation and flexibility, to the extent that can be accomplished in the ordinance, and making the appropriate recommendation to staff/council.

Frank Elliott
Addendum: Illustrative Examples of the Two-Step Significance Framework This has been a difficult concept for me to fully grasp, so I used AI to help work through the distinction. Below is a simplified explanation and a couple of examples that helped clarify how this is intended to work.

The key point is that there are really two separate questions: first, whether a property is actually significant within a defined historic context, and second, how that significance is expressed through the criteria. The criteria are not meant to operate as a standalone checklist.

Example 1: 1950s Ranch Home (easier case)
Take a typical 1950s ranch home. Under the current draft language, the analysis could go straight to Criterion (c): the home “embodies the distinctive characteristics” of a 1950s ranch. If it retains its basic form, it could qualify on that basis alone. The result is that an ordinary tract home could be designated simply because it fits the category.

Under the two-step approach, the first question is whether that home is actually important within a defined context, such as post-war suburban development in San Mateo. If it is just one of many similar homes, not especially early, intact, or distinctive, then it is not significant within that context and the analysis stops there. Only if the home is shown to be an important or representative example, such as an early build, highly intact, or associated with a notable

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architect, does it move to the second step, where the criteria and integrity are applied. At that point, designation may be appropriate.

Example 2: Tudor Revival Home (less obvious case)
A Tudor-style home is a bit more subtle, because there is often an assumption that it is inherently significant. Using a criteria-only approach, the home could qualify simply because it represents a recognized architectural style.

Under the two-step framework, the same initial question applies: is this particular Tudor significant within its context? If it is one of many similar homes, modest in design, or altered over time, it may not rise to the level of significance, even though it clearly reflects the style. On the other hand, if it is a high-quality, well-preserved example, associated with a notable architect, or part of a cohesive and historically important grouping, then it may meet the threshold for significance. Only after that determination is made should the criteria and integrity be applied.

Without that first step, the criteria can unintentionally function as a checklist that allows ordinary examples of common building types to qualify.

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From: Carol Gillman
Sent: Tuesday, April 7, 2026 1:35 PM
To: City Council (San Mateo) <[email protected]> Cc: Doug D'Anna ; Marty Gillman Alysha Gillman
Subject: Glazenwood Residents in favor of affirming Historic District by 77% Dear Members of the City Council,
In a decision like this, the most important principle is that outcomes should reflect the will of those directly affected.

It is very important to our family, including our grown children who hope to live here after we are gone, to preserve the history and charm of our small enclave of architecturally beautiful homes. The data from within Glazenwood is clear. A verified 77% of homeowners (28 of 36) support the designation, and based on direct neighborto-neighbor outreach, that number is expected to surpass 80% by April 20.

While outside perspectives may be submitted, they are not rooted in living here day to day. The residents themselves have spoken with unusual clarity: At the January 21st meeting, at the community meeting with the Mayor, our council member Lisa DiazNash, and staff, and through our signed petition. We certainly appreciated the meeting and being able to express in person how special our small historic district is to its residents.

We have done construction twice on our home, and we were enthusiastic about preserving the nature of the home and fitting in with the charm of the neighborhood. Yet, we were able to make the interior more livable for modern life while preserving some of the beautiful moldings etc. We found no downside to considering our remodel and addition part of a historic district.

This is a rare level of consensus. We ask that you recognize it and affirm our historic district on April 20.

Warmest Regards,
Carol Gillman
(And Marty & Alysha Gillman)
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From: Martin McTaggart
Sent: Tuesday, April 7, 2026 12:31 PM
To: Zachary Dahl; Sung H. Kwon; Joanna Winter Somer Smith Cc: Alex Khojikian Christina Horrisberger
Subject: FW: Glazenwood - affirming a historic district Kindly see the below public comment, please include with the agenda report.

Best wishes,
Martin
From: Aida Kedefors
Sent: Tuesday, April 7, 2026 12:01 PM
To: City Council (San Mateo) <[email protected]>; Clerk <[email protected]> Subject: Glazenwood - affirming a historic district
Dear Members of the City Council,
A verified 77% of homeowners in Glazenwood support the designation of our district as historic.

Perspectives outside of the district may try to influence your decision but they do not live here. As a resident of Glazenwood, I ask that you consider the will of those in our neighborhood and approve the historic designation on April 20th.

Thank you.

Aida Kedefors
San Mateo
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From: JOHN SAVAGE
Sent: Tuesday, April 7, 2026 3:08 PM
To: City Council (San Mateo) <[email protected]> Subject: The continuous designation of Glazenwood as a City Historic Neighborhood When I purchased my home in Glazenwood in 2005, I was intrigued with its historic significance of my chosen purchase as I have always been a history buff.

The designation is significant, meaningful, and appropriate for the area like no other in the City.

The pillars that once enhanced the property of the estate of Alvinsa Hayward still remain to remind its residents and the city of the uniqueness of the neighborhood.

We look forward to seeing that designation reaffirmed as scheduled on April 20.

John Savage
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From: marc schellenberg
Sent: Tuesday, April 7, 2026 12:55 PM
To: City Council (San Mateo) <[email protected]> Cc: marc schellenberg
Subject: Glazenwood Residents Speak: 77% Support Affirming a Historic District Dear Members of the City Council,
In a decision like this, the most important principle is that outcomes should reflect the will of those directly affected.

The data from within Glazenwood is clear. A verified 77% of homeowners (28 of 36) support the designation, and based on direct neighbor-to-neighbor outreach, that number is expected to surpass 80% by April 20.

This is a rare level of consensus. We ask that you recognize it and affirm our historic district on April 20.

Sincerely,
Marc Schellenberg
San Mateo
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From: brenda litwin
Sent: Wednesday, April 8, 2026 11:42 AM
To: City Council (San Mateo) <[email protected]> Subject: Glazenwood Historic Designstion
Dear city council,
I have lived in my house at for 30 years and definitely support our historic designation. We are a very special close knit caring neighborhood group. We look out for each other, help one another, and have a neighborhood contact list with which we share interesting information.

Enclosed is a picture of the plaque on the Pillar at the corner of Rosewood and 9th Avenue. This plaque to me shows the city how proud we Glazenwood residents are of our neighborhood.

Because the pillars designating the entrances of Laurel, Hayward, and Rosewood were in horrible shape back in 2009 our neighbors bonded together and organized a repair committee. Neighbors who were able to each personally contributed funds to repair and repaint these historic pillars dating back to the Peninsula Hotel. Some neighbors used their wood working skills and handyman skills while the rest of us formed painting parties on different weekends for each street. When completed the plaques were installed. Many of the original repair crew still live in Glazenwood.

Some of the residents have changed but the spirit of our neighborhood has not. New residents fit right in because everyone cares and we look out for each other.

Thank you,
Brenda Litwin
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From: Gregory ZINKL
Sent: Wednesday, April 8, 2026 3:03 PM
To: City Council (San Mateo) <[email protected]> Cc: [email protected]; Clerk <[email protected]>; Martin McTaggart <[email protected]>
Subject: Glazenwood Designation: Completing the Council's January 2026 Direction Dear Mayor and Members of the City Council,
I am writing to respectfully request that the curative designation resolution for Glazenwood be brought forward and adopted before the Historic Preservation Ordinance vote. I am a Glazenwood resident who is incredibly proud of our new city (arrived August 2025) and much of the rich history and architectural significance of San Mateo and Glazenwood.

At the January 26, 2026 study session, the Council gave clear direction: the Glazenwood documentation gap should be resolved through a curative resolution, and that resolution should be in place before the new ordinance framework — including its owner-consent requirements — goes into effect. That direction reflected a sound distinction. Glazenwood is not a neighborhood seeking new designation. It is a neighborhood whose long-established status was inadvertently left without a corresponding resolution in the City's records. Two General Plans, the California Register (Glazenwood Residential Historic District, California Office of Historic Preservation Built Environment Resource Directory, OTIS ID 411749, evaluation date January 1989), and over 35 years of city communications have consistently treated Glazenwood as a designated historic district, as documented in coverage of the January 26 study session and confirmed by Council members' own statements at that meeting.

Tom (Braham) and I bought our home at in part relying on the representations in the public record (including web searches and cross-checking with reputable news sources) that Glazenwood is a historic district. We have made, and will continue to make, renovation and investment decisions accordingly. To ignore the previous assertions and allow the new, not yet approved, statute to apply retroactively to Glazenwood — a neighborhood whose historic status has been formally acknowledged by the City for over 35 years — would be to effectively impose a regulatory rollback on property owners who made purchasing decisions in reliance on the City's own representations. I understand that in California, courts have recognized that property owners may have cognizable interests in regulatory frameworks they relied upon at the time of purchase. The City should not place itself in the position of having created that exposure.

Fairness requires that the process match the circumstances. The new consent threshold is an appropriate safeguard for new designations proposed over the objection of property owners. It was not designed — and should not be applied — to neighborhoods whose historic status predates the current policy discussion by three decades.

Completing the January 26 direction before the ordinance vote is the straightforward, equitable path. I urge the Council to follow through on their direction, including acting such that the resolution would be binding before the new ordinance framework is put in place, and to do it without any further delay.

I appreciate your service - thank you.

Sincerely,
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Gregory Zinkl
San Mateo, California 94401
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From: deborah athens
Sent: Wednesday, April 8, 2026 7:29 AM
To: City Council (San Mateo) <[email protected]> Subject: Glazenwood Residents Speak: 77% Support Affirming a Historic District Dear Members of the City Council,
In a decision like this, the most important principle is that outcomes should reflect the will of those directly affected. The Glazenwood community is a clear example of a rare level of consensus. We ask that you recognize this and to affirm our historic district on a final vote on April 20.

While outside perspectives may be submitted, they are not rooted in living here day to day. The residents themselves have spoken with unusual clarity on multiple occasions, including: the January 21st meeting; the community meeting with the Mayor, our council member Lisa Diaz-Nash, and staff; and through our signed petition.

Please honor this and re-affirm our historic district on April 20.

Most sincerely,
Deborah & Thomas Athens, 30-year Glazenwood homeowners
San Mateo
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From: wayne feinstein
Sent: Thursday, April 9, 2026 5:59 AM
To: [email protected] <[email protected]> Cc: l ; City Council (San Mateo)
<[email protected]>
Subject: Comments for San Mateo Planning Commission Meeting April 14, 2026

Members of the Commission:

Regrettably, I am unable to join the meeting next week, but I do want to offer comments on the draft Historic Preservation Ordinance you’ll consider that evening.
*Expand the extremely limited 2026 Historic Resources Inventory that excludes many known significant resources (including the Yoshiko Yamanouchi House District, Glazenwood Historic District, circa 1865 Japanese-American Community Center on South Claremont, Japanese Gardeners Association Hall on East 5th Avenue, San Mateo Masonic Lodge).
*Reduce the onerous and inequitable process for adding properties or districts— only property owners can initiate, with high costs and a 60% owner support threshold
*Include development review procedures for properties not on the limited inventory—otherwise, there is no evaluation or protection for demolition, additions, or major alterations on most older buildings *Provide clear definition and authority for the Historic Resources Commission *Provide meaningful economic incentives and a clear process for the Mills Act program
*Include economic penalties for noncompliance (the Draper Building/Benjamin Franklin Hotel has been out of compliance with their permits for 2 years with unpermitted mechanical equipment on the roof)
*Make the ordinance consistent with state and federal best practices and the 2040 General Plan
Thank you for your consideration to these proposed improvements to the draft you are now considering.
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Wayne Feinstein
Wayne Feinstein
San Mateo, CA 94402
--
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NATIONAL REGISTER

BULLETIN
Technical information on the the National Register of Historic Places:
survey, evaluation, registration, and preservation of cultural resources U.S. Department of the Interior
National Park Service
Cultural Resources
National Register, History and Education
How to Apply the National Register
Criteria for Evaluation
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The mission of the Department of the Interior is to protect and provide access to our Nation's natural and cultural heritage and honor our trust responsibilities to tribes.

The National Park Service preserves unimpaired the natural and cultural resources and values of the National Park System for the enjoyment, education, and inspiration of this and future generations. The Park Service cooperates with partners to extend the benefits of natural and cultural resource conservation and outdoor recreation throughout this country and the world.

This material is partially based upon work conducted under a cooperative agreement with the National Conference ofState Historic Preservation Officers and the U.S. Department of the Interior.

Date of publication: 1990; revised 1991, 1995, 1997. Revised for Internet 1995.

Cover
(Top Left) Criterion B - Frederick Douglass Home, Washington, D.C. From 1877- 1899, this was the home of Frederick Douglass, the former slave who rose to become a prominent author, abolitionist, editor, orator, and diplomat. (Walter Smalling, Jr.) (Top Right) Criterion D - Francis Canyon Ruin, Blanco vicinity, Rio Arriba County, New Mexico. A fortified village site composed of 40 masonry-walled rooms arranged in a cluster of four house blocks. Constructed ca. 1716-17 42 for protection against raiding Utes and Comanches, the site has information potential related to Navajo, Pueblo, and Spanish cultures. (Jon Samuelson) (Bottom Left) Criterion C - Bridge in Cherrytree Township, Venago County, Pennsylvania. Built in 1882, this Pratt through truss bridge is significant for engineering as a well preserved example of a type of bridge frequently used in northwestern Pennsylvania in the late 19th century. (Pennsylvania Department of Transportation) (Bottom Right) Criterion A - Main Street/Market Square Historic District, Houston, Harris County, Texas. Until well into the 20th century this district marked the bounds of public and business life in Houston. Constructed between the 1870s and 1920s, the district includes Houston's municipal and county buildings, and served as the city's wholesale, retail, and financial center. (Paul Hester) 418 of 605

PREFACE
Preserving historic properties as
important reflections of our American
heritage became a national policy
through passage of the Antiquities
Act of 1906, the Historic Sites Act of
1935, and the National Historic Preservation Act of 1966, as amended.

The Historic Sites Act authorized the
Secretary of the Interior to identify
and recognize properties of national
significance (National Historic Landmarks) in United States history and archeology. The National Historic
Preservation Act of 1966 authorized
the Secretary to expand this recognition to properties of local and State significance in American history, architecture, archeology, engineering, and culture, and worthy of preservation. The National Register of Historic Places is the official list of these recognized properties, and is maintained and expanded by the National Park Service on behalf of the Secretary
of the Interior. 1
The National Register of Historic
Places documents the appearance and
importance of districts, sites, buildings, structures, and objects significant in our prehistory and history.

These properties represent the major
patterns of our shared local, S_tate,
and national experience. To guide the
selection of properties included in the
National Register, the National Park
Service has developed the National
Register Criteria for Evaluation.

These criteria are standards by which
every property that is nominated to
the National Register is judged. In
addition, the National Park Service
has developed criteria for the recognition of nationally significant properties, which are designated National Historic Landmarks and prehistoric
and historic units of the National Park
System. Both these sets of criteria
were developed to be consistent with
the Secretary of the Interior's Standards and Guidelines for Archeology and Historic Preservation, which are uniform, national standards for preservation activities. 2 This publication explains how the
National Park Service applies these
criteria in evaluating the wide range
of properties that may be significant
in local, State, and national history.

It should be used by anyone who
must decide if a particular property
qualifies for the National Register of
Historic Places.

Listing properties in the National
Register is an important step in a nationwide preservation process. The responsibility for the identification,
initial evaluation, nomination, and
treatment of historic resources lies
with private individuals, State historic
preservation offices, and Federal preservation offices, local governments, and Indian tribes. The final evaluation and listing of properties in the National Register is the responsibility
of the Keeper of the National Register.

This bulletin was prepared by staff
of the National Register Branch, Interagency Resources Division, National Park Service, with the assistance of the
History Division. It was originally issued in draft form in 1982. The draft was revised into final form by Patrick
W. Andrus, Historian, National Register, and edited by Rebecca H.

Shrimpton, Consulting Historian.

Beth L. Savage, National Register
and Sarah Dillard Pope, National Register, NCSHPO coordinated the latest revision of this bulletin. Antionette J.

Lee, Tanya Gossett, and Kira Badamo
coordinated earlier revisions.
1Properties listed in the National Register receive limited Federal protection and certain benefits. For more information concerning the effects of listing, and how the National Register may be used by the general public and Certified Local Governments, as well as by local, State, and Federal agencies, and for copies of National Register Bulletins, contact the National Park Service, National Register, 1849 C Street, NW, NC400, Washington, D.C., 20240. Information may also be obtained by visiting the National Register Web site at www.cr.nps.gov/nr or by contacting any of the historic preservat10n offices m the States and territories.
'The Secretary of the Interior's Standards and Guidelines for Archeology and Historic Preservation are found in the Federal Register, Vol. 48, No. 190 (Thursday, September 29, 1983). A copy can be obtained by writing the National Park Service, Heritage Preservation Services (at the address above). 419 of 605

TABLE OF CONTENTS
Preface .......................................................................................................................................................................................... i I. Introduction ................................................................................................................................................................................. 1 II. National Register Criteria for Evaluation ............................................................................................................................. 2 III. How to Use this Bulletin to Evaluate a Property ................................................................................................................. 3 IV. How to Define Categories of Historic Properties ................................................................................................................ 4 Building ......................................................................................................................................................................................... 4 Structure ........................................................................................................................................................................................ 4 Object ......................................................................................................................................................................................... 5 Site ......................................................................................................................................................................................... 5 District ......................................................................................................................................................................................... 5 Concentration, Linkage, & Continuity of Features ........................................................................................................ 5 Significance .......................................................................................................................................................................... 5 Types of Features ................................................................................................................................................................ 5 g~;~~{i;~~~s 8~¥s~~~;!~~:::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::

V. How to Evaluate a Property Within its Historfc Context ................................................................................................... 7 Understanding Historic Contexts ............................................................................................................................................. 7 How to Evaluate a Property Within Its Historic Context ..................................................................................................... 7 Properties Significant Within More Than on Historic Context ................................................................................... 9 Comparing Related Properties .......................................................................................................................................... 9 Local, State, and National Historic Contexts .......................................................................................................................... 9 VI. How to Identify the Type of Significance of a Property .................................................................................................. 11 Introduction ................................................................................................................................................................................ 11 Criterion A: Event ..................................................................................................................................................................... 12 Understanding Criterion A ............................................................................................................................................. 12 Jy~! ~~t:!~~s~.::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::

Association of the Property with the Events ......................................................................................................... 12 Significance of the Association ................................................................................................................................ 12 Traditional Cultural Values ..................................................................................................................................... 13 Criterion B: Person ................................................................................................................................................................... 14 Comparison to Related Properties .......................................................................................................................... 15 Association with Groups .......................................................................................................................................... 15 Association with Living Persons ............................................................................................................................. 16 Association with Architects/ Artisans .................................................................................................................... 16 Native American Sites ............................................................................................................................................... 16 ii 420 of 605
Distinctive Characteristics of Type, Period, and Method of Construction .............................................................. 18 Historic Adaptation of the Original Property .............................................................................................................. 19 Works of a Master ............................................................................................................................................................. 20 Properties Possessing High Artistic Values .................................................................................................................. 20 Criterion D: Information Potential ........................................................................................................................................ 21 Understanding Criterion D ................................................................................................................................................. 21 Applying Criterion D ........................................................................................................................................................... 21 Archeological Sites ..................................................................................................................................................... 21 Buildings, Structures, and Objects .......................................................................................................................... 21 Association with Human Activity .......................................................................................................................... 22 Establishing a Historic Context ............................................................................................................................... 22 Developing Research Questions .............................................................................................................................. 22 Establishing the Presence of Adequate Data ......................................................................................................... 23 Integrity ....................................................................................................................................................................... 23 Partly Excavated or Disturbed Properties ............................................................................................................. 23 Completely Excavated Sites ..................................................................................................................................... 24 VII. How to Apply the Criteria Considerations ......................................................................................................................... 25 Introduction ................................................................................................................................................................................ 25 Criteria Consideration A: Religious Properties ................................................................................................................... 26 Understanding Criteria Consideration A ...................................................................................................................... 26 Applying Criteria Consideration A ............................................................................................................................... 26 Eligibility for Historic Events .................................................................................................................................. 26 Eligibility for Historic Persons ................................................................................................................................. 27 Eligibility for Architectural or Artistic Distinction .............................................................................................. 28 Eligibility for Information Potential ....................................................................................................................... 28 Ability to Reflect Historic Associations .................................................................................................................. 28 Criteria Consideration B: Moved Properties ........................................................................................................................ 29 Understanding Criteria Consideration B ...................................................................................................................... 29 Applying Criteria Consideration B ................................................................................................................................ 29 Eligibility for Architectural Value ........................................................................................................................... 29 Eligibility for Historic Associations ........................................................................................................................ 30 Setting and Environment .......................................................................................................................................... 30 Association Dependent on the Site ......................................................................................................................... 30 Properties Designed to Be Moved ........................................................................................................................... 31 Artificially Created Groupings ................................................................................................................................ 31 Portions of Properties ................................................................................................................................................ 31 Criteria Consideration C: Birthplaces and Graves .............................................................................................................. 32 Understanding Criteria Consideration C ...................................................................................................................... 32 Applying Criteria Consideration C ................................................................................................................................ 32 Persons of Outstanding Importance ....................................................................................................................... 32 Last Surviving Property Associated with a Person .............................................................................................. 32 Eligibility for Other Associations ............................................................................................................................ 33 Criteria Consideration D: Cemeteries ................................................................................................................................... 34 Understanding Criteria Consideration D ...................................................................................................................... 34 Applying Criteria Consideration D ............................................................................................................................... 34 Persons of Transcendent Importance ..................................................................................................................... 34 Eligibility on the Basis of Age .................................................................................................................................. 35 Eligibility for Design ................................................................................................................................................. 35 Eligibility for Association with Events ................................................................................................................... 35 Eligibility for Information Potential ....................................................................................................................... 35 Integrity ....................................................................................................................................................................... 36 National Cemeteries .................................................................................................................................................. 36 Criteria Consideration E: Reconstructed Properties ........................................................................................................... 37 Understanding Criteria Consideration E ...................................................................................................................... 37 Applying Criteria Consideration E ................................................................................................................................ 37 Accuracy of the Reconstruction ............................................................................................................................... 37 Suitable Environment ................................................................................................................................................ 37 Restoration Master Plans .......................................................................................................................................... 38 421 of 605111
Last Surviving Property of a Type ............................................................................................................................... 38 Reconstructions Older than Fifty Years ....................................................................................................................... 38 Criteria Consideration F: Commemorative Properties ...................................................................................................... 39 Understanding Criteria Consideration F .......................................................................................................................... 39 Applying Criteria Consideration F .................................................................................................................................... 39 Eligibility for Design ................................................................................................................................................. 39 Eligibility for Age, Tradition, or Symbolic Value ................................................................................................. 40 Ineligibility as the Last Representative of an Event or Person ........................................................................... 40 Criteria Consideration G: Properties that Have Achieved Significance Within the Past Fifty Years ........................ 41 Understanding Criteria Consideration G ......................................................................................................................... 41 Applying Criteria Consideration G ................................................................................................................................... 42 Eligibility for Exceptional Importance ................................................................................................................... 42 Historical Perspective ................................................................................................................................................ 42 National Park Service Rustic Architecture ............................................................................................................ 42 Veterans Administration Hospitals ........................................................................................................................ 42 Comparison with Related Properties ..................................................................................................................... 42 World War II Properties ........................................................................................................................................... 42 Eligibility for Information Potential ....................................................................................................................... 43 Historic Districts ........................................................................................................................................................ 43 Properties Over Fifty Years in Age, Under Fifty Years in Significance ............................................................ 43 Requirement to Meet the Criteria, Regardless of Age ......................................................................................... 43 VIII. How to Evaluate the Integrity of a Property .............................................................................................................. 44 Introduction ....................................................................................................................................................................... 44 Understanding the Aspects of Integrity ........................................................................................................................ 44 Location ....................................................................................................................................................................... 44 Design .......................................................................................................................................................................... 44 Setting .......................................................................................................................................................................... 44 Materials ...................................................................................................................................................................... 45 Workmanship ............................................................................................................................................................. 45 Feeling .......................................................................................................................................................................... 45 Association .................................................................................................................................................................. 45 Assessing Integrity in Properties .................................................................................................................................... 45 Defining the Essential Physical Features ............................................................................................................... 46 Visibility of the Physical Features ........................................................................................................................... 46 Comparing Similar Properties ................................................................................................................................. 47 Determining the Relevant Aspects of Integrity .................................................................................................... 48 IX. Summary of the National Historic Landmarks Criteria for Evaluation ............................................................... 50 X. Glossary .............................................................................................................................................................................. 53 XI. List of National Register Bulletins ............................................................................................................................... 54 iv 422 of 605
I. INTRODUCTION
The National Register is the
nation's inventory of historic places
and the national repository of documentation on the variety of historic property types, significance, abundance, condition, ownership, needs, and other information. It is the beginning of a national census of historic properties. The National Register Criteria for Evaluation define the scope of the National Register of Historic
Places; they identify the range of resources and kinds of significance that will qualify properties for listing in
the National Register. The Criteria
are written broadly to recognize the
wide variety of historic properties associated with our prehistory and history.

Decisions concerning the significance, historic integrity, documentation, and treatment of properties can be made reliably only when the resource is evaluated within its historic context. The historic context serves as
the framework within which the National Register Criteria are applied to specific properties or property types.
(See Part V for a brief discussion of
historic contexts. Detailed guidance
for developing and applying historic
contexts is contained in National Register Bulletin: How to Complete the National Register Registration Form and National Register Bulletin: How to Complete the National Register Multiple Property Documentation Form )
The guidelines provided here are
intended to help you understand the
National Park Service's use of the Criteria for Evaluation, historic contexts, integrity, and Criteria Considerations,
and how they apply to properties under consideration for listing in the National Register. Examples are provided throughout, illustrating specific circumstances in which properties are
and are not eligible for the National
Register. This bulletin should be used
by anyone who is:
• Preparing to nominate a property
to the National Register,
• Seeking a determination of a
property's eligibility,
• Evaluating the comparable significance of a property to those listed in the National Register, or
• Expecting to nominate a property
as a National Historic Landmark
in addition to nominating it to
the National Register.

This bulletin also contains a summary of the National Historic Landmarks Criteria for Evaluation (see Part IX). National Historic Landmarks are those districts, sites, buildings, structures, and objects designated by the Secretary of the Interior as possessing national significance in
American history, architecture, archeology, engineering, and culture .. Although National Register documentation includes a recommendation about whether a property is significant at the local, State, or national level, the only official designation of
national significance is as a result of
National Historic Landmark designation by the Secretary of the Interior, National Monument designation by
the President of the United States, or
establishment as a unit of the National
Park System by Congress. These
properties are automatically listed in
the National Register.
1 423 of 605
II. THE NATIONAL

EVALUATION

CRITERIA FOR
EVALUATION: 3
The quality of significance in
American history, architecture, archeology, engineering, and culture is present in districts, sites, buildings,
structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association, and:

A. That are associated with events that
have made a significant contribution to the broad patterns of our history; or
B. That are associated with the lives of
persons significant in our past; or
C. That embody the distinctive
characteristics of a type, period, or
method of construction, or that
represent the work of a master, or
that possess high artistic values, or
that represent a significant and
distinguishable entity whose
components may lack individual
distinction; or
D. That have yielded, or may be likely
to yield, information important in
prehistory or history.

CRITERIA
CONSIDERATIONS:

Ordinarily cemeteries, birthplaces,
or graves of historical figures, properties owned by religious institutions or used for religious purposes, structures
that have been moved from their
original locations, reconstructed historic buildings, properties primarily commemorative in nature, and properties that have achieved significance within the past 50 years shall not be
considered eligible for the National
Register. However, such properties
will qualify if they are integral parts of
districts that do meet the criteria or if
they fall within the following categories:
a. A religious property deriving
primary significance from architectural or artistic distinction or historical importance; or
b. A building or structure removed
from its original location but which
is significant primarily for architectural value, or which is the surviving structure most importantly associated with a historic person or
event; or
c. A birthplace or grave of a historical
figure of outstanding importance
if there is no appropriate site or
building directly associated with
his or her productive life; or
d A cemetery which derives its
primary significance from graves
of persons of transcendent importance, from age, from distinctive design features, or from association
with historic events; or
e. A reconstructed building when
accuratelv executed in a suitable
environ~ent and presented in a
dignified manner as part of a
restoration master plan, and when
no other building or structure with
the same association has survived;
or
f. A property primarily commemorative in intent if design, age, tradition, or symbolic value has invested it with its own exceptional significance; or
g. A property achieving significance
within the past 50 years if it is of
exceptional importance.
3The Criteria for Evaluation are found in the Code of Federal Regulations, Title 36, Part 60, and are reprinted here in full. 2 424 of 605
III. HOW TO USE THIS

BULLETIN TO EVALUATE A

PROPERTY
For a property to qualify for the
National Register it must meet one of
the National Register Criteria for
Evaluation by:
• Being associated with an important historic context and • Retaining historic integrity of
those features necessary to convey its significance.

Information about the property
based on physical examination and
documentary research is necessary to
evaluate a property's eligibility for the
National Register. Evaluation of a
property is most efficiently made
when following this sequence:

1. Categorize the property (Part IV).

A property must be classified as
a district, site, building, structure,
or object for inclusion in the
National Register.

2. Determine which prehistoric or
historic context(s) the property
represents (Part V). A property
must possess significance in
American history, architecture,
archeology, engineering, or
culture when evaluated within
the historic context of a relevant
geographic area.

3. Determine whether the property
is significant under the National
Register Criteria (Part VI). This
is done by identifying the links to
important events or persons,
design or construction features,
or information potential that
make the property important.

4. Determine if the property represents a type usually excluded from the National Register (Part VII).

If so, determine if it meets any of
the Criteria Considerations.

5. Determine whether the property
retains integrity (Part VIII).

Evaluate the aspects of location,
design, setting, workmanship, materials, feeling, and association that the property must retain to
convey its historic significance.

If, after completing these steps, the
property appears to qualify for the National Register, the next step is to prepare a written nomination. (Refer to National Register Bulletin: How to
Complete the National Register Registration Form.)
425 of 6053
IV. HOW TO DEFINE

CATEGORIES OF HISTORIC

PROPERTIES
The National Register of Historic
Places includes significant properties,
classified as buildings, sites, districts,
structures, or objects. It is not used to
list intangible values, except in so far
as thev are associated with or reflected by historic properties. The Nation,11 Register does not list cultural events, or skilled or talented individuals, as is done in some countries.

Rather, the National Register is oriented to recognizing physically concrete properties th<1t are relatively fixed in location.

For purposes of National Register
nominations, small groups of properties are listed under a single category, using the primary resource. For example, a city hall and fountain would be categorized by the city hall (building), a farmhouse with two outbuildings would be categorized by the farmhouse (building), and a city park
with a gazebo would be categorized
by the park (site). Properties with
large acreage or a number of resources are usually considered districts. Common sense and reason should dictate the selection of categories.

BUILDING
A building, such as a house, barn,
church, hotel, or similar construction, is created principally to shelter any form of human activity. "Building" may also be used to refer to a historically and functionally related
unit, such as a courthouse and jail or
a house and barn.

Buildings eligible for the National
Register must include all of their basic
structural elements. Parts of buildings, such as interiors, facades, or wings, are not eligible independent of
the rest of the existing building. The
4 whole building must be considered,
and its significant features must be
identified.

If a building has lost any of its basic
structural elements, it is usuallv considered a "ruin" and is categorized as a site.

Examples of buildings include:
administration building
carriage house
clzurclz
city or town hall
courthouse
detached kitchen, barn, and privy
dormitory
fort
garage
hotel
house
library
mill building
office building
post office
school
social hall
shed
stable
store
theater
train station

STRUCTURE
The term "structure" is used to
distinguish from buildings those
functional constructions made usually for purposes other than creating human shelter.

Structures nominated to the
National Register must include all of
the extant basic structural elements.

Parts of structures can not be considered eligible if the whole structure remains. For example, a truss bridge
is composed of the metal or wooden
truss, the abutments, and supporting
piers, all of which, if extant, must be
included when considering the
property for eligibility.

If a structure has lost its historic
configuration or pattern of organization through deterioration or demolition, it is usually considered a "ruin" and is categorized as a site.

Examples of structures include:
aircraft
apiary
automobile
bandstand
boats and ships
bridge
cairn
canal
carousel
corncrib
dam
earthwork
fence
gazebo
grain elevator
highway
irrigation system
kiln
lighthouse
railroad grade
silo
trolley car
tunnel
windmill
426 of 605
OBJECT
The term "object" is used to
distinguish from buildings and
structures those constructions that
are primarily artistic in nature or are
relatively small in scale and simply
constructed. Although it may be, by
nature or design, movable, an object
is associated with a specific setting
or environment.

Small objects not designed for a
specific location are normally not
eligible. Such works include transportable sculpture, furniture, and other decorative arts that, unlike a
fixed outdoor sculpture, do not
possess association with a specific
place.

Objects should be in a setting
appropriate to their significant
historic use, roles, or character.

Objects relocated to a museum are
inappropriate for listing in the National Register.

Examples of objects include:
boundary marker
fountain
milepost
monument
scupturc
statuary
SITE
A site is the location of a significant event, a prehistoric or historic occupation or activity, or a building
or structure, whether standing,
ruined, or vanished, where the
location itself possesses historic,
cultural, or archeological value
regardless of the value of any existing structure.

A site can possess associative
significance or information potential
or both, and can be significant under
any or all of the four criteria. A site
need not be marked by physical
remains if it is the location of a
prehistoric or historic event or pattern
of events and if no buildings, structures, or objects marked it at the time of the events. However, when the
location of a prehistoric or historic
event cannot be conclusively determined because no other cultural materials were present or survive,
documentation must be carefully
evaluated to determine whether the
traditionally recognized or identified
site is accurate.

A site may be a natural landmark
strongly associated with significant
prehistoric or historic events or
patterns of events, if the significance
of the natural feature is well documented through scholarly research.

Generally, though, the National
Register excludes from the definition
of "site" natural waterways or bodies
of water that served as determinants
in the location of communities or
were significant in the locality's
subsequent economic development.

While they may have been "avenues
of exploration," the features most
appropriate to document this significance are the properties built in association with the waterways.

Examples of sites include:
battlefield
campsite
cemeteries significant for information
potential or historic association
ceremonial site
designed landscape
habitation site
natural feature (such as a rock formation)
having cultural significance
petroglyph
rock carving
rock shelter
ruins of a building or structure
shipwreck
trail
village site

DISTRICT
A district possesses a significant
concentration, linkage, or continuity
of sites, buildings, structures, or
objects united historically or aesthetically by plan or physical development.

CONCENTRATION, LINKAGE, &

CONTINUITY OF FEATURES
A district derives its importance
from being a unified entity, even
though it is often composed of a wide
v~rie_ty of resources. The identity of a
d1stnct results from the interrelationship of its resources, which can convey a visual sense of the overall
historic environment or be an arrangement of historically or functional_ly ~elated properties. For example, a d1stnct can reflect one principal
activity, such as a mill or a ranch, or it
can encompass several interrelated
activities, such as an area that includes industrial, residential, or commercial buildings, sites, structures, or objects. A district can also be a grouping of archeological sites
related primarily by their common
components; these types of districts
often will not visually represent a
specific historic environment.

SIGNIFICANCE
A district must be significant, as
well as being an identifiable entity. It
must be important for historical,
architectural, archeological, engineering, or cultural values. Therefore, districts that are significant will
usually meet the last portion of
Criterion C plus Criterion A, Criterion
B, other portions of Criterion C, or
Criterion D.

TYPES OF FEATURES
A district can comprise both
features that lack individual distinction and individually distinctive features that serve as focal points. It
may even be considered eligible if all
of the components lack individual
distinction, provided that the grouping achieves significance as a whole within its historic context. In either
case, the majority of the components
that add to the district's historic
character, even if they are individually undistinguished, must possess integrity, as must the district as a
whole.

A district can contain buildings,
structures, sites, objects, or open
spaces that do not contribute to the
significance of the district. The
nm:1b~r of noncontributing properties
a d1stnct can contain yet still convey
its sense of time and place and
historical development depends on
how these properties affect the
district's integrity. In archeological
districts, the primary factor to be
considered is the effect of any disturbances on the information potential of the district as a whole.
427 of 6055

GEOGRAPHICAL BOUNDARIES
A district must be a definable
geographic area that can be distinguished from surrounding properties by changes such as density, scale,
type, age, style of sites, buildings,
structures, and objects, or by documented differences in patterns of historic development or associations.

It is seldom defined, however, by the
limits of current parcels of ownership,
management, or planning boundaries.

The boundaries must be based upon a
shared relationship among the
properties constituting the district.

DISCONTIGUOUS DISTRICTS
A district is usually a single geographic area of contiguous historic properties; however, a district can
also be composed of two or more
definable significant areas separated
by nonsignificant areas. A
discontiguous district is most appropriate where:
•
•
•
Elements are spatially discrete;
Space between the elements is
not related to the significance of
the district; and
Visual continuity is not a factor
in the significance.

In addition, a canal can be treated
as a discontiguous district when the
system consists of man-made sections
of canal interspersed with sections of
river navigation. For scattered
archeological properties, a
discontiguous district is appropriate
when the deposits are related to each
other through cultural affiliation,
period of use, or site type.

It is not appropriate to use the
discontiguous district format to
include an isolated resource or small
group of resources which were once
connected to the district, but have
since been separated either through
demolition or new construction. For
example, do not use the discontiguous
district format to nominate individual
buildings of a downtown commerical
district that have become isolated
through demolition.

Examples of districts iE,[;lude:
business districts
canal systems
groups of habitation sites
college campuses
estates and farms with large acreage/
numerous properties
industrial complexes
irrigation systems
residential areas
rural villages
transportation networks
rural historic districts
Ordeman-Shaw Historic District, Montgomery, Montgomery County, Alabama.

Historic districts derive their identity from the interrationship of their resources. Part of the defining characteristics of this 19th century residential district in Montgomery, Alabama, is found in the rhythmic pattern of the rows of decorative porches. (Frank L.

Thiermonge, III)
6 428 of 605
V. HOWTOEVALUATEA

PROPERTY WITHIN ITS

HISTORIC CONTEXT

UNDERSTANDING

HISTORIC

CONTEXTS
To qualify for the National Register, a property must be significant; that is, it must represent a significant
part of the history, architecture,
archeology, engineering, or culture of
an area, and it must have the characteristics that make it a good representative of properties associated with that aspect of the past. This section
explains how to evaluate a property
within its historic context.

The significance of a historic
property can be judged and explained
only when it is evaluated within its
historic context. Historic contexts are
those patterns or trends in history by
which a specific occurrence, property,
or site is understood and its meaning
(and ultimately its significance)
within history or prehistory is made
clear. Historians, architectural
historians, folklorists, archeologists,
and anthropologists use different
words to describe this phenomena
such as trend, pattern, theme, or
cultural affiliation, but ultimately the
concept is the same.

The concept of historic context is
not a new one; it has been fundamental to the study of history since the 18th century and, arguably, earlier
than that. Its core premise is that
resources, properties, or happenings
in history do not occur in a vacuum
but rather are part of larger trends or
patterns.

In order to decide whether a
property is significant within its
historic context, the following five
things must be determined:
•
•
•
•
•
The facet of prehistory or history
of the local area, State, or the nation that the property represents; Whether that facet of prehistory
or history is significant;
Whether it is a type of property
that has relevance and importance in illustrating the historic context;
How the property illustrates that
history; and finally
Whether the property possesses
the physical features necessary to
convey the aspect of prehistory
or history with which it is associated.

These five steps are discussed in
detail below. If the property being
evaluated does represent an important aspect of the area's history or prehistory and possesses the requisite
quality of integrity, then it qualifies
for the National Register.

HOW TO EVALUATE

APROPERTY

WITHIN ITS

HISTORIC CONTEXT
Identify what the property represents: the theme(s), geographical limits, and chronological period that
provide a perspective from which to
evaluate the property's significance.

Historic contexts are historical
patterns that can be identified through
consideration of the history of the
property and the history of the surrounding area. Historic contexts may have already been defined in your area
by the State historic preservation office,
Federal agencies, or local governments.

In accordance with the National Register Criteria, the historic context may relate to one of the following:
•
•
•
•
An event, a series of events or activities, or patterns of an area's development (Criterion A); Association with the life of an important person (Criterion B); A building form, architectural style,
engineering technique, or artistic
values, based on a stage of physical
development, or the use of a material or method of construction that shaped the historic identity of an
area (Criterion C); or
A research topic (Criterion D).
4 For a complete discussion of historic contexts, see National Register Bulletin: Guidelines for Completing National Register of Historic Places Registration Forms.
429 of 6057
Determine how the theme of the
context is significant in the history of
the local area, the State, or the
nation.

A theme is a means of organizing
properties into coherent patterns
based on elements such as environment, social/ ethnic groups, transportation networks, technology, or political developments that have
influenced the development of an area
during one or more periods of prehistory or history. A theme is considered significant if it can be demonstrated,
through scholarly research, to be
important in American history. Many
significant themes can be found in the
following list of Areas of Significance
used by the National Register.

AREAS OF SIGNIFICANCE
Agriculture
Architecture
Archeology
Prehistoric
Historic-Aboriginal
Historic-Non-Aboriginal
Art
Commerce
Communications
Community Planning and Development
Conservation
Economics
Education
Engineering
Entertainment/ Recreation
Ethnic Heritage
Asian
Black
European
Hispanic
Native American
Pacific Islander
Other
Explora lion/ Settlement
Health/Medicine
Industry
Invention
Landscape Architecture
Law
Literature
Maritime History
Military
Performing Arts
Philosophy
Politics/Government
Religion
Science
Social History
Transportation
Other
8 Determine what the property type
is and whether it is important in
illustrating the historic context.

A context may be represented by a
variety of important property types.

For example, the context of "Civil
War Military Activity in Northern
Virginia" might be represented by
such properties as: a group of mid19th century fortification structures; an open field where a battle occurred;
a knoll from which a general directed
troop movements; a sunken transport
ship; the residences or public buildings that served as company headquarters; a railroad bridge that served as a focal point for a battle; and
earthworks exhibiting particular
construction techniques.

Because a historic context for a
community can be based on a distinct
period of development, it might
include numerous property types.

For example, the context "Era of
Industrialization in Grand Bav,
Michigan, 1875 - 1900" could be
represented by important property
types as diverse as sawmills, paper
mill sites, salt refining plants, flour
mills, grain elevators, furniture
factories, workers housing, commercial buildings, social halls, schools, churches, and transportation facilities.

A historic context can also be based
on a single important type of property. The context "Development of County Government in Georgia,
1777 - 1861" might be represented
solely by courthouses. Similarly,
"Bridge Construction in Pittsburgh,
1870 - 1920" would probably only
have one property type.

Determine how the property
represents the context through
specific historic associations, architectural or engineering values, or information potential (the Criteria
for Evaluation).

For example, the context of county
government expansion is represented
under Criterion A by historic districts
or buildings that reflect population
growth, development patterns, the
role of government in that society,
and political events in the history of
the State, as well as the impact of
county government on the physical
development of county seats. Under
Criterion C, the context is represented
by properties whose architectural
treatments reflect their governmental
functions, both practically and
symbolically. (See Part VI: How to
Identify the Type of Significance of a
Property.)
Determine what physical features
the property must possess in order
for it to reflect the significance of the
historic context.

These physical features can be
determined after identifying the
following:
• Which types of properties are associated with the historic context, • The ways in which properties can
represent the theme, and
• The applicable aspects of integrity.

Properties that have the defined
characteristics are eligible for listing.
(See Part VIII: How to Evaluate the
Integrity of a Property.)
430 of 605

PROPERTIES SIGNIFICANT

WITHIN MORE THAN ONE

HISTORIC CONTEXT
A specific property can be significant within one or more historic contexts, and, if possible, all of these
should be identified. For example, a
public building constructed in the
1830s that is related to the historic
context of Civil War campaigns in the
area might also be related to the
theme of political developments in the
community during the 1880s. A
property is only required, however, to
be documented as significant in one
context.

COMPARING RELATED

PROPERTIES
Properties listed in the National
Register must possess significance
when evaluated in the perspective of
their historic context. Once the
historic context is established and the
property type is determined, it is not
necessary to evaluate the property in
question against other properties if:
• It is the sole example of a property type that is important in illustrating the historic context or • It clearly possesses the defined
characteristics required to
strongly represent the context.

If these two conditions do not
apply, then the property will have to
be evaluated against other examples
of the property type to determine its
eligibility. The geographic level
(local, State, or national) at which this
evaluation is made is the same as the
level of the historic context. (See Part
V: How to Evaluate a Property Within
Its Historic Context.)

LOCAL, STATE,

AND NATIONAL

HISTORIC

CONTEXTS
Historic contexts are found at a
variety of geographical levels or
scales. The geographic scale selected
may relate to a pattern of historical
development, a political division, or a
cultural area. Regardless of the scale,
the historic context establishes the
framework from which decisions
about the significance of related
properties can be made.

LOCAL HISTORIC

CONTEXTS
A local historic context represents
an aspect of the history of a town,
city, county, cultural area, or region,
or any portions thereof. It is defined
by the importance of the property, not
necessarily the physical location of the
property. For instance, if a property
is of a type found throughout a State,
or its boundaries extend over two
States, but its importance relates only
to a particular county, the property
would be considered of local significance.

The level of context of archeological sites significant for their information potential depends on the scope of the applicable research design. For
example, a Late Mississippian village
site may yield information in a
research design concerning one
settlement system on a regional scale,
while in another research design it
may reveal information of local
importance concerning a single
group's stone tool manufacturing
techniques or house forms. It is a
question of how the available information potential is likely to be used.

STATE HISTORIC

CONTEXTS
Properties are evaluated in a State
context when they represent an aspect
of the history of the State as a whole
(or American Samoa, the District of
Columbia, the Commonwealth of the
Northern Mariana Islands, Guam,
Puerto Rico, or the Virgin Islands).

These properties do not necessarily
have to belong to property types
found throughout the entire State:
they can be located in only a portion
of the State's present political boundary. It is the property's historic context that must be important
statewide. For example, the "cotton
belt" extends through only a portion
of Georgia, yet its historical development in the antebellum period affected the entire State. These State historic contexts may have associated
properties that are statewide or
locally significant representations. A
cotton gin in a small town might be a
locally significant representation of
this context, while one of the largest
cotton producing plantations might
be of State significance.

A property whose historic associations or information potential appears to extend beyond a single local area
might be significant at the State level.

A property can be significant to more
than one community or local area,
however, without having achieved
State significance.

A property that overlaps several
State boundaries can possibly be
significant to the State or local history
of each of the States. Such a property
is not necessarily of national significance, however, nor is it necessarily significant to all of the States in which
it is located.

Prehistoric sites are not often
considered to have "State" significance, per se, largely because States are relatively recent political entities
and usually do not correspond closely
to Native American political territories or cultural areas. Numerous sites, however, may be of significance to a
large region that might geographically encompass parts of one, or usually several, States. Prehistoric
resources that might be of State
significance include regional sites that
provide a diagnostic assemblage of
artifacts for a particular cultural
group or time period or that provide
chronological control (specific dates
or relative order in time) for a series
of cultural groups.
431 of 6059

NATIONAL HISTORIC

CONTEXTS
Properties are evaluated in a
national context when they represent
an aspect of the history of the United
States and its territories as a whole.

These national historic contexts may
have associated properties that are
locally or statewide significant
representations, as well as those of
national significance.

Properties designated as nationally
significant and listed in the National
Register are the prehistoric and
historic units of the National Park
System and those properties that have
been designated National Historic
Landmarks. The National Historic
Landmark criteria are the standards
for nationally significant properties;
they are found in the Code of Federal
10 Regulations, Title 36, Part 65 and are
summarized in this bulletin in Part IX:

Summary of National Historic Landmarks Criteria for Evaluation.

A property with national significance helps us understand the history of the nation by illustrating the
nationwide impact of events or
persons associated with the property,
its architectural type or style, or
information potential. It must be of
exceptional value in representing or
illustrating an important theme in the
history of the nation.

Nationally significant properties
do not necessarily have to belong to a
property type found throughout the
entire country: they can be located in
only a portion of the present political
boundaries. It is their historic context
that must be important nationwide.

For example, the American Civil War
was fought in only a portion of the
United States, yet its impact was
nationwide. The site of a small
military skirmish might be a locally
significant representation of this
national context, while the capture of
the State's largest city might be a
statewide significant representation
of the national context.

When evaluating properties at the
national level for designation as a
National Historic Landmark, please
refer to the National Historic Landmarks outline, History and Prehistory in the National Park System and the
National Historic Landmarks Program
1987. (For more information about
the National Historic Landmarks
program, please write to the Department of the Interior, National Park Service, National Historic Landmarks, 1849 C Street, NW, NC400, Washington, DC 20240.)
432 of 605
VI. HOW TO IDENTIFY THE

TYPE OF SIGNIFICANCE OF A

PROPERTY

INTRODUCTION
When evaluated within its historic
context, a property must be shown to
be significant for one or more of the four
Criteria for Evaluation - A, B, C, or D
(listed earlier in Part II). The Criteria
describe how properties are significant for their association with important events or persons, for their importance in design or construction,
or for their information potential.

The basis for judging a property's
significance and, ultimately, its
eligibility under the Criteria is historic
context. The use of historic context
allows a property to be properly
evaluated in a nearlv infinite number
of capacities. For i~stance, Criterion
C: Design/Construction can accommodate properties representing construction types that are unusual or
widely practiced, that are innovative
or traditional, that are "high style" or
vernacular, that are the work of a
famous architect or an unknown
master craftsman. The ke11 to deternzining whether the clwracteristics or associations of a particular property are significant is to consider the property within its historic context.

After identifying the relevant
historic context(s) with which the
property is associated, the four
Criteria are applied to the property.

Within the scope of the historic
context, the National Register Criteria
define the kind of significance that the
properties represent.

For example, within the context of
"19th Century Gunpowder Production in the Brandywine Valley," Criterion A would apply to those
properties associated with important
events in the founding and development of the industry. Criterion B would apply to tho~e properties
associated with persons who are
significant in the founding of the
industry or associated with important
inventions related to gunpowder
manufacturing. Criterion C would
apply to those buildings, structures,
or objects whose architectural form or
style reflect important design qualities
integral to the industry. And Criterion D would apply to properties that can convey information important in
our understanding of this industrial
process. If a property qualifies under
more than one of the Criteria, its
significance under each should be
considered, if possible, in order to
identify all aspects of its historical
value.

NATIONAL REGISTER

CRITERIA FOR
EVALUATION*
The National Register Criteria
recognize different types of values
embodied in districts, sites, buildings,
structures, and objects. These values
fall into the following categories:

Associative value (Criteria A and
B): Properties significant for their
association or linkage to events
(Criterion A) or persons (Criterion B)
important in the past.

Design or Construction value
(Criterion C): Properties significant
as representatives of the manmade
expression of culture or technology.

Information value (Criterion D):

Properties significant for their ability
to yield important information about
prehistory or history.
*For a complete listing of the Criteria for
Evaluation, refer to PMt II of this bulletin.
433 of 60511
CRITERION A: EVENT
Properties can be eligible for the National Register if they are associated with events that have made a significant contribution to the broad patterns of our history.

UNDERSTANDING
CRITERION A:

EVENT
To be considered for listing under
Criterion A, a property must be
associated with one or more events
important in the defined historic
context. Criterion A recognizes
properties associated with single
events, such as the founding of a
town, or with a pattern of events,
repeated activities, or historic trends,
such as the gradual rise of a port city's
prominence in trade and commerce.

The event or trends, however, must
clearly be important within the
associated context: settlement, in the
case of the town, or development of a
maritime economy, in the case of the
port city. Moreover, the property
must have an important association
with the event or historic trends, and
it must retain historic integrity. (See
Part V: How to Evaluate a Property
Within its Historic Context.)
Several steps are involved in
determining whether a property is
significant for its associative values:
12 • Determine the nature and origin
of the property,
• Identify the historic context with
which it is associated, and
• Evaluate the property's history to
determine whether it is associated with the historic context in any important way.

APPLYING
CRITERION A:

EVENT

TYPES OF EVENTS
A property can be associated with
either (or both) of two types of events:
• A specific event marking an important moment in American prehistory or history and • A pattern of events or a historic
trend that made a significant contribution to the development of a community, a State, or the nation.

Refer to the sidebar on the right for
a list of specific examples.

ASSOCIATION OF THE

PROPERTY WITH THE
EVENTS
The property you are evaluating
must be documented, through accepted means of historical or archeological research (including oral history), to have existed at the time of
the event or pattern of events and to
have been associated with those
events. A property is not eligible if its
associations are speculative. For
archeological sites, well reasoned
inferences drawn from data recovered
at the site can be used to establish the
association between the site and the
events.

SIGNIFICANCE OF THE

ASSOCIATION
Mere association with historic
events or trends is not enough, in and
of itself, to qualify under Criterion A:
the property's specific association
must be considered important as well.

For example, a building historically in
commercial use must be shown to
have been significant in commercial
history.

EXAMPLES OF PROPERTIES

ASSOCIATED WITH EVENTS
Properties associated with specific events:
• The site of a battle.
• The building in which an important
invention was developed.
• A factory district where a significant
strike occurred.
• An archeological site at which a major new aspect of prehistory was discovered, such as the first evidence of man and extinct Pleistocene animals
being contemporaneous.
• A site where an important facet of
European exploration occurred.

Properties associated with a pattern of
events:
• A trail associated with western migration.
• A railroad station that served as the
focus of a community's transportation system and commerce. • A mill district reflecting the importance of textile manufacturing during a given period. • A building used by an important local social organization. • A site where prehistoric Native
Americans annually gathered for
seasonally available resources and
for social interaction.
• A downtown district representing a
town's growth as the commercial focus of the surrounding agricultural area.
434 of 605

TRADITIONAL CULTURAL
VALUES
Traditional cultural significance is
derived from the role a property plays
in a community's historically rooted
beliefs, customs, and practices.

Properties may have significance
under Criterion A if they are associated with events, or series of events, significant to the cultural traditions of
a community. 5
Eligible
• A hilltop associated in oral historical accounts with the founding of an Indian tribe or
society is eligible.
• A rural community can be eligible whose organization, buildings, or patterns of
land use reflect the cultural
traditions valued by its longterm residents.
• An urban neighborhood can
be eligible as the traditional
home of a particular cultural
group and as a reflection of its
beliefs and practices.

Not Eligible
• A site viewed as sacred by a
recently established utopian or
religious community does not
have traditional cultural value
and is not eligible.

Criterion A - The Old Brulay Plantation, Brownsville vicinity, Cameron county, Texas. Historically significant for its association with the development of agriculture in southeast Texas, this complex of 10 brick buildings was constructed by George N.

Brulay, a French immigrant who introduced commercial sugar production and irrigation to the Rio Grande Valley. (Photo by Texas Historical Commission). 5 For more information, refer to National Register Bulletin: Guidelines for Evaluating and Documenting Traditional Cultural Properties. 13 435 of 605
CRITERION B: PERSON
Properties may be eligible for the National Register if they are associated with the lives of persons significant in our past.

UNDERSTANDING
CRITERION B:

PERSON 6
Criterion B applies to properties
associated with individuals whose
specific contributions to history can
be identified and documented .

Persons "significant in our past"
refers to individuals whose activities
are demonstrably important within a
local, State, or national historic
context. The criterion is generally
restricted to those properties that
illustrate (rather than commemorate)
a person's important achievements.
(The policy regarding commemorative properties, birthplaces, and graves is explained further in Part
VIII: How to Apply the Criteria Considerations.)
Several steps are involved in
determining whether a property is
significant for its associative values
under Criterion B. First, determine
the importance of the individual.

Second, ascertain the length and
nature of his/her association with the
property under study and identify the
other properties associated with the
individual. Third, consider the
property under Criterion B, as
outlined below .

EXAMPLES OF PROPERTIES

ASSOCIATED WITH PERSONS
Properties associated with a Significant
Person:
• The home of an important merchant
or labor leader.
• The studio of a significant artist.
• The business headquarters of an important industrialist.

Criterion B - The William Whitney House, Hinsdale, DuPage County, Illinois.

This building is locally significant for its historical association with William Whitney, the founder of the town of Hinsdale, Illinois. Whitney, a citizen of New York State, moved to Illinois, established the town, and while living here between 1870 and 1879 was a prominent local businessman and politician. (Photo by Frederick C. Cue). • For further information on properties eligible under Criterion B, refer to National Register Bulletin: Guidelines for Evalr1ati11g and Dornmenting Properties Associated with Significant Persons.
14 436 of 605

APPLYING
CRITERION B:

PERSON

SIGNIFICANCE OF THE

INDIVIDUAL
The persons associated with the
property must be individually significant within a historic context. A property is not eligible if its only
justification for significance is that it
was owned or used by a person who
is a member of an identifiable profession, class, or social or ethnic group.

It must be shown tha~ the person
gained importance within his or her
profession or group.

Eligible
• The residence of a doctor, a
mayor, or a merchant is eligible under Criterion B if the person was significant in the
field of medicine, politics, or
commerce, respectively.

Not Eligible
• A property is not eligible under Criterion B if it is associated with an individual about whom no scholarly judgement
can be made because either research has not revealed specific information about the person's activities and their
impact, or there is insufficient
perspective to determine
whether those activities or
contributions were historically
important.

ASSOCIATION WITH THE

PROPERTY
Properties eligible under Criterion
B are usuallv those associated with a
person's prdductive life, reflecting the
time period when he or she achieved
significance. In some instances this
may be the person's home; in other
cases, a person's business, office,
laboratory, or studio may best represent his or her contribution. Properties that pre- or post-date an individual's significant accomplishments are usually not eligible. (See Comparison to Related Properties, below,
for exceptions to this rule.)
The individual's association with
the property must be documented by
accepted methods of historical or
archeological research, including
written or oral history. Speculative
associations are not acceptable. For
archeological sites, well reasoned
inferences drawn from data recovered
at the site are acceptable.

COMP ARIS ON TO RELATED

PROPERTIES
Each property associated with an
important individual should be
compared to other associated properties to identify those that best represent the person's historic contributions. The best representatives usually are properties associated with
the person's adult or productive life.

Properties associated with an
individual's formative or later years
may also qualify if it can be demonstrated that the person's activities during this period were historically
significant or if no properties from the
person's productive years survives.

Length of association is an important
factor when assessing several properties with similar associations.

A community or State may contain
several properties eligible for associations with the same important person, if each represents a different aspect of
the person's productive life. A
property can also be eligible if it has
brief but consequential associations
with an important individual. (Such
associations are often related to
specific events that occurred at the
property and, therefore, it may also be
eligible under Criterion A.)

ASSOCIATION WITH
GROUPS
For properties associated with
several community leaders or with a
prominent family, it is necessary to
identify specific individuals and to
explain their significant accomplishments.

Eligible
• A residential district in which a
large number of prominent or
influential merchants, professionals, civic leaders, politicians, etc., lived will be eligible under Criterion B if the significance of one or more specific individual residents is explicitly justified.
• A building that served as the
seat of an important family is
eligible under Criterion B if the
significant accomplishments of
one or more individual family
members is explicitly justified.

Not Eligible
• A residential district in which a
large number of influential persons lived is not eligible under Criterion B if the accomplishments of a specific individual(s) cannot be documented.

If the significance of the district
rests in the cumulative importance of prominent residents, however, then the district
might still be eligible under
Criterion A. Eligibility, in this
case, would be based on the
broad pattern of community
development, through which
the neighborhood evolved into
the primary residential area for
this class of citizens.
• A building that served as the
seat of an important family will
not be eligible under Criterion
B if the significant accomplishments of individual family members cannot be documented. In cases where a succession of family members have lived in a house and collectively have had a demonstrably significant impact on the community, as a family, the
house is more likely to be significant under Criterion A for association with a pattern of
events.
437 of 60515

ASSOCIATION WITH

LIVING PERSONS
Properties associated with living
persons are usually not eligible for
inclusion in the National Register.

Sufficient time must have elapsed to
assess both the person's field of
endeavor and his/her contribution to
that field. Generally, the person's
active participation in the endeavor
must be finished for this historic
perspective to emerge. (See Criteria
Considerations C and G in Part VII:

How to Apply the Criteria Considerations.)

ASSOCIATION WITH

ARCHITECTS/ ARTISANS
Architects, artisans, artists, and
engineers are often represented by
their works, which are eligible under
Criterion C. Their homes and studios,
however, can be eligible for consideration under Criterion B, because these usually are the properties with which
they are most personally associated.

NATIVE AMERICAN SITES
The known major villages of
individual Native Americans who
were important during the contact
period or later can qualify under
Criterion B. As with all Criterion B
properties, the individual associated
with the property must have made
some specific important contribution
to history. Examples include sites
significantly associated with Chief
Joseph and Geronimo.7
7 For more information, refer to National Register Bulletin: Guidelines for Eualuati11g and Documenting Traditional Cultural Properties. 16 438 of 605
CRITERION C:

DESIGN/CONSTRUCTION
Properties may be eligible for the National Register if they embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction.

Richland Plantation, East Feliciana Parish, Louisiana. Properties can qualify under Criterion C as examples of high style architecture. Built in the 1830s, Richland is a fine example of a Federal style residence with a Greek Revival style portico. (Photo by Dave Gleason).

UNDERSTANDING
CRITERION C:

DESIGN/

CONSTRUCTION
This criterion applies to properties
significant for their physical design or
construction, including such elements
as architecture, landscape architecture, engineering, and artwork. To be eligible under Criterion C, a property
must meet at least one of the following
requirements:
• Embody distinctive characteristics of a type, period, or method of construction.
• Represent the work of a master .
• Possess high artistic value.
• Represent a significant and distinguishable entity whose components may lack individual distinction .

The first requirement, that properties "embody the distinctive characteristics of a type, period, or method of construction," refers to the way in
which a property was conceived,
designed, or fabricated by a people or
culture in past periods of history.
"The work of a master" refers to the
technical or aesthetic achievements of
an architect or craftsman. "High
artistic values" concerns the expression of aesthetic ideals or preferences and applies to aesthetic achievement.

Resources "that represent a significant and distinguishable entity whose components may lack individual distinction" are called "districts." In the Criteria for Evaluation (as published
in the Code of Federal Regulations and
reprinted here in Part II), districts are
defined within the context of Criterion C. Districts, however, can be considered for eligibility under all the Criteria, individually or in any combination, as is appropriate. For this reason, the full discussion of districts is contained in Part IV: How to Define
Categories of Historic Properties.

Throughout the bulletin, however,
districts are mentioned within the
context of a specific subject, such as
an individual Criterion.

Grant Family House, Saco vicinity,
York County, Maine. Properties
possessing high artistic value meet
Criterion C through the expression of
aesthetic ideals or preferences. The Grant
Family House, a modest Federal style
residence, is significant for its remarkably
well-preserved stenciled wall decorative
treatment in the entry hall and parlor.

Painted by an unknown artist ca. 1825,
this is a fine example of 19th century New
England regional artistic expression.
(Photo by Kirk F. Mohney).
17 439 of 605

EXAMPLES OF PROPERTIES

ASSOCIATED WITH DESIGN/

CONSTRUCTION
Properties associated with design and
construction:
• A house or commercial building representing a significant style of architecture. • A designed park or garden associated
with a particular landscape design
philosophy.
• A 111ovie theater embodying high artistic value in its decorative features. • A bridge or dam representing technological advances.

APPLYING
CRITERION C:

DESIGN/

CONSTRUCTION

DISTINCTIVE

CHARACTERISTICS OF

TYPE, PERIOD, AND

METHOD OF

CONSTRUCTION
This is the portion of Criterion C
under which most properties are
eligible, for it encompasses all architectural styles and construction practices. To be eligible under this
portion of the Criterion, a property
must clearly illustrate, through
"distinctive characteristics," the
following:
18 • The pattern of features common
to a particular class of resources,
• The individuality or variation of
features that occurs within the
class,
• The evolution of that class, or
• The transition between classes of
resources.

Distinctive Characteristics: "Distinctive characteristics" are the physical features or traits that commonly recur in individual types, periods, or
methods of construction. To be
eligible, a property must clearly
contain enough of those characteristics
to be considered a true representative
of a particular type, period, or method
of construction.

Characteristics can be expressed in
terms such as form, proportion, structure, plan, style, or materials. They can be general, referring to ideas of
design and construction such as basic
plan or form, or they can be specific,
referring to precise ways of combining
particular kinds of materials.

Eligible
• A building eligible under the
theme of Gothic Revival architecture must have the distinctive characteristics that make up the vertical and picturesque
qualities of the style, such as
pointed gables, steep roof
pitch, board and batten siding,
and ornamental bargeboard
and veranda trim.
• A late Mississippian village
that illustrates the important
concepts in prehistoric
community design and planning will qualify.
• A designed historic landscape
will qualify if it reflects a historic trend or school of theory and practice, such as the City
Beautiful Movement, evidencingdistinguished design, layout, and the work of skilled era ftsmanshi p.

Not Eligible
• A commercial building with
some Art Deco detailing is not
eligible under Criterion C if the
detailing was added merely as
an afterthought, rather than
fully integrated with overall
lines and massing typical of the
Art Deco style or the transition
between that and another style.
• A designed landscape that has
had major changes to its historic design, vegetation, original boundary, topography/ grading, architectural features,
and circulation system will not
qualify.

Type, Period, and Method of
Construction: "Type, period, or
method of construction" refers to the
way certain properties are related to
one another by cultural tradition or
function, by dates of construction or
style, or by choice or availability of
materials and technology.

A structure is eligible as a specimen of its type or period of construction if it is an important example (within its context) of building
practices of a particular time in
history. For properties that represent
the variation, evolution, or transition
of construction types, it must be
demonstrated that the variation, etc.,
was an important phase of the architectural development of the area or community in that it had an impact as
evidenced by later buildings. A
property is not eligible, however,
simply because it has been identified
as the only such property ever fabricated; it must be demonstrated to be significant as well.

Eligible
• A building that has some characteristics of the Romanesque Revival style and some characteristics of the Commercial style can qualify if it illustrates
the transition of architectural
design and the transition itself
is considered an important architectural development.
• A Hopewellian mound, if it is
an important example of
mound building construction
techniques, would qualify as a
method or type of construction.
• A building which illustrates
the early or the developing
technology of particular
structural systems, such as
skeletal steel framing, is eligible as an example of a particular method of construction.
440 of 605
Swan Falls Dam and Power Plant, Murphy vicinity, Ada County, Idaho.

Significant works of engineering can qualify under Criterion C. Built between 1900- 1907 the Swan Falls Dam and Power Plant across the Snake River is one of the early hydroelectric plants in the State of Idaho. (Photo by H.L. Hough).

Looney House, Asheville vicinity, St. Clair County, Alabama. Examples of vernacular styles of architecture can qualify under Criterion C. Built ca. 1818, the Looney House is significant as possibly the State's oldest extant two-story dogtrot type of dwelling. The defining open center passage of the dogtrot was a regional building response to the southern climate. (Photo by Carolyn Scott).

HISTORIC ADAPTATION OF

THE ORIGINAL PROPERTY
A property can be significant not
only for the way it was originally
constructed or crafted, but also for the
way it was adapted at a later period,
or for the way it illustrates changing
tastes, attitudes, and uses over a
period of time.

A district is eligible under this
guideline if it illustrates the evolution
of historic character of a place over a
particular span of time.

Eligible
•
•
•
A Native American irrigation
system modified for use by
Europeans could be eligible if
it illustrates the technology of
either or both periods of construction.

An early 19th century farmhouse modified in the 1880s
with Queen Anne style ornamentation could be significant for the modification itself, if it
represented a local variation
or significant trend in building
construction or remodelling,
was the work of a local master
(see Works of a Master on page
20), or reflected the tastes of an
important person associated
with the property at the time·
of its alteration.

A district encompassing the
commercial development of a
town between 1820 and 1910,
characterized by buildings of
various styles and eras, can be
eligible.
19 441 of 605

WORKS OF A MASTER
A master is a figure of generally
recognized greatness in a field, a
known craftsman of consummate
skill, or an anonymous craftsman
whose work is distinguishable from
others by its characteristic style and
quality. The property must express a
particular phase in the development
of the master's career, an aspect of his
or her work, or a particular idea or
theme in his or her craft.

A property is not eligible as the
work of a master, however, simply
because it was designed by a prominent architect. For example, not every building designed by Fran~ Lloy?
Wright is eligible under ~his portion
of Criterion C, although 1t might meet
other portions of the Criterion, for
instance as a representative of the
Prairie style.

The work of an unidentified
craftsman is eligible if it rises above
the level of workmanship of the other
properties encompassed by the
historic context.
20 PROPERTIES POSSESSING

HIGH ARTISTIC VALUES
High artistic values may be expressed in many ways, inch~ding . areas as diverse as community design
or planning, engineering, and sculpture. A property is eligible for its high artistic values if it so fully
articulates a particular concept of
design that it expresses an aesthetic
ideal. A property is not eligible,
however, if it does not express
aesthetic ideals or design concepts
more fully than other properties of its
type.

Eligible
• A sculpture in a town square
that epitomizes the design
principles of the Art Deco style
is eligible.
• A building that is a classic expression of the design theories of the Craftsman Style, such as
carefully detailed handwork,
is eligible.
• A landscaped park that synthesizes early 20th century principles of landscape architecture and expresses an aesthetic ideal of environment can be eligible.
• Properties that are important_
representatives of the aesthetic
values of a cultural group,
such as petroglyphs and
ground drawings by Native
Americans, are eligible.

Not Eligible
• A sculpture in a town square
that is a typical example of
sculpture design during its period would not qualify for high artistic value, although_ it
might be eligible if it were significant for other reasons. • A building that is a modest example (within its historic context) of the Craftsman Style of architecture, or a landscaped
park that is characteristic of
turn of the century landscape
design would not qualify for
high artistic value.

A Significant and Distinguishable
Entity Whose Components May Lack
Individual Distinction. This portion
of Criterion C refers to districts. For
detailed information on districts, refer
to Part IV of this bulletin.
442 of 605
CRITERION D: INFORMATION

POTENTIAL
Properties may be eligible for the National Register if they have yielded, or may be likely to yield, information important in prehistory or history.

UNDERSTANDING
CRITERION D:

INFORMATION

POTENTIAL
Certain important research questions about human history can only be answered by the actual physical
material of cultural resources. Criterion D encompasses the properties that have the potential to answer, in
whole or in part, those types of
research questions. The most common type of property nominated under this Criterion is the archeological si le (or a district comprised of archeological sites). Buildings,
objects, and structures (or districts
comprised of these property types),
however, can also be eligible for their
information potential.

Criterion D has two requirements,
which must both be met for a property
to qualify:
• The property must have, or have
had, information to contribute to
our understanding of human history or prehistory, and
• The information must be considered important.

Under the first of these requirements, a property is eligible if it has been used as a source of data and
contains more, as yet unretrieved
data. A property is also eligible if it
has not yet yielded information but,
through testing or research, is determined a likely source of data.

Under the second requirement, the
information must be carefully evaluated within an appropriate context to determine its importance. Information is considered "important" when it is shown to have a significant
bearing on a research design that
addresses such areas as: I) current
data gaps or alternative theories that
challenge existing ones or 2) priority
areas identified under a State or
Federal agency management plan.

APPLYING
CRITERION D:

INFORMATION

POTENTIAL

ARCHEOLOGICAL SITES
Criterion D most commonly
applies to properties that contain or
are likely to contain information
bearing on an important archeological
research question. The property must
have characteristics suggesting the
likelihood that it possesses configurations of artifacts, soil strata, structural remains, or other natural or cultural
features that make it possible to do
the following:
• Test a hypothesis or hypotheses
about events, groups, or processes in the past that bear on important research questions in the social or natural sciences or the
humanities; or
• Corroborate or amplify currently
available information suggesting
that a hypothesis is either true or
false; or
• Reconstruct the sequence of archeological cultures for the purpose of identifying and explaining continuities and discontinuities in the archeological record for a particular area.

BUILDINGS, STRUCTURES,

AND OBJECTS
While most often applied to
archeological districts and sites,
Criterion D can also apply to buildings, structures, and objects that contain important information. In
order for these types of properties to
be eligible under Criterion D, they
themselves must be, or must have
been, the principal source of the
important information.

Eligible
• A building exhibiting a local
variation on a standard design
or construction technique can
be eligible if study could yield
important information, such as
how local availability of materials or construction expertise affected the evolution of local
building development.

Not Eligible
• The ruins of a hacienda once
contained murals that have
since been destroyed. Historical documentatio~, however, indicates that the murals were
significant for their highly unusual design. The ruins can not be eligible under Criterion
D for the importance of the destroyed murals if the information is contained only in the documentation.
443 of 605 21
Criterion D - Champe-Fremont 1 Archeological Site, Omaha vicinity, Douglas County, Nebraska. This archeological site, dating from ca. 1100-1450 A.D., consists of pit houses and storage pits which have the potential to yield important information concerning the subsistence patterns, religious and mortuary practices, and social organization of the prehistoric residents of eastern Nebraska. (Nebraska State Historical Society)

ASSOCIATION WITH

HUMAN ACTIVITY
A property must be associated with
human activity and be critical for
understanding a site's historic environment in order to be eligible under Criterion D. A property can be linked
to human activity through events,
processes, institutions, design, construction, settlement, migration, ideals, beliefs, lifeways, and other facets of the
development or maintenance of
cultural systems.

The natural environment associated
with the properties was often very
different from that of the present and
strongly influenced cultural development. Aspects of the environment that are pertinent to human activities
should be considered when evaluating
properties under Criterion D.

Natural features and paleontological
(floral and faunal) sites are not usually
eligible under Criterion D in and of
themselves. They can be eligible,
however, if they are either directly
related to human activity or critical to
understanding a site's historic environment. In a few cases, a natural feature or site unmarked by cultural materials,
that is primarily eligible under Criterion A, may also be eligible under Criterion D, if study of the feature, or
its location, setting, etc. (usually in the
context of data gained from other
sources), will yield important information about the event or period with which it is associated.
22 ESTABLISHING A HISTORIC

CONTEXT
The information that a property
yields, or will yield, must be evaluated within an appropriate historic context. This will entail consulting
the body of information already
collected from similar properties or
other pertinent sources, including
modern and historic written records.

The researcher must be able to
anticipate if and how the potential
information will affect the definition
of the context . The information likely
to be obtained from a particular
property must confirm, refute, or
supplement in an important way
existing information.

A property is not eligible if it
cannot be related to a particular time
period or cultural group and, as a
result, lacks any historic context
within which to evaluate the importance of the information to be gained.

DEVELOPING RESEARCH

QUESTIONS
Having established the importance
of the information that may be
recovered, it is necessary to be explicit
in demonstrating the connection
between the important information
and a specific property. One approach is to determine if specific important research questions can be
answered by the data contained in the
property. Research questions can be
related to property-specific issues, to
broader questions about a large
geographic area, or to theoretical
issues independent of any particular
geographic location. These questions
may be derived from the academic
community or from preservation
programs at the local, regional, State,
or national level. Research questions
are usually developed as part of a
"research design," which specifies not
only the questions to be asked, but
also the types of data needed to
supply the answers, and often the
techniques needed to recover the data .

Eligible
• When a site consisting of a village occupation with midden deposits, hearths, ceramics,
and stratified evidence of several occupations is being evaluated, three possible research topics could be: 1) the question of whether the site
occupants were indigenous to
the area prior to the time of occupation or recent arrivals, 2) the investigation of the settlement-subsistence pattern of the occupants, 3) the question
of whether the region was a
center for the domestication of
plants . Specific questions
could include: A) Do the deposits show a sequential development or sudden introduction of Ceramic Type X? B) Do the dates of the occupations fit our expectations based on the current model for the
reoccupation behavior of
slash-and-burn agriculturalists? C) Can any genetic
changes in the food plant remains be detected?
Not Eligible
• A property is not eligible if so
little can be understood about
it that it is not possible to determine if specific important research questions can be answered by data contained in the property.
444 of 605

ESTABLISHING THE

PRESENCE OF ADEQUATE
DATA
To support the assertion that a
property has the data 1:ecessary_ to
provide the important 1~form~hon,
the property should be mveshgate~
with techniques sufficient to estabhsh
the presence of relevant data c~tegories. What constitutes appropriate investigation techniques would
depend upon specific circumstances
including the property's location,
condition, and the research questions
being addressed, and could range
from surface survey (or photographic
survey for buildings), to the application of remote sensing techniques or intensive subsurface testing. Justification of the research potential of a property may be based on anal~gy to
another better known property 1f
sufficient similarities exist to establish
the appropriateness of the analogy.

Eligible
• Data requirements depend on
the specific research topics and
questions to be addressed. To
continue the example in "Developing Research Questions" above, we might want to ascertain the following with reference to questions A, B, and C:

A) The site contains Ceramic
Type X in one or more occupation levels and we expect to be able to document the local
evaluation of the type or its intrusive nature. B) The hearths contain datable carbon deposits
and are associated with more
than one occupation. C) The
midden deposits show good
floral/ fauna! preservation, and
we know enough about the
physical evolution of food
plants to interpret signs that
suggest domestication.

Not Eligible
• Generally, if the applicable research design requires clearly stratified deposits, then subsurface investigation techniques must be applied. A site composed only of surface materials can not be eligible for its potential to yield information that could only be found in stratified deposits.

INTEGRITY
The assessment of integrity for
properties considered for informati_on
potential depends on the data reqmrements of the applicable research design. A property possessing
information potential does not need to
recall visually an event, person,
process, or constructi~n t~~hnique. It
is important that the s1gmficant_ data
contained in the property remam
sufficiently intact to yield the expected important inforf1:ation, if the appropriate study techmques are
employed.

Eligible
• An irrigation system significant for the information it will yield on early engineering
practices can still be eligible
even though it is now filled in
and no longer retains the appearance of an open canal.

Not Eligible
• A plowed archeological site
contains several superimposed
components that have been
mixed to the extent that artifact assemblages cannot be reconstructed. The site cannot be eligible if the data requirements of the research design call for the study of artifacts
specific to one component.

PARTLY EXCAVATED OR

DISTURBED PROPERTIES
The current existence of appropriate physical remains must be ascertained in considering a property's ability to yield important information.

Properties that have been partly
excavated or otherwise disturbed and
that are being considered for their
potential to yield additional important information must be shown to retain that potential in their remaining
portions.

Eligible
• A site that has been partially
excavated but still retains substantial intact deposits (or a site in which the remaining deposits are small but contain critical information on a topic
that is not well known) is eligible.

Not Eligible
• A totally collected surface site
or a completely excavated buried site is not eligible since the physical remains capable of
yielding important information no longer exist at the site. (See Completely Excavated Sites,
on page 24, for exception.)
Likewise, a site that has been
looted or otherwise disturbed
to the extent that the remaining cultural materials have lost their important depositional
context (horizontal or vertical
location of deposits) is not eligible.
• A reconstructed mound or
other reconstructed site will
generally not be considered
eligible, because original cultural materials or context or both have been lost.
445 of 605 23

COMPLETELY EXCAVATED
SITES
Properties that
important information in the past and
that no longer retain additional
research potential (such as completely
excavated archeological sites) must be
assessed essentially as historic sites
under Criterion A. Such sites must be
significant for associative values
related to: 1) the importance of the
data gained or 2) the impact of the
property's role in the history of the
development of anthropology/
archeology or other relevant disciplines. Like other historic properties, the site must retain the ability to
convey its association as the former
repository of important information,
the location of historic events, or the
representative of important trends.
have yielded
24 Eligible
• A property that has been excavated is eligible if the data recovered was of such importance that it influenced the direction of research in the discipline, as in a site that clearly established the antiquity of the
human occupation of the New
World. (See Criterion A in
Part VI: How to Identify the
Type of Significance of a Property
and Criteria Consideration G
in Part VII: How to Apply the
Criteria Considerations.)
Not Eligible
• A totally excavated site that at
one time yielded important information but that no longer can convey either its historic/
prehistoric utilization or significant modern investigation is not eligible.
446 of 605
VII. HOW TO APPLY THE

CRITERIA CONSIDERATIONS

INTRODUCTION
Certain kinds of properties are not
usually considered for listing in the
National Register: religious properties, moved properties, birthplaces and graves, cemeteries, reconstructed
properties, commemorative properties, and properties achieving significance within the past fifty years.

These properties can be eligible for
listing, however, if they meet special
requirements, called Criteria Considerations, in addition to meeting the regular requirements (that is, being
eligible under one or more of the four
Criteria and possessing integrity).

Part VII provides guidelines for
determining which properties must
meet these special requirements and
for applying each Criteria Consideration.

The Criteria Considerations need to
be applied only to individual properties. Components of eligible districts do not have to meet the special
requirements unless they make up the
majority of the district or are the focal
point of the district. These are the
general steps to follow when applying
the Criteria Considerations to your
property:
• Before looking at the Criteria
Considerations, make sure your
property meets one or more of
the four Criteria for Evaluation
and possesses integrity.
• If it does, check the Criteria Considerations (next column) to see if the property is of a type that is
usually excluded from the National Register. The sections that follow also list specific examples
of properties of each type. If
your property clearly does not fit
one of these types, then it does
not need to meet any special requirements.
• If your property does fit one of
these types, then it must meet the
special requirements stipulated
for that type in the Criteria Considerations.

CRITERIA
CONSIDERATIONS*
Ordinarily cemeteries, birthplaces,
or graves of historical figures, properties owned by religious institutions or used for religious purposes, structures
that have been moved from their
original locations, reconstructed
historic buildings, properties primarily commemorative in nature, and properties that have achieved significance within the past fifty years shall not be considered eligible for the
National Register. However, such
properties will qualify if they are
integral parts of districts that do meet
the criteria or if they fall within the
following categories:
a. a religious property deriving primary significance from architectural or artistic distinction or historical importance; or b. a building or structure removed
from its original location but
hich is significant primarily for
rchitectural value, or which is
the surviving structure most imortantly associated with a historic person or event; or w
a
p
c. a birthplace or grave of a historical figure of outstanding importance if there is no appropriate site or building directly associated with his or her productive life; or
d. a cemetery which derives its primary significance from graves of persons of transcendent importance, from age, from distinctive design features, from association
with historic events; or
e. a reconstructed building when
accurately executed in a suitable
environment and presented in a
dignified manner as part of a restoration master plan, and when no other building or structure
with the same association has
survived; or
f. a property primarily commemorative in intent if design, age, tradition, or symbolic value has invested it with its own exceptional significance; or,
g. a property achieving significance
within the past 50 years if it is of
exceptional importance.
*The Criteria Considerations are taken from
the Criteria for Evaluation, found in the Code of
Federal Reg11latious, Title 36, Part 60.
25 447 of 605
CRITERIA CONSIDERATION A:

RELIGIOUS PROPERTIES
A religious property is eligible if it derives its primary significzince from architectural or artistic distinction or historiczil importzince.

UNDERSTANDING

CRITERIA

CONSIDERATION
A: RELIGIOUS

PROPERTIES
A religious property requires
justification on architectural, artistic,
or historic grounds to avoid any
appearance of judgment by government about the validity of ziny religion or belief. Historic significance for a religious property cannot be
established on the merits of a religious doctrine, but rather, for architectural or artistic values or for important historic or cultural forces
that the property represents. A
religious property's significance
under Criterion A, B, C, or D must be
judged in purely secular terms. A
religious group may, in some cases,
be considered a cultural group whose
activities are significant in areas
broader than religious history.

Criteria Consideration for Religious Properties applies:
26 • If the resource was constructed
by a religious institution.
• If the resource is presently
owned by a religious institution
or is used for religious purposes.
• If the resource was owned by a
religious institution or used for
religious purposes during its Period of Significance.
• If Religion is selected as an Area
of Significance.

Examples of Properties that MUST
Meet Criteria Co11sidemtion A: Religious Properties
• A historic church where r.11 important 11011-rcligio11s e,1e11t occurred, such as a spccclz /Jy Patrick Henry.
• A historic synagogue that is sig11ifica11t for architecture. • A pri'rntc residence is the site of a
111ecti11g important to religious lzistory.
• A co111111ercial block that is rnrrentlt;
owned as a11 i11vest111e11t property b:\j
a religious i11stitutio11.
• A historic district i11 wlziclz rcligio11
was eitlzer a predo111ina11t or significant fu11ctio11 duri11g the period of sig11ifica11cc.

Example of Properties that DO NOT
Need to Meet Criteria Consideration
A: Religious Properties
• A residential or commercial district
that rnrrently co11tai11s a smal/ 11111
ber of clrnrclzes that are not a predo111ina11t feature of the district. • A town meeting hall that serves as
the center of comm1111ity activity and
houses a wide variety of public
and priuate meetings, including religio11s service. The resource is significant for architecture and politics, and the religious f1111ction is incidental.
• A town hall, significant for politics
from 1875 to 1925, that housed
religious services during the 1950s.

Since the religio11s function occurred
after the Period of Significance, the
Criteria Consideration does not apply.

APPLYING

CRITERIA

CONSIDERATION
A: RELIGIOUS

PROPERTIES

ELIGIBILITY FOR HISTORIC
EVENTS
A religious property can be eligible
under Criterion A for any of three reasons:
• It is significant under a theme in
the history of religion having
secular scholarly recognition; or
• It is significant under another historical theme, such as exploration, settlement, social philanthropy, or education; or • It is significantly associated with
traditional cultural values.
448 of 605

RELIGIOUS HISTORY
A religious property can be eligible
if it is directly associated with either a
specific event or a broad pattern in the
history of religion.

Eligible
• The site of a convention at
which a significant denominational split occurred meets the requirements of Criteria Consideration A. Also eligible is a property that illustrates the
broad impact of a religious institution on the history of a local area.

Not Eligible
• A religious property cannot be
eligible simply because was
the place of religious services
for a community, or was the
oldest structure used by a religious group in a local area.

OTHER HISTORICAL
THEMES
A religious property can be eligible
if it is directly associated with either a
specific event or a broad pattern that
is significant in another historic
context. A religious property would
also qualify if it were significant for
its associations that illustrate the
importance of a particular religious
group in the social, cultural, economic, or political history of the area.

Eligibility depends on the importance
of the event or broad pattern and the
role of the specific property.

Eligible
• A religious property can
qualify for its important role
as a temporary hospital during
the Revolutionary War, or if its
school was significant in the
history of education in the
community.

Not Eligible
• A religious property is not significant in the history of education in a community simply because it had occasionally
served as a school.

TRADITIONAL CULTURAL
VALUES
When evaluating properties
associated with traditional cultures, it
is important to recognize that often
these cultures do not make clear
distinctions between what is secular
and what is sacred. Criteria Consideration A is not intended to exclude traditional cultural resources merely
because they have religious uses or
are considered sacred. A property or
natural feature important to a traditional culture's religion and mythology is eligible if its importance has been ethnohistorically documented
and if the site can be clearly defined.

It is critical, however, that the activities be documented and that the associations not be so diffuse that the
physical resource cannot be adequately defined. 8
Eligible
• A specific location or natural
feature that an Indian tribe believes to be its place of origin and that is adequately documented qualifies under Criteria Consideration A.

ELIGIBILITY FOR HISTORIC

PERSONS
A religious property can be eligible
for association with a person important in religious history, if that significance has scholarly, secular
recognition or is important in other
historic contexts. Individuals who
would likely be considered significant
are those who formed or significantly
influenced an important religious
institution or movement, or who were
important in the social, economic, or
political history of the area. Properties associated with individuals important only within the context of a
single congregation and lacking
importance in any other historic
context would not be eligible under
Criterion B.

Eligible
• A religious property strongly
associated with a religious
leader, such as George
Whitefield or Joseph Smith, is
eligible.
8 For more information on applying Criteria Consideration A to traditional cultural properties, refer to National Register Bulletin: Guidelines for Evaluating and Documenting Traditional Cultural Properties.
27 449 of 605

ELIGIBILITY FOR

ARCHITECTURAL OR

ARTISTIC DISTINCTION
A religious property significant for
its architectural design or construction should be evaluated as are other properties under Criterion C; that is,
it should be evaluated within an
established architectural context and,
if necessary, compared to other
properties of its type, period, or
method of construction. (See "Comparing Related Properties" in Part V:

How to Evaluate a Property Within Its
Historic Context.)
Eligible
• A historic camp meeting district that meets the requirements of Criterion C for its significance as a type of construction is eligible.

ELIGIBILITY FOR

INFORMATION POTENTIAL
A religious property, whether a
district, site, building, structure, or
object, is eligible if it can yield important information about the religious practices of a cultural group or other
historic themes . This kind of property
should be evaluated as are other
properties under Criterion D, in
relation to similar properties, other
information sources, and existing data
gaps.

Eligible
• A 19th century camp meeting
site that could provide information about the length and intensity of site use during revivals of the Second Great Awakening is eligible.
• Rock cairns or medicine
wheels that had a historic religious mythological function and can provide information
about specific cultural beliefs
are eligible.

Criteria Consideration A - Religious Properties. A religious property can qualify as an exception to the Criteria if it is architecturally significant. The Church of the Navity in Rosedale, Iberville Parish, Louisiana, qualified as a rare example in the State of a 19th century small frame Gothic Revival style chapel. (Robert Obier) 28 ABILITY TO REFLECT

HISTORIC ASSOCIATIONS
As with all eligible properties,
religious properties must physically
represent the period of time for which
they are significance . For instance, a
recent building that houses an older
congregation cannot qualify based on
the historic activit ies of the group
because the current building does not
convey the earlier history. Likewi se,
an older building that housed the
historic activities of the congregation
is eligible if it still physically represents the period of the congregation's significance. However, if an older
building has been remodeled to the
extent that its appearance dates from
the time of the remodeling, it can only
be eligible if the period of significance
corresponds with the period of the
alterations .

Eligible
• A church built in the 18th century and altered beyond recognition in the 19th century is eligible only if the additions
are important in themselves as
an example of late 19th century architecture or as a reflection of an important period of the congregation 's growth.

Not Eligible
• A synagogue built in the 1920s
cannot be eligible for the important activities of its congregation in the 18th and 19th centuries. It can only be eligible for significance obtained after its construction date .
• A rural 19th century frame
church recently sheathed in
brick is not eligible because it
has lost its characteristic appearance and therefore can no longer convey its 19th century
significance, either for architectural value or historic association . 450 of 605
CRITERIA CONSIDERATION B:

MOVED PROPERTIES
A property removed from its original or historically significant location can be eligible if it is significant primarily for architectural value or it is the surviving property most importantly associated with a historic person or event.

UNDERSTANDING

CRITERIA

CONSIDERATION
B:MOVED

PROPERTIES
The National Register criteria limit
the consideration of moved properties
because significance is embodied in
locations and settings as well as in the
properties themselves. Moving a
property destroys the relationships
between the property and its surroundings and destroys associations with historic events and persons. A
move may also cause the loss of
historic features such as landscaping,
foundations, and chimneys, as well as
loss of the potential for a~sociated
archeological deposits. Properties
that were moved before their period of
significance do not need to meet the
special requirements of Criteria
Consideration B.

One of the basic purposes of the
National Register is to encourage the
preservation of historic properties as
living parts of their communities. In
keeping with this purpose, it is not
usual to list artificial groupings of
buildings that have been created for
purposes of interpretation, protection,
or maintenance. Moving buildings to
such a grouping destroys the integrity
of location and setting, and can create
a false sense of historic development.

APPLYING

CRITERIA

CONSIDERATION
B: MOVED

PROPERTIES

ELIGIBILITY FOR

ARCHITECTURAL VALUE
A moved property significant
under Criterion C must retain enough
historic features to convey its architectural values and retain integrity of design, materials, workmanship,
feeling, and association.

Examples of Properties that MUST
Meet Criteria Consideration B:

Moved Properties
• A resource moued from one location
011 its original site to mzotlzcr location on tlze property, during or after its Period of Significance.
• A district in wlziclz a significant
number of resources lzaue been
moved from their original location.
• A district wlziclz has one moved
building that makes an especially
significant contribution to the district.
• A portable resource, such as a slzip or
railroad car, tlzat is relocated to a
place incompatible with its original
function.
• A portable resource, such as a slzip or
railroad car, whose importance is
critically linked to its historic location or route and that is moved.

Examples of Properties that DO NOT
Need to Meet Criteria Consideration
B: Moved Properties
• A property that is moved prior to its
Period of Significance.
• A district in which only a small percentage of typical buildings in a district are moved. • A moved building that is part of a
complex but is of less significance
than the remaining (unmoved)
buildings.
• A portable resource, such as a ship or
railroad car, that is eligible under
Criterion C and is moved within its
natural setting (water, rails, etc.).
• A property that is raised or lowered
on its foundations.
29 451 of 605

ELIGIBILITY FOR HISTORIC

AS SOCIA TIO NS
A moved property significant
under Criteria A or B must be demonstrated to be the surviving property most importantly associated with a
particular historic event or an important aspect of a historic person's life.

The phrase "most importantly associated" means that it must be the single surviving property that is most
closely associated with the event or
with the part of the person's life for
which he or she is significant.
30 Eligible
• A moved building occupied by
an business woman during the
majority of her productive career would be eligible if the other extant properties are a
house she briefly inhabited
prior to her per(od of significance and a commercial building she owned after her retirement.

Not Eligible
• A moved building associated
with the beginning of rail
transportation in a community
is not eligible if the original
railroad station and warehouse remained intact on their original sites.

SETTING AND

ENVIRONMENT
In addition to the requirements
above, moved properties must still
have an orientation, setting, and
general environment that are comparable to those of the historic location and that are compatible with the
property's significance.

Eligible
• A property significant as an
example of mid-19th century
rural house type can be eligible after a move, provided that it is placed on a lot that is
sufficient in size and character
to recall the basic qualities of
the historic environment and
setting, and provided that the
building is sited appropriately
in relation to natural and
manm.ade surroundings.

Not Eligible
• A rural house that is moved
into an urban area and a
bridge that is no longer situated over a waterway are not eligible.

ASSOCIATION DEPENDENT

ON THE SITE
For a property whose design values
or historical associations are directly
dependent on its location, any mov~
will cause the property to lose its
integrity and prevent it from conveying its significance.

Eligible
• A farm structure significant
only as an example of·a
method of construction peculiar to the local area is still eligible if it is moved within that local area and the new setting
is similar to that of the original
location.

Not Eligible
• A 19th century rural residence
that was designed around particular topographicfeatures, reflecting that time period's
ideals of environment, is not
eligible if moved.
452 of 605

PROPERTIES DESIGNED TO

BE MOVED
A property designed to move or a
property frequently moved during its
historic use must be located in a
historically appropriate setting in
order to qualify, retaining its integrity
of setting, design, feeling, and association. Such properties include ,rntomobiles, railroad cars and engines, and ships.

Eligible
• A ship docked in a harbor, a
locomotive on tracks or in a
railyard, and a bridge relocated from one body of water to another are eligible.

Not Eligible
• A ship on land in a park, a
bridge placed in a pasture, or a
locomotive displayed in an indoor museum are not eligible.

ARTIFICIALLY CREATED

GROUPINGS
An artificially created grouping of
buildings, structures, or objects is not
eligible unless it has achieved significance since the time of its assemblage.

It cannot be considered as a reflection
of the time period when the individual buildings were constructed.

Eligible
• A grouping of moved historic
buildings whose creation
marked the beginning of a major concern with past lifestyles can qualify as an early attempt
at historic preservation and as
an illustration of that generation's values.

Not Eligible
• A rural district composed of a
farmhouse on its original site
and a grouping of historic
barns recently moved onto the
property is not eligible.

PORTIONS OF PROPERTIES
A moved portion of a building,
structure, or object is not eligible
because, as a fragment of a larger
resource, it has lost integrity of
design 1 setting, materials, workmanship, and location. 31 453 of 605
CRITERIA CONSIDERATION C:

BIRTHPLACES OR GRAVES
A birthplace or grave of a historical figure is eligible if the person is of outstanding importance and if there is no other appropriate site or building directly associated with his or her productive life.

UNDERSTANDING

CRITERIA

CONSIDERATION
C: BIRTHPLACES

AND GRAVES
Birthplaces and grilves often ilttilin
importance ilS reflections of the origins
of importilnt persons or ilS lasting
memorials to them. The lives of
persons significant in our past normally are recognized by the National Register through listing of properties
illustrative of or associilted with that
person's productive life's work.

Birthplaces and graves, as properties
that represent the beginning and the
end of the life of distinguished individuills, may be temporally and geogrilphically for removed from the
person's significilnt activities, ilnd
therefore are not usually considered
eligible.

Examples of Properties that MUST
Meet Criteria Consideration C: Birthplaces and Graves
• The birthplace of a significant person
who lived elsewhere during his or her
Period of Significance.
• A grave that is nominated for its association with the significant person buried in it.
• A grave that is nominated for information potential.

Examples of Properties that DO NOT
Need to Meet Criteria Consideration
C: Birthplaces and Graves
32 • A house that was inhabited by a significant person for his or her entire lifetime.
• A grave located on the grounds of the
house where a significant person
spent his or her productive years.

APPLYING

CRITERIA

CONSIDERATION
C: BIRTHPLACES

AND GRAVES

PERSONS OF

OUTSTANDING

IMPORTANCE
The phrase "a historical figure of
outstanding importance" means that
in order for a birthplace or grave lo
qualify, it cannot be simply the
birthplace or grave of a person
significant in our past (Criterion B). It
must be the birthplace or grave of an
individual who was of outstanding
importance in the history of the locill
area, State, or nation. The birthplace
or grilve of an individual who was
one of several people ilctive in some
aspect of the history of a community,
a state, or the Nation would not be
eligible.

LAST SURVIVING

PROPERTY ASSOCIATED

WITH A PERSON
When an geographical areil
strongly associated with a person of
outstanding importance has lost all
other properties directly associated
with his or her formative years or
productive life, a birthplace or grave
may be eligible.
454 of 605

ELIGIBILITY FOR OTHER

ASSOCIATIONS
A birthplace or grave can also be
eligible if it is significant for reasons
other than association with the
productive life of the person in
question. It can be eligible for significance under Criterion A for association with important events, under Criterion B for association with the
productive lives of other important
persons, or under Criterion C for
architectural significance. A birthplace or grave can also be eligible in rare cases if, after the passage of time,
it is significant for its commemorative
value. (See Criteria Consideration F
for a discussion of commemorative
properties.) A birthplace or grave can
also be eligible under Criterion D if it
contains important information on
research, e.g., demography, pathology, mortuary practices, socioeconomic status differentiation.

Criteria Consideration C - Birthplaces. A birthplace of a historical figure is eligible if the person is of outstanding importance and there is no other appropriate site or building associated with his or her productive life. The Walter Reed Birthplace, Gloucester vicinity, Gloucester County, Virginia is the most appropriate remaining building associated with the life of the man who, in 1900, discovered the cause and mode of transmission of the great scourge of the tropics, yellow fever. (Virginia Historic Landmarks Commission)
33 455 of 605
CRITERIA CONSIDERATION D:

CEMETERIES
A cemetery is eligible if it derives its primary significance from graves of persons of transcendent importance, from age, from distinctive design features, or from association with historic events.

UNDERSTANDING

CRITERIA

CONSIDERATION
D: CEMETERIES
A cemetery is a collection of graves
that is marked by stones or other
artifacts or that is unmarked but
recognizable by features such as
fencing or depressions, or through
maps, or by means of testing. Cemeteries serve as a primary means of an individual's recognition of family
history and as expressions of collective religious and/ or ethnic identity .

Because cemeteries may embody
values beyond personal or familyspecific emotions, the National Register criteria allow for listing of
cemeteries under certain conditions.

Examples of Properties that MUST
Meet Criteria Consideration D:

Cemeteries
• A cemetery that is nominated individually for Criterion A, B, or C.

Examples of Properties that DO NOT
Need to Meet Criteria Consideration
D: Cemeteries
• A cemetery that is nominated along
with its associated church, but the
church is the main resource nominated.
• A cemetery that is nominated under
Criterion D for information potential.
• A cemetery that is nominated as part
of a district but is not the focal point
of the district.

Criteria Consideration D - Cemeteries. The Hancock Cemetery, Quincy, Norfolk County, Massachusetts meets the exception to the Criteria because it derives its primary significance from its great age (the earliest burials date from 1640) and from the distinctive design features found in its rich collection of late 17th and early 18th century funerary art. (N. Hobart Holly)
34 APPLYING

CRITERIA

CONSIDERATION
D: CEMETERIES

PERSONS OF

TRANSCENDENT

IMPORTANCE
A cemetery containing the graves
of persons of transcendent importance
may be eligible. To be of transcendent
importance the persons must have
been of great eminence in their fields
of endeavor or had a great impact
upon the history of their community ,
State , or nation. (A single grave that
is the burial place of an important
person and is located in a larger
cemetery that does not qualify under
this Criteria Consideration should be
treated under Criteria Consideration
C: Birthplaces and Graves .)
Eligible
• A historic cemetery containing
the graves of a number of persons who were exceptionally significant in determining the
course of a State's political or
economic history during a particular period is eligible.

Not Eligible
• A cemetery containing graves
of State legislators is not eligible if they simply performed the daily business of State government and did not have an outstanding impact upon the
nature and direction of the
State's history .
456 of 605

ELIGIBILITY ON THE BASIS
OFAGE
Cemeteries can be eligible if they
have achieved historic significance for
their relative great age in a particular
geographic or cultural context.

Eligible
• A cemetery dating from a
community's original 1830s
settlement can attain significance from its association with that very early period.

ELIGIBILITY FOR DESIGN
Cemeteries can qualify on the basis
of distinctive design values. These
values refer to the same design values
addressed in Criterion C and can
include aesthetic or technological
achievement in the fields of city
planning, architecture, landscape
architecture, engineering, mortuary
art, and sculpture. As for all other
nominated properties, a cemetery
must clearly express its design values
and be able to convey its historic
appearance.

Eligible
• A Victorian cemetery is eligible if it clearly expresses the aesthetic principlesrelated to
funerary design for that period, through such features as the overall plan, landscaping,
statuary, sculpture, fencing,
buildings, and grave markers.

Not Eligible
• A cemetery cannot be eligible
for design values if it no
longer conveys its historic appearance because of the introduction of new grave markers.

ELIGIBILITY FOR

ASSOCIATION WITH
EVENTS
Cemeteries may be associated with
historic events including specific
important events or general events
that illustrate broad patterns.

Eligible
• A cemetery associated with an
important Civil War battle is
eligible.
• A cemetery associated with the
settlement of an area by an
ethnic or cultural group is eligible if the movement of the group into the area had an important impact, if other properties associated with that group are rare, and if few
documentary sources have
survived to provide information about the group's
history.

Not Eligible
• A cemetery associated with a
battle in the Civil War does
not qualify if the battle was
not important in the history of
the war.
• A cemetery associated with an
area's settlement by an ethnic
or cultural group is not eligible if the impact of the group on the area cannot be established, if other extant historic properties better convey association with the group, or if the information that the cemetery can impart is available in documentary sources.

ELIGIBILITY FOR

INFORMATION POTENTIAL
Cemeteries, both historic and
prehistoric, can be eligible if they
have the potential to yield important
information. The information must be
important within a specific context
and the potential to yield information
must be demonstrated.

A cemetery can qualify if it has
potential to yield important information provided that the information it contains is not available in extant
documentary evidence.

Eligible
• A cemetery associated with the
settlement of a particular cultural group will qualify if it has the potential to yield important information about subjects such as demography, variations in mortuary practices, or the study of the cause of death correlated with nutrition or other variables. 457 of 605 35

INTEGRITY
Assessing the integrity of a historic
cemetery entails evaluating principal
design features such as plan, grave
markers, and any related elements
(such as fencing). Only that portion
of a historic cemetery that retains its
historic integrity can be eligible. If the
overall integrity has been lost because
of the number and size of recent grave
markers, some features such as
buildings, structures, or objects that
retain integrity may be considered as
individual properties if they are of
such historic or artistic importance
that they individually meet one or
more of the requirements listed
above.
36 NATIONAL CEMETERIES
National Cemeteries administered
by the Veterans Administration are
eligible because they have been
designated by Congress as primary
memorials to the military history of
the United States. Those areas within
a designated national cemetery that
have been used or prepared for the
reception of the remains of veterans
and their dependents, as well as any
landscaped areas that immediately
surround the graves may qualify.

Because these cemeteries draw their
significance from the presence of the
remains of military personnel who
have served the country throughout
its history, the age of the cemetery is
not a factor in judging eligibility,
although integrity must be present.

A national cemetery or a portion of
a national cemetery that has only been
set aside for use in the future is not
eligible.
458 of 605
CRITERIA CONSIDERATION E:

RECONTRUCTED PROPERTIES
A reconstructed property is eligible when it is accurately executed in a suitable environment and presented in a dignified manner as part of a restoration master plan and when no other building or structure with the same associations has survived. All three of these requirements must be met.

UNDERSTANDING

CRITERIA
CONSIDERATION E:

RECONSTRUCTED

PROPERTIES
"Reconstruction" is defined as the
reproduction of the exact form and
detail of a vanished building, structure, object, or a part thereof, as it appeared at a specific period of time.

Reconstructed buildings fall into two
categories: buildings wholly constructed of new materials and buildings reassembled from some qistoric and some new materials. Both 1categories of properties present problems in meeting the integrity requirements of
the National Register criteria.

Examples of Properties that MUST
Meet Criteria Consideration E: Reconstructed Properties • A property in which most or all of the
fabric is not original.
• A district in which an important resource or a significant number of resources are reconstructions.

Examples of Properties that DO NOT
Need to Meet Criteria Consideration E:

Reconstructed Properties
• A property that is remodeled or renovated and still has the majority of its original fabric.

APPLYING

CRITERIA
CONSIDERATION E:

RECONSTRUCTED

PROPERTIES

ACCURACY OF THE

RECONSTRUCTION
The phrase "accurately executed"
means that the reconstruction must be
based upon sound archeological,
architectural, and historic data concerning the historic construction and appearance of the resource. That
documentation should include both
analysis of any above or below ground
material and research in written and
other records.

SUITABLE ENVIRONMENT
The phrase "suitable environment"
refers to: 1) the physical context
provided by the historic district and
2) any interpretive scheme, if the
historic district is used for interpretive
purposes. This means that the
reconstructed property must be
located at the same site as the original.

It must also be situated in its original
grou'ping of buildings, structures, and
objects (as many as are extant), and
that grouping must retain integrity.

In addition, the reconstruction must
not be misrepresented as an authentic
historic property.

Eligible
• A reconstructed plantation
manager's office building is
considered eligible because it
is located at its historic site,
grouped with the remaining
historic plantation buildings
and structures, and the plantation as a whole retains integrity. Interpretation of the plantation district includes an
explanation that the manager's
office is not the original building, but a reconstruction.

Not Eligible
• The same reconstructed plantation manager's office building would not qualify if it were rebuilt at a location different from that of the original building, or if the district as a
whole no longer reflected the
period for which it is significant, or if a misleading interpretive scheme were used for the district or for the reconstruction itself.
459 of 605 37

RESTORATION MASTER
PLANS
Being presented "as part of a
restoration master plan" means that:

I) a reconstructed property is an
essential component in a historic
district and 2) the reconstruction is
part of an overall restoration plan for
an entire district. "Restoration" is
defined as accurately recovering the
form and details of a property and its
setting as it appeared at a particular
period by removing later work or by
replacing missing earlier work (as
opposed to completely rebuilding the
property). The master plan for the
entire property must emphasize
restoration, not reconstruction. In
other words, the master plan for the
entire resource would not be acceptable under this consideration if it called for reconstruction of a majority
of the resource.
38 Eligible
• A reconstructed plantation
manager's office is eligible if
the office were an important
component of the plantation
and if the reconstruction is one
element in an overall plan for
restoring the plantation and if
no other building or structure
with the same associations has
survived.
• The reconstruction of the plantation manager's office building can be eligible only if the majority of buildings, structures, and objects that comprised the plantation are extant and are being restored.

For guidance regarding restoration see the Secretary of the Interior's Standards for Historic
Preservation Projects.

LAST SURVIVING

PROPERTY OF A TYPE
This consideration also stipulates
that a reconstruction can qualify if, in
addition to the other requirements, no
other building, object, or structure
with the same association has survived. A reconstruction that is part of a restoration master plan is appropriate only if: I) the property is the only one in the district with which a
particular important activity or event
has been historically associated or
2) no other property with the same
associative values has survived.

RECONSTRUCTIONS

OLDER THAN FIFTY YEARS
After the passage of fifty years, a
reconstruction may attain its own
significance for what it reveals about
the period in which it was built,
rather than the historic period it was
intended to depict. On that basis, a
reconstruction can possibly qualify
under any of the Criteria.
460 of 605
CRITERIA CONSIDERATION F:

COMMEMORATIVE PROPERTIE
A property primarily commemorative in intent can be eligible if design, age, tradition, or symbolic value has invested it with its own historical significance.

UNDERSTANDING

CRITERIA
CONSIDERATION F:

COMMEMORATIVE

PROPERTIES
Commemorative properties are
designed or constructed after the
occurrence of an important historic
event or after the life of an important
person. They are not directly associated with the event or with the person's productive life, but serve as
evidence of a later generation's assessment of the past. Their significance comes from their value as cultural
expressions at the date of their creation. Therefore, a commemorative property generally must be over fifty
years old and must possess significance based on its own value, not on the value of the event or person being
memorialized.

Examples of Properties that MUST
Meet Criteria Consideration F:

Commemorative Properties
• A property whose sole or pri111ary
function is commemorative or in
which the commemorative function
is of pri111ary significance.

Examples of Properties that DO NOT
Need to Meet Criteria Consideration
F: Commemorative Properties
• A resource that has a nonco111mc111orative primary function or significance.
• A single marker that is a component
of a district (whether contributing or
non-contributing).

APPLYING

CRITERIA
CONSIDERATION F:

COMMEMORATIVE

PROPERTIES

ELIGIBILITY FOR DESIGN
A commemorative property derives
its design from the aesthetic values of
the period of its creation. A commemorative property, therefore, may be significant for the architectural,
artistic, or other design qualities of its
own period in prehistory or history.

Eligible
• A commemorative statue situated in a park or square is eligible if it expresses the aesthetics or craftsmanship of the period when it was made, meeting Criterion C. • A late 19th century statue
erected on a courthouse square
to commemorate Civil War veterans would qualify if it reflects that era's shared perception of
the noble character and valor of
the veterans and their cause.

This was commonly conveyed
by portraying idealized soldiers
or allegorical figures of battle,
victory, or sacrifice.
461 of 605 39

ELIGIBILITY FOR AGE,

TRADITION, OR SYMBOLIC
VALUE
A commemorative property cannot
qualify for association with the event
or person it memorializes. A commemorative property may, however, acquire significance after the time of
its creation through age, tradition, or
symbolic value. This significance must
be documented by accepted methods
of historical research, including
written or oral history, and must meet
one or more of the Criteria.
40 Eligible
•
•
•
A commemorative marker
erected by a cultural group
that believed the place was the
site of its origins is eligible if,
for subsequent generations of
the group, the marker itself became the focus of traditional association with the group's
historic identity.

A building erected as a monument to an important historical figure will qualify if through the passage of time
the property itself has come to
symbolize the value placed
upon the individual and is
widely recognized as a reminder of enduring principles or contributions valued by the
generation that erected the
monument.

A commemorative marker
erected early in the settlement
or development of an area will
qualify if it is demonstrated
that, because of its relative
great age, the property has
long been a part of the historic
identity of the area.

Not Eligible
•
•
•
A commemorative marker
erected in the past by a cultural group at the site of an event in its history would not
be eligible if the marker were
significant only for association
with the event, and it had not
become significant itself
through tradition.

A building erected as a monument to an important historical figure would not be eligible if its only value lay in its association with the individual, and it has not come to symbolize values, ideas, or contributions valued by the generation that erected the monument.

A commemorative marker
erected to memorialize an
event in the community's
history would not qualify simply for its association with the event it memorialized.

INELIGIBILITY AS THE

LAST REPRESENTATIVE OF

AN EVENT OR PERSON
The loss of properties directly
associated with a significant event or
person does not strengthen the case
for consideration of a commemorative
property. Unlike birthplaces and
graves, a commemorative property
usually has no direct historic association. The commemorative property can qualify for historic association
only if it is clearly significant in its
own right, as stipulated above.
462 of 605
CRITERIA CONSIDERATION G:

PROPERTIES THAT HAVE

ACHIEVED SIGNIFICANCE
WITHIN THE LAST FIFl'Y YEARS9
A property achieving significance within the last fifty years is eligible if it is of exceptional importance.

UNDERSTANDING

CRITERIA

CONSIDERATION
G: PROPERTIES

THAT HAVE

ACHIEVED

SIGNIFICANCE

WITHIN THE LAST

FIFTY YEARS
The National Register Criteria for
Evaluation exclude properties that
achieved significance within the last
fifty years unless they are of exceptional importance. Fifty years is a general estimate of the time needed to
develop historical perspective and to
evaluate significance. This consideration guards against the listing of properties of passing contemporary
interest and ensures that the National
Register is a list of truly historic
places.

Examples of Properties that MUST
Meet Criteria Consideration G: Properties that Have Achieved Significance Within the Last Fifty Years • A property that is less than fifty
years old.
• A property that continues to achieve
significance into a period less than
fifty years before the nomination.
• A property that has non-contiguous
Periods of Significance, one of which
is less than fifty years before the
nomination.
• A property that is more than fifty
years old and had no significance
until a period less than fifty years
before the nomination.

Examples of Properties that DO NOT
Need to Meet Criteria Consideration
G: Properties that Have Achieved
Significance Within the Last Fifty
Years
• A resource whose construction began over fifty years ago, but the completion overlaps the fifty year period by a few years or less. • A resource that is significant for its
plan or design, which is over fifty
years old, but the actual completion
of the project overlaps the fifty year
period by a few years.
• A historic district in which a few
properties are newer than fifty years
old, but the majority of properties
and the most important Period of
Significance are greater than fifty
years old.
9 For more information on Criteria Consideration G, refer to National Register Bulletin: Guidelines for Evafllati11g and Nominating Properties that Have Achieved Significa11ce Withi11 the Last Fifty Years.
41 463 of 605

APPLYING

CRITERIA

CONSIDERATION
G: PROPERTIES

THAT HAVE

ACHIEVED

SIGNIFICANCE

WITHIN THE PAST

FIFTY YEARS

ELIGIBILITY FOR

EXCEPTIONAL

IMPORTANCE
The phrase "exceptional importance" may be applied to the extraordinary importance of an event or to an entire category of resources so
fragile that survivors of any age are
unusual. Properties listed that had
attained significance in less than fifty
years include: the launch pad at Cape
Canaveral from which men first
traveled to the moon, the home of
nationally prominent playwright
Eugene O'Neill, and the Chrysler
Building (New York) significant as the
epitome of the "Style Moderne"
architecture.

Properties less than fifty years old
that qualify as exceptional because the
entire category of resources is fragile
include a recent example of a traditional sailing canoe in the Trust Territory of the Pacific Islands, where
because of rapid deterioration of
materials, no working Micronesian
canoes exist that are more than twenty
years old. Properties that by their
nature can last more than fifty years
cannot be considered exceptionally
important because of the fragility of
the class of resources.
42 The phrase "exceptional importance" does not require that the property be of national significance.

It is a measure of a property's importance within the appropriate historic context, whether the scale of that
context is local, State, or national.

Eligible
• The General Laundry Building
in New Orleans, one of the few
remaining Art Deco Style
buildings in that city, was
listed in the National Register
when it was forty years old because of its exceptional importance as an example of that architectural style.

HISTORICAL PERSPECTIVE
A property that has achieved
significance within the past fifty years
can be evaluated only when sufficient
historical perspective exists to determine that the property is exceptionally important. The necessary perspective can be provided by scholarly research and evaluation, and must
consider both the historic context and
the specific property's role in that
context.

In many communities, properties
such as apartment buildings built in
the 1950s cannot be evaluated because
there is no scholarly research available to provide an overview of the nature, role, and impact of that
building type within the context of
historical and architectural developments of the 1950s.

NATIONAL PARK SERVICE

RUSTIC ARCHITECTURE
Properties such as structures built
in a rustic style by the National Park
Service during the 1930s and 1940s
can be evaluated because a broad
study, National Park Service Rustic
Architecture (1977), provides the
context for evaluating properties of
this type and style. Specific examples
were listed in the National Register
prior to reaching fifty years of age
when documentation concerning the
individual properties established their
significance within the historical and
architectural context of the type and
style.

VETERANS

ADMINISTRATION

HOSPITALS
Hospitals less than fifty years old
that were constructed by the Veterans
Bureau and Veterans Administration
can be evaluated because the collection of forty-eight facilities built between 1920 and 1946 has been analyzed in a study prepared by the agency. The study provided a historic
and architectural context for development of veteran's care within which hospitals could be evaluated. The exceptional importance of specific individual facilities constructed within the past fifty years could therefore be determined based on their role and their present integrity.

COMP ARIS ON WITH

RELATED PROPERTIES
In justifying exceptional importance, it is necessary to identify other properties within the geographical
area that reflect the same significance
or historic associations and to determine which properties best represent the historic context in question.

Several properties in the area could
become eligible with the passage of
time, but few will qualify now as
exceptionally important.

POST-WORLD WAR II

PROPERTIES
Properties associated with the postWorld War II era must be identified and evaluated to determine which
ones in an area could be judged
exceptionally important. For example, a public housing complex may be eligible as an outstanding expression of the nation's post-war urban policy. A military installation could
be judged exceptionally important
because of its contribution to the Cold
War arms race. A church building in
a Southern city may have served as
the pivotal rallying point for the city's
most famous civil rights protest. A
post-war suburban subdivision may
be the best reflection of contemporary
siting and design tenets in a metropolitan area. In each case, the nomination preparer must justify the exceptional importance of the property
relative to similar properties in the
community, State, or nation.
464 of 605

ELIGIBILITY FOR

INFORMATION POTENTIAL
A property that has achieved
significance within the past fifty years
can qualify under Criterion D only if
it can be demonstrated that the
information is of exceptional importance within the appropriate context and that the property contains data
superior to or different from those
obtainable from other sources, including other culturally related sites. An archeological site less than fifty years
old may be eligible if the former
inhabitants are so poorly documented
that information about their lifeways
is best obtained from examination of
the material remains.

Eligible
• Data such as the rate of adoption of modern technological innovations by rural tenant
farmers in the 1950s may not
be obtainable through interviews with living persons but could be gained by examination of homesites.

Not Eligible
• A recent archeological site
such as the remains of a
f\:avajo sheep corral used in
the 1950s would not be considered exceptionally significant for its information potential on
animal husbandry if better information on the same topic is available through ethnographic studies or living informants.

HISTORIC DISTRICTS
Properties which have achieved
significance within the past fifty years
can be eligible for the National
Register if they are an integral part of
a district which qualifies for National
Register listing. This is demonstrated
by documenting that the property
dates from within the district's
defined Period of Significance and
that it is associated with one or more
of the district's defined Areas of
Significance.

Properties less than fifty years old
may be an integral part of a district
when there is sufficient perspective to
consider the properties as historic.

This is accomplished by demonstrating that: 1) the district's Period of Significance is justified as a discrete
period with a defined beginning and
end, 2) the character of the district's
historic resources is clear!v defined
and assessed, 3) specific resources in
the district are demonstrated to date
from that discrete era, and 4) the
majority of district properties are over
fifty years old. In these instances, it is
not necessary to prove exceptional
importance of either the district itself
or the less-than-fifty-year-old properties. Exceptional importance still must be demonstrated for district
where the majority of properties or
the major Period of Significance is less
than fifty years old, and for less-thanfifty-year-old properties which are nominated individually.

PROPERTIES MORE THAN

FIFTY YEARS IN AGE, LESS

THAN FIFTY YEARS IN

SIGNIFICANCE
Properties that are more than fifty
years old, but whose significant
associations or qualities are less than
fifty vears old, must be treated under
the, fifty year consideration.

Eligible
• A building constructed early
in the twentieth century (and
having no architectural importance), but that was associated with an important person
during the 1950s, must be
evaluated under Criteria Consideration G because the Period of Significance is within the past fifty years. Such a
property would qualify if the
person was of exceptional importance.

REQUIREMENT TO MEET

THE CRITERIA,

REGARDLESS OF AGE
Properties that are less than fifty
years old and are not exceptionally
important will not automatically
qualify for the National Register once
they are fifty years old. In order to be
listed in the National Register, all
properties, regardless of age, must be
demonstrated to meet the Criteria for
Evaluation.
465 of 605 43
VIII. HOW TO EVALUATE THE

INTEGRITY OF A PROPERTY

INTRODUCTION
Integrity is the ability of a property to convey its significance. To be listed in the National Register of
Historic Places, a property must not
only be shown to be significant under
the National Register criteria, but it
also must have integrity. The evaluation of integrity is sometimes a subjective judgment, but it must
always be grounded in an understanding of a property's physical features and how they relate to its
significance.

Historic properties either retain
integrity (this is, convey their significance) or they do not. Within the concept of integrity, the National
Register criteria recognizes seven
aspects or qualities that, in various
combinations, define integrity.

To retain historic integrity a
property will always possess several,
and usually most, of the aspects. The
retention of specific aspects of integrity is paramount for a property to convey its significance. Determining
whic/z of these aspects are most
important to a particular property
requires knowing why, where, and
when the property is significant. The
following sections define the seven
aspects and explain how they combine to produce integrity. 44 SEVEN ASPECTS OF

INTEGRITY
• Location
• Design
• Setting
• Materials
• Workmanship
• Feeling
• Association

UNDERSTANDING

THE ASPECTS OF

INTEGRITY

LOCATION
Location is the place where the
historic property was constructed or
the place where the historic event
occurred. The relationship between
the property and its location is often
important to understanding why the
property was created or why something happened. The actual location of a historic property, complemented
by its setting, is particularly important
in recapturing the sense of historic
events and persons. Except in rare
cases, the relationship between a
property and its historic associations
is destroyed if the property is moved.
(See Criteria Consideration Bin Part
VII: How to Apply the Criteria Considerations, for the conditions under which a moved property can be eligible.)
DESIGN
Design is the combination of
elements that create the form, plan,
space, structure, and style of a
property. It results from conscious
decisions made during the original
conception and planning of a property (or its significant alteration) and applies to activities as diverse as
community planning, engineering,
architecture, and landscape architecture. Design includes such elements as organization of space, proportion,
scale, technology, ornamentation, and
materials.

A property's design reflects historic
functions and technologies as well as
aesthetics. It includes such considerations as the structural system; massing; arrangement of spaces;
pattern of fenestration; textures and
colors of surface materials; type,
amount, and style of ornamental
detailing; and arrangement and type
of plantings in a designed landscape.

Design can also apply to districts,
whether they are important primarily
for historic association, architectural
value, information potential, or a
combination thereof. For districts
significant primarily for historic
association or architectural value,
design concerns more than just the
individual buildings or structures
located within the boundaries. It also
applies to the way in which buildings,
sites, or structures are related: for
example, spatial relationships between major features; visual rhythms in a streetscape or landscape
plantings; the layout and materials of
walkways and roads; and the relationship of other features, such as statues, water fountains, and archeological
sites.
466 of 605

SETTING
Setting is the physical environment of a historic property. Whereas location refers to the specific place
where a property was built or an event
occurred, setting refers to the character
of the place in which the property
played its historical role. It involves
how, not just where, the property is
situated and its relationship to surrounding features and open space.

Setting often reflects the basic
physical conditions under which a
property was built and the functions it
was intended to serve. In addition,
the way in which a property is positioned in its environment can reflect the designer's concept of nature and
aesthetic preferences.

The physical features that constitute
the setting of a historic property can
be either natural or manmade, including such elements as:
• Topographic features (a gorge or
the crest of a hill);
• Vegetation;
• Simple manmade features (paths
or fences); and
• Relationships between buildings
and other features or open space.

These features and their relationships should be examined not only within the exact boundaries of the
property, but also between the property and its surroundini;:s. This is pa;ticularly important for districts.

MATERIALS
Materials are the physical elements that were combined or deposited during a particular period of time and in a particular pattern or
configuration to form a historic
property. The choice and combination
of materials reveal the preferences of
those who created the property and
indicate the availability of particular
types of materials and technologies.

Indigenous materials are often the
focus of regional building traditions
and thereby help define an area's
sense of time and place.

A property must retain the key
exterior materials dating from the
period of its historic significance. If
the property has been rehabilitated,
the historic materials and significant
features must have been preserved.

The property must also be an actual
historic resource, not a recreation; a
recent structure fabricated to look
historic is not eligible. Likewise, a
property whose historic features and
materials have been lost and then
reconstructed is usually not eligible.
(See Criteria Consideration E in Part
VII: How to Apply tlze Criteria Considerations for the conditions under which a reconstructed property can be
eligible.)

WORKMANSHIP
Workmanship is the physical
evidence of the crafts of a particular
culture or people during any given
period in history or prehistory. It is
the evidence of artisans' labor and
skill in constructing or altering a
building, structure, object, or site.

Workmanship can apply to the
property as a whole or to its individual components. It can be expressed in vernacular methods of construction and plain finishes or in
highly sophisticated configurations
and ornamental detailing. It can be
based on common traditions or
innovative period techniques.

Workmanship is important because
it can furnish evidence of the technology of a craft, illustrate the aesthetic principles of a historic or prehistoric
period, and reveal individual, local,
regional, or national applications of
both technological practices and
aesthetic principles. Examples of
workmanship in historic buildings
include tooling, carving, painting,
graining, turning, and joinery. Examples of workmanship in prehistoric contexts include Paleo-Indian clovis
projectile points; Archaic period
beveled adzes; Hopewellian birdstone
pipes; copper earspools and worked
bone pendants; and Iroquoian effigy
pipes.

FEELING
Feeling is a property's expression
of the aesthetic or historic sense of a
particular period of time. It results
from the presence of physical features
that, taken together, convey the
property's historic character. For
example, a rural historic district
retaining original design, materials,
workmanship, and setting will relate
the feeling of agricultural life in the
19th century. A grouping of prehistoric petroglyphs, unmarred by graffiti and intrusions and located on
its original isolated bluff, can evoke a
sense of tribal spiritual life.

ASSOCIATION
Association is the direct link
between an important historic event
or person and a historic property. A
property retains association if it is the
place where the event or activity
occurred and is sufficiently intact to
convey that relationship to an observer. Like feeling, association requires the presence of physical
features that convey a property's
historic character. For example, a
Revolutionary War battlefield whose
natural and manmade elements have
remained intact since the 18th centurv
will retain its quality of association °
with the battle.

Because feeling and association
depend on individual perceptions,
their retention alone is never sufficient
to support eligibility of a property for
the National Register.

ASSESSING

INTEGRITY IN

PROPERTIES
Integrity is based on significance:
why, where, and when a property is
important. Only after significance is
fully established can you proceed to
the issue of integrity.

The steps in assessing integrity are:
• Define the essential physical features that must be present for a property to represent its significance.
• Determine whether the essential
physical features are visible
enough to convey their significance.
• Determine whether the property
needs to be compared with similar properties. And,
• Determine, based on the significance and essential physical features, which aspects of integrity are particularly vital to the property being nominated and if they are present.

Ultimately, the question of integrity is answered by whether or not the property retains the identity for
which it is significant.
467 of 605 45

DEFINING THE ESSENTIAL

PHYSICAL FEATURES
All properties change over time. It
is not necessary for a property to
retain all its historic physical features
or characteristics. The property must
retain, however, the essential physical
features that enable it to convey its
historic identity. The essentia(
physical featu!es are those features
that define both why a property is
significant (Applicable Criteria and
Areas of Significance) and zohc11 it was
significant (Periods of Significance).

They are the features without which a
property can no longer be identified
as, for instance, a late 19th century
dairy barn or an early 20th century
commercial district.

CRITERIA A AND B
A property that is significant for its
historic association is eligible if it
retains the essential physical features
that made up its character or appearance during the period of its association with the important event, historical pattern, or person(s). If the property is a site (such as a treaty site)
where there are no material cultural
remains, the setting must be intact.

Archeological sites eligible under
Criteria A and B must be in overall
good condition with excellent preservation of features, artifacts, and spatial relationships to the extent that
these remains are able to convey
important associations with events or
persons.

CRITERION C
A property important for illustrating a particular architectural style or construction technique must retain
most of the physical features that
constitute that style or technique. A
property that has lost some historic
materials or details can be eligible if it
retains the majority of the features
that illustrate its style in terms of the
massing, spatial relationships, proportion, pattern of windows and doors, texture of materials, and ornamentation. The property is not eligible, however, if it retains some basic
features conveying massing but has
lost the majority of the features that
once characterized its style.

Archeological sites eligible under
Criterion C must be in overall good
condition with excellent preservation
46 of features, artifacts, and spatial
relationships to the extent that these
remains are able to illustrate a site
type, time period, method of construction, or work of a master.

CRITERION D
For properties eligible under
Criterion D, including archeological
sites and standing structures studied
for their information potential, less
attention is given to their overall
condition, than it they were being
considered under Criteria A, B, or C.

Archeological sites, in particular, do
not exist today exactly as they were
formed. The/e are al{vays cu0
ltural
and natural processes that cllter the
deposited mcl tericl ls clnd their spcl ticll
relationships.

For properties eligible under
Criterion D, integrity is based upon
the property's potenticll to yield
specific dcltcl thclt clddresses importclnt
reseclrch questions, such clS those
identified in the historic context
documentation in the Stcltewide
Comprehensive Preservation Plan or
in the reseclrch design for projects
meeting the Secretary of tire Interior's
Standards for Arc/1cological Documentation.

INTERIORS
Some historic buildings are virtucllly defined by their exteriors, and their contribution to the built environment can be appreciclted even if their interiors are not accessible. Examples
of this would include early exclmples
of steel-framed skyscraper construction. The greclt advclnce in American technology and engineering mclde by
these buildings can be read from the
outside. The change in American
populclr tclste during the 19th century,
from the symmetry and simplicity of
clrchitectural styles bclsed on classiccll
precedents, to the expressions of High
Victorian styles, with their combincltion of textures, colors, and asymmetrical forms, is readily apparent from the exteriors of these buildings.

Other buildings "are" interiors.

The Cleveland Arcade, that soaring
19th century glass-covered shopping
clrec1, can only be appreciated from the
inside. Other buildings in this
category would be the great covered
train sheds of the 19th century.

In some cases the loss of an interior
will disqualify properties from listing
in the National Register-cl historic
concert hclll noted for the beauty of its
cluditorium and its fine acoustic
qualities would be the type of property that if it were to lose its interior, it would lose its Vcllue as a historic
resource. In other cclses, the overclrching significance of cl property's exterior rnn overcome the adverse
effect of the loss of an interior.

In borderline cclses particular
attention is paid to the significance of
the property and the remaining
historic features.

HISTORIC DISTRICTS
For a district to retain integrity as a
whole, the majority of the components thclt make up the district's historic character must possess
integrity even if they are individucllly
undistinguished. In addition, the
relationships among the district's
components must be substclnticllly
unchanged since the period of significclnce.

When evaluating the impclct of
intrusions upon the district's integrity, take into consideration the relative number, size, scclle, design,
clnd location of the components that
do not contribute to the significance.

A district is not eligible if it contains
so mclny cllterations or new intrusions
thclt it no longer conveys the sense of
cl historic environment.

A component of a district cclnnot
contribute to the significance if:
• it has been substantially altered
since the period of the district's
significclnce or
• it does not shclre the historic clssociations of the district.

VISIBILITY OF PHYSICAL

FEATURES
Properties eligible under Criteria
A, B, clnd C must not only retain their
essential physical fecltures, but the
fecltures must be visible enough to
convey their significance. This means
that even if a property is physiccllly
intact, its integrity is questionable if
its significant features are concealed
under modern construction. Archeological properties clre often the exception to this; by nature they
usually do not require visible features
to convey their significance.
468 of 605

NON-HISTORIC EXTERIORS
If the historic exterior building
material is covered by non-historic
material (such as modern siding), the
property can still be eligible if the
significant form, features, and detailing are not obscured. If a property's exterior is covered by a non-historic
false-front or curtain wall, the property will not qualify under Criteria A, B, or C, because it does not retain the
visual quality necessary to convey
historic or architectural significance.

Such a property also cannot be
considered a contributing element in a
historic district, because it does not
add to the district's sense of time and
place. If the false front, curtain wall,
or non-historic siding is removed and
the original building materials are
intact, then the property's integrity
can be re-evaluated.

PROPERTY CONTAINED

WITHIN ANOTHER

PROPERTY
Some properties contain an earlier
structure that formed the nucleus for
later construction. The exterior
property, if not eligible in its own
right, can qualify on the basis of the
interior property only if the interior
property can yield significant information about a specific construction technique or material, such as
rammed earth or tabby. The interior
property cannot be used as the basis
for eligibility if it has been so altered
that it no longer contains the features
that could provide important information, or if the presence of important information cannot be demonstrated.

SUNKEN VESSELS
A sunken vessel can be eligible
under Criterion C as embodying the
distinctive characteristics of a method
of construction if it is structurally
intact. A deteriorated sunken vessel,
no longer structurally intact, can be
eligible under Criterion D if the
remains of either the vessel or its
contents is capable of yielding significant information. For further information, refer to National Register Bulletin: Nominating Historic Vessels
and Shipwrecks to the National Register
of Historic Places.

Natural Features
A natural feature that is associated
with a historic event or trend, such as
a rock formation that served as a trail
marker during westward expansion,
must retain its historic appearance,
unobscured by modern construction
or landfill. Otherwise it is not eligible, even though it remains intact.

COMPARING SIMILAR

PROPERTIES
For some properties, comparison
with similar properties should be
considered during the evaluation of
integrity. Such comparison may be
important in deciding what physical
features are essential to properties of
that type. In instances where it has
not been determined what physical
features a property must possess in
order for it to reflect the significance
of a historic context, comparison with
similar properties should be undertaken during the evaluation of integrity. This situation arises when scholarly work has not been done on a
particular property type or when
surviving examples of a property type
are extremely rare. (See Comparing
Related Properties in Part V: How to
Evaluate a Property within its Historic
Context.)

RARE EXAMPLES OF A

PROPERTY TYPE
Comparative information is
particularly important to consider
when evaluating the integrity of a
property that is a rare surviving
example of its type. The property
must have the essential physical
features that enable it to convey its
historic character or information. The
rarity and poor condition, however, of
other extant examples of the type may
justify accepting a greater degree of
alteration or fewer features, provided
that enough of the property survives
for it to be a significant resource.

Eligible
• A one-room schoolhouse that
has had all original exterior
siding replaced and a replacement roof that does not exactly replicate the original roof profile can be eligible if the other extant rare examples have received an even greater degree of alteration, such as the subdivision of the original oneroom plan.

Not Eligible
• A mill site contains information on how site patterning reflects historic functional requirements, but parts of the site have been destroyed. The
site is not eligible for its information potential if a comparison of other mill sites reveals more intact properties with
complete information.
469 of 60547

DETERMINING THE

RELEVANT ASPECTS OF

INTEGRITY
Each type of property depends on
certain aspects of integrity, more than
others, to express its historic significance. Determining which of the aspects is most important to a particular property requires an understanding of the property's significance and its essential physical features.

CRITERIA A AND B
A property important for association with an event, historical pattern, or person(s) ideally might retain some
features of all seven aspects of integrity: location, design, setting, materials, workmanship, feeling, and association. Integrity of design and
workmanship, however, might not be
as important to the significance, and
would not be relevant if the property
were a site. A basic integrity test for a
property associated with an important
event or person is whether a historical
contemporary would recognize the
property as it exists today.

For archeological sites that are
eligible under Criteria A and B, the
seven aspects of integrity can be
applied in much the same way as they
are to buildings, structures, or objects.

It is important to note, however, that
the site must have demonstrated its
ability to convey its significance, as
opposed to sites eligible under Criterion D where only the potential to yield information is required.

Eligible
A mid-19th century waterpowered
mill important for its association
with an area's industrial development is eligible if:
• it is still on its original site
(Location), and
• the important features of its
setting are intact (Setting), and
• it retains most of its historic
materials (Materials), and
• it has the basic features expressive of its design and function, such as configuration, proportions, and window pattern (Design).
48 Not Eligible
A mid-19th century waterpowered mill important for its association with an area's industrial development is not eligible if:
• it has been moved (Location,
Setting, Feeling, and Association), or
• substantial amounts of new
materials have been incorporated (Materials, Workmanship, and Feeling), or • it no longer retains basic design features that convey its historic appearance or
function (Design, Workmanship, and Feeling).

CRITERION C
A property significant under
Criterion C must retain those physical features that characterize the type, period, or method of construction that
the property represents. Retention of
design, workmanship, and materials
will usually be more important than
location, setting, feeling, and association. Location and setting will be important, however, for those properties whose design is a reflection of their immediate environment (such as
designed landscapes and bridges).

For archeological sites that are
eligible under Criterion C, the seven
aspects of integrity can be applied in
much the same way as they are to
buildings, structures, or objects. It is
important to note, however, that the
site must have demonstrated its ability
to convey its significance, as opposed
to sites eligible under Criterion D
where only the potential to yield
information is required.

Eligible
A 19th century wooden covered
bridge, important for illustrating
a construction type, is eligible if:
• the essential features of its design are intact, such as abutments, piers, roof configuration, and trusses (Design, Workmanship, and Feeling),
and
• most of the historic materials
are present (Materials, Workmanship, and Feeling), and • evidence of the craft of
wooden bridge technology remains, such as the form and assembly technique of the
trusses (Workmanship).
• Since the design of a bridge relates directly to its function as a transportation crossing, it is
also important that the bridge
still be situated over a waterway (Setting, Location, Feeling, and Association).

Not Eligible
For a 19th century wooden covered bridge, important for its construction type, replacement
of some materials of the flooring,
siding, and roofing would not
necessarily damage its integrity.

Integrity would be lost, however,
if:
• the abutments, piers, or trusses
were substantially altered (Design, Workmanship, and Feeling) or • considerable amounts of new
materials were incorporated
(Materials, Workmanship,
and Feeling).
• Because environment is a
strong factor in the design of
this property type, the bridge
would also be ineligible if it no
longer stood in a place that
conveyed its function as a
crossing (Setting, Location,
Feeling, and Association).
470 of 605

CRITERION D
For properties eligible under
Criterion D, setting and feeling may
not have direct bearing on the
property's ability to yield important
information. Evaluation of integrity
probably will focus primarily on the
location, design, materials, and
perhaps workmanship.

Eligible
A multicomponent prehistoric
site important for yielding data
on changing subsistence patterns
can be eligible if:
• floral or faunal remains are
found in clear association with
cultural material (Materials
and Association) and
• the site exhibits stratigraphic
separation of cultural components (Location).

Not Eligible
A multicomponent prehistoric
site important for yielding data
on changing subsistence patterns
would not be eligible if:
• floral or fauna! remains were
so badly decomposed as to
make identification impossible
(Materials), or
• floral or fauna! remains were
disturbed in such a manner as
to make their association with
cultural remains ambiguous
(Association), or
• the site has lost its stratigraphic context due to subsequent land alterations (Location).

Eligible
A lithic scatter site important for
yielding data on lithic technology
during the Late Archaic period
can be eligible if:
• the site contains lithic
debitage, finished stone tools,
hammerstones, or antler
flakers (Material and Design),
and
• the site contains datable material (Association).

Not Eligible
A lithic scatter site important for
yielding data on lithic technology
during the Late Archaic period
would not be eligible if:
• the site contains natural deposits of lithic materials that are impossible to distinguish
from culturally modified lithic
material (Design) or
• the site does not contain any
temporal diagnostic evidence
that could link the site to the
Late Archaic period (Association).
471 of 605 49
IX. SUMMARY OF THE

NATIONAL HISTORIC

LANDMARKS CRITERIA FOR

EVALUATION
A property being nominated to the
National Register may also merit
consideration for potential designation as a National Historic Landmark.

Such consideration is dependent upon
the stringent application of the
following distinct set of criteria
(found in the Code of Federal Regulations, Title 36, Part 65).

NATIONAL

HISTORIC

LANDMARKS

CRITERIA
The quality of national significance
is ascribed to districts, sites, buildings,
structures, and objects that possess
exceptional value or quality in illustrating or interpreting the heritage of the United States in history, architecture, archeology, engineering, and culture and that possess a high degree
of integrity of location, design,
setting, materials, workmanship,
feeling, and association, and:
50 1. That are associated with events
that have made a significant contribution to, and are identified with, or that outstandingly represent, the broad national patterns of United States history and from
which an understanding and appreciation of those patterns may be gained; or

2. That are associated importantly
with the lives of persons nationally significant in the history of the United States; or

3. That represent some great idea
or ideal of the American people;
or

4. That embody the distinguishing
characteristics of an architectural
type specimen exceptionally
valuable for a study of a period,
style or method of construction,
or that represent a significant,
distinctive and exceptional entity
whose components may lack individual distinction; or

5. That are composed of integral
parts of the environment not sufficiently significant by reason of historical association or artistic
merit to warrant individual recognition but collectively compose an entity of exceptional historical
or artistic significance, or outstandingly commemorate or illustrate a way of life or culture; or

6. That have yielded or may be
likely to yield information of major scientific importance by revealing new cultures, or by shedding light upon periods of occupation over large areas of the United States. Such sites are
those which have yielded, or
which may reasonably be expected to yield, data affecting theories, concepts and ideas to a
major degree.

NATIONAL

HISTORIC

LANDMARK

EXCLUSIONS
Ordinarily, cemeteries, birthplaces,
graves of historical figures, properties
owned by religious institutions or
used for religious purposes, structures
that have been moved from their
original locations, reconstructed historic buildings and properties that have achieved significance within the
past fifty years are not eligible for designation. If such properties fall within the following categories they
may, nevertheless, be found to
qualify:

1. A religious property deriving its
primary national significance
from architectural or artistic distinction or historical importance; or

2. A building or structure removed
from its original location but
which is nationally significant
primarily for its architectural
merit, or for association with persons or events of transcendent importance in the nation's history and the association consequential; or

3. A site of a building or structure
no longer standing but the person or event associated with it is of transcendent importance in the
nations's history and the association consequential; or 472 of 605

4. A birthplace, grave or burial if it
is of a historical figure of transcendent national significance and no other appropriate site,
building, or structure directly associated with the productive life of that person exists; or

5. A cemetery that derives its primary national significance from graves of persons of transcendent
importance, or from an exceptionally distinctive design or an exceptionally significant event; or

6. A reconstructed building or ensemble of buildings of extraordinary national significance when accurately executed in a suitable
environment and presented in a
dignified manner as part of a restoration master plan, and when no other buildings or structures
with the same association have
survived; or

7. A property primarily commemorative in intent if design, age, tradition, or symbolic value has invested it with its own national historical significance; or

8. A property achieving national
significance within the past 50
years if it is of extraordinary national importance. ·

COMPARING THE

NATIONAL

HISTORIC

LANDMARKS

CRITERIA AND THE

NATIONAL

CRITERIA
In general, the instructions for
preparing a National Register nomination and the guidelines stated in this bulletin for applying the National
Register Criteria also apply to Landmark nominations and the use of the Landmark criteria. While there are
specific distinctions discussed below,
Parts IV and V of this bulletin apply
equally to National Register listings
and Landmark nominations. That is,
the categories of historic properties are
defined the same way; historic contexts are identified similarly; and comparative evaluation is carried out
on the same principles enumerated in
Part V.

There are some differences between
National Register and National
Historic Landmarks Criteria. The
following is an explanation of how
each Landmark Criterion compares
with its National Register Criteria
counterpart:

CRITERION 1
This Criterion relates to National
Register Criterion A. Both cover
properties associated with events.

The Landmark Criterion, however,
requires that the events associated
with the property be outstandingly
represented by that property and that
the property be related to the broad
national patterns of U.S. history.

Thus, the quality of the property to
convey and interpret its meaning
must be of a higher order and must
relate to national themes rather than
the narrower context of State or local
themes.

CRITERION 2
This Criterion relates to National
Register Criterion B. Both cover
properties associated with significant
people. The Landmark Criterion
differs in that it specifies that the
association of a person to the property
in question be an important one and
that the person associated with the
property be of national significance.

CRITERION 3
This Criterion has no counterpart
among the National Register Criteria.

It is rarely, if ever, used alone. While
not a landmark at present, the Liberty
Bell is an object that might be considered under this Criterion. The application of this Criterion obviously requires the most careful scrutiny and
would apply only in rare instances
involving ideas and ideals of the
highest order.

CRITERION 4
This Criterion relates to National
Register Criterion C. Its intent is to
qualify exceptionally important works
of architecture or collective elements
of architecture extraordinarily significant as an ensemble, such as a historic district. Note that the language is
more restrictive than that of the
National Register Criterion in requiring that a candidate in architecture be "a specimen exceptionally valuable for
the study of a period, style, or method
of construction" rather than simply
embodying distinctive characteristics
of a type, period, or method of construction. With regard to historic districts, the Landmarks Criterion
requires an entity that is distinctive
and exceptional. Unlike National
Register Criterion C, this Criterion will
not qualify the works of a master, per
se, but only such works which are
exceptional or extraordinary. Artistic
value is considered onlv in the context
of history's judgement in order to
avoid current conflicts of taste.

CRITERION 5
This Criterion does not have a strict
counterpart among the National
Register Criteria. It may seem redundant of the latter part of Landmark Criterion 4. It is meant to cover
collective entities such as Greenfield
Village and historic districts like New
Bedford, Massachusetts, which qualify
for their collective association with a
nationally significant event, movement, or broad pattern of national development.

CRITERION 6
The National Register counterpart
of this is Criterion D. Criterion 6 was
developed specifically to recognize
archeological sites. All such sites must
address this Criterion. The following
are the qualifications that distinguish
this Criterion from its National Register counterpart: the information yielded or likely to be yielded must be
of major scientific importance by
revealing new cultures, or by shedding
light upon periods of occupation over
large areas of the United States. Such
sites should be expected to yield data
affecting theories, concepts, and ideas to a
major degree.

The data recovered or expected to
be recovered must make a major
contribution to the existing corpus of
information. Potentially recoverable
data must be likely to revolutionize or
substantially modify a major theme in
history or prehistory, resolve a substantial historical or anthropological debate, or close a serious gap in a
major theme of U.S. history or prehistory.
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EXCLUSIONS AND

EXCEPTIONS TO

THE EXCLUSIONS
This section of the National Historic Landmarks Criteria has its counterpart in the National Register's
"Criteria Considerations." The most
abundant difference between them is
the addition of the qualifiers "national," "exceptional," or "extraordinary" before the word significance.

Other than this, the following are the
most notable distinctions:

EXCLUSION 2
Buildings moved from their
original location, qualify only if one of
two conditions are met: 1) the building is nationally significant for 52 architecture, or 2) the persons or
events with which they are associated
are of transcendent national significance and the association is consequential.

Transcendent significance means
an order of importance higher than
that which would ordinarily qualify a
person or event to be nationally
significant. A consequential association is a relationship to a building that had an evident impact on events,
rather than a connection that was
incidental and passing.

EXCLUSION 3
This pertains to the site of a structure no longer standing. There is no counterpart to this exclusion in the
National Register Criteria. In order
for such a property to qualify for
Landmark designation it must meet
the second condition cited for Exclusion 2.

EXCLUSION 4
This exclusion relates to Criteria
Consideration C of the National
Register Criteria. The only difference
is that a burial place qualifies for
Landmark designation only if, in
addition to other factors, the person
buried is of transcendent national
importance.

When evaluating properties at the
national level for designation as a
National Historic Landmark, please
refer to the National Historic Landmarks outline, History and Prehistory in the National Park System and the
National Historic Landmarks Program,
1987. (For more information about
the National Historic Landmarks
program, please write to Department
of the Interior, National Park Service,
National Historic Landmarks, 1849 C
Street, NW, NC400, Washington, DC
20240.)
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X. GLOSSARY
Associative Qualities - An aspect of a
property's history that links it with
historic events, activities, or
persons.

Code of Federal Regulations -
Commonly referred to as "CFR."
The part containing the National
Register Criteria is usually referred
to as 36 CFR 60, and is available
from the National Park Service.

CLG - Certified Local Government.

Culture - A group of people linked
together by shared values, beliefs,
and historical associations, together
with the group's social institutions
and physical objects necessary to
the operation of the institution.

Cultural Resource - See Historic
Resource.

Evaluation - Process by which the
significance and integrity of a
historic property are judged and
eligibility for National Register
listing is determined.

Historic Context - An organizing
structure for interpreting history
that groups information about
historic properties that share a
common theme, common geographical area, and a common time period. The development of
historic contexts is a foundation for
decisions about the planning,
identification, evaluation, registration, and treatment of historic properties, based upon comparative historic significance.

Historic Integrity - The unimpaired
ability of a property to convey its
historical significance.

Historic Property - See Historic
Resource.

Historic Resource - Building, site,
district, object, or structure evaluated as historically significant.

Identification - Process through
which information is gathered
about historic properties.

Listing - The formal entry of a property in the National Register of Historic Places. See also, Registration.

Nomination - Official recommendation for listing a property in the National Register of Historic
Places.

Property Type - A grouping of
properties defined by common
physical and associative c1ttributes.

Registration - Process by which a
historic property is documented
and nominated or determined
eligible for listing in the National
Register.

Research Design - A statement of
proposed identification, documentation, investigation, or other treatment of a historic property
that identifies the project's goals,
methods and techniques, expected
results, c1nd the relationship of the
expected results to other proposed
activities or treatments.
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XI. LIST OF NATIONAL

REGISTER BULLETINS
The Basics
How to Apply National Register Criteria for Evaluation* Guidelines for Completing National Register of Historic Places Form Part A: How to Complete the National Register Form*
Part B: How to Complete the National Register Multiple Property Documentation Form* Researching a Historic Property *
Property Types
Guidelines for Evaluating and Documenting Historic Aids to Navigation* Guidelines for Identifying, Evaluating and Registering America's Historic Battlefields Guidelines for Evaluating and Registering Historical Archeological Sites Guidelines for Evaluating and Documenting Historic Aviation Properties Guidelines for Evaluating and Registering Cemeteries and Burial Places How to Evaluate and Nominate Designed Historic Landscapes * Guidelines for Identifying, Evaluating and Registering Historic Mining Sites How to Apply National Register Criteria to Post Offices* Guidelines for Evaluating and Documenting Properties Associated with Significant Persons Guidelines for Evaluating and Documenting Properties That Have Achieved Significance Within the Last Fifty Years* Guidelines for Evaluating and Documenting Rural Historic Landscapes * Guidelines for Evaluating and Documenting Traditional Cultural Properties * Nominating Historic Vessels and Shipwrecks to the National Register of Historic Places Technical Assistance
Defining Boundaries for National Register Properties*
Guidelines for Local Surveys: A Basis for Preservation Planning * How to Improve the Quality of Photographs for National Register Nominations National Register Casebook: Examples of Documentation*
Using the UTM Grid System to Record Historic Sites
To order these publications, write to: National Register of Historic Places, National Park Service, 1849 C St., NC 400, NW, Washington, D.C. 20240, or e-mail at: [email protected]. Publications marked with an asterisk(*) are also available in electronic form at www.cr.nps.gov/nr. 54 U.S GOVERNMENT PRINTING OFFICE: 2005-717-788 476 of 605 1 Alby Calles
From: Doug D'Anna
Sent: Friday, April 17, 2026 11:38 AM
To: City Council (San Mateo); Clerk
Subject: Glazenwood Homeowners Speak: 83% Support Historic District Status Attachments: Glazenwood_Petition_Final_v7.pdf
Dear Mayor and Members of the City Council,
Glazenwood has been recognized as a historic district in San Mateo's General Plan for over thirty years. Today, its residents are asking the Council to make that recognition official.

Through direct outreach, 83% of homeowners — 30 of 36 households — within the established district boundaries have signed a petition affirming their support for historic designation. In many households, multiple family members signed, reflecting not just broad agreement but genuine, household-level conviction.

A copy of the petition is attached for the public record, with personal contact information redacted to protect resident privacy. The full unredacted petition, including signatory telephone numbers and email addresses, will be made available to Council at the April 20th meeting.

This is not passive support.

As demonstrated at the January 28th Council meeting and the February 2nd community gathering with the Mayor and Council representative Lisa Diaz-Nash, Glazenwood residents are engaged, organized, and invested in this process. Many plan to attend the April 20th meeting at 7:00 PM to speak in person.

These are neighbors who bought their homes here because of Glazenwood's historic character, who have renovated in keeping with its architectural legacy, and who have invested — financially and personally — in the neighborhood's continuity.

Glazenwood's historic significance is not a new claim.

The neighborhood was identified in the City's 1989 Historic Building Survey and has been recognized as a historic district in two successive General Plans — the 2010 and 2024 General Plans. The City's own planning staff has acknowledged that Glazenwood meets historic eligibility criteria, confirming this is not a contested factual question — only a procedural one.
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2 This long-standing recognition reflects decades of consistent City practice and policy.

The current designation process is therefore not a new designation, but a formal restoration of what has already been acknowledged through multiple Counciladopted documents. We respectfully ask that this history be given full weight in your deliberations.

The community has more than satisfied consent standard — by every measure, including the opposition's own.

The public record before the Council includes a statement from an opponent of this designation — one who does not reside in Glazenwood and holds no stake in the neighborhood — setting a clear threshold for consent.

That opponent stated publicly: 'I would gladly support Council making Glazenwood historic with the 60% documented written consent of the affected property owners, as the upcoming Historic Ordinance Update specifies,' and further advised: 'Build community and cohesion, and make people put their support in writing.'" The Glazenwood community has done precisely that.

Eighty-three percent of affected homeowners have provided affirmative, written, documented consent — substantially exceeding the threshold the opposition itself defined as sufficient. The community was organized. The neighbors were engaged. The signatures were collected. The standard has been met.

There is no remaining procedural objection that has not been answered by the residents of Glazenwood themselves.

The record is complete. The residents have met every standard. We ask the Council to reaffirm our historic district on April 20th:

Respectfully submitted,
Doug D'Anna Glazenwood Homeowner
Attachments:

Exhibit A — Glazenwood Homeowner Petition Package, including:
 Redacted petition (for public record; unredacted version available April 20th)  Household support summary
 Participant roster by street
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3  Signed resident petitions
 Historical background on Glazenwood's architectural legacy and designation history  Public Comment Letter to City Council dated April 5, 2026, cited herein. 479 of 605
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Dear Mayor and Members of the City Council,
Glazenwood has been recognized as a historic district in San Mateo's General Plan for over thirty years. Today, its residents are asking the Council to make that recognition official.

This is not passive support.

Many plan to attend the April 20th meeting at 7:00 PM to speak in person.

Glazenwood's historic significance is not a new claim.

This long-standing recognition reflects decades of consistent City practice and policy.

The current designation process is therefore not a new designation, but a formal restoration of what has already been acknowledged through multiple Council-adopted documents. We respectfully ask that this history be given full weight in your deliberations.
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The community has more than satisfied the consent standard — by every measure, including the opposition's own.

That opponent stated publicly: ‘I would gladly support Council making Glazenwood historic with the 60% documented written consent of the affected property owners, as the upcoming Historic Ordinance Update specifies,’ and further advised: ‘Build community and cohesion, and make people put their support in writing.’
The Glazenwood community has done precisely that.

There is no remaining procedural objection that has not been answered by the residents of Glazenwood themselves.

The record is complete. The residents have met every standard. We ask the Council to reaffirm our historic district on April 20th:

Respectfully submitted,
Doug D'Anna Glazenwood Homeowner and Organizer of the Historic District Initiative 482 of 605

GLAZENWOOD HISTORIC DISTRICT
Verified Owner Consent Summary — April 2026
Cover Page & Petition Summary Page 1
Overview of district support: 83% owner consent, signers by street.

Letter to Mayor and City Council Pages 2–3
Formal request by Doug D'Anna and neighborhood organizers.

Table of Contents Page 4
This page.

Participant Roster by Street Pages 5–6
Detailed list of the 30 households behind the initiative.

Signed Resident Petitions Pages 7–10
Redacted copies of official resident signatures.

Historical Background & Significance Page 11
The architectural legacy of Glazenwood (1920–Present).

Key Timeline of Designation Page 12
Chronology from 1989 survey to current 2024 General Plan listing.

District Boundaries & Character Page 13
Detailed descriptions of district streets and defining features.

Public Comment, April 5, 2026 Pages 14–15
Statement from opponent setting consent threshold of 60%; community has provided 83%.

Presented by the Glazenwood Historic District Initiative | Contact: Doug D'Anna (Organizer) 483 of 605
Meet The People Behind the Petition: Glazenwood Homeowners by Street The 30 households represented on this petition span every street in the Glazenwood historic district — 18 on Laurel, 8 on Rosewood, 3 on Hayward, and 1 on Palm. In many households, multiple family members signed, reflecting not just broad agreement but genuine, household-level conviction. These are not abstract supporters — they are the neighbors who share driveways, tend gardens, and have built lives in a community they believe is worth preserving. Together, they represent approximately 83% of Glazenwood homeowners within the proposed district boundaries.

LAUREL
Burnham, Thomas / Zinkl, Gregory
Huang, Alayn
Saba, George / Saba, Teresa
Sampson, Brian
Lim, Michael
Savage, John
Krause, Courtney
Matsuyama, Takako
Cagler, Oktay
— Gonzales, Richard
— D’Anna, Doug
— Edholm, Kaj
— Guzman, Maria / Pate, Jamme
— Ferrari, Alisa
— Truong, Tiffany / Larchman, Patrick
— D’Amato, Caren
— Schellenberg, Marc / Schellenberg, Sam
— Bliss, Kim

ROSEWOOD
Desai, Devendra
Gillman, Carol / Gillman, Alysha / Gillman, Martin
Athens, Deborah
Ames, Joann
Labeaud, Desiree
Litwin, Brenda
Costello, Cathy
Kasten, Glenn / Kasten, Dawn

HAYWARD
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Jordan, Elizabeth / Jordan, Matt
Jerving, Phillipa
Combs, Kelli
PALM
— Kedefors, Aida
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A Neighborhood Worth Preserving: The History of Glazenwood Glazenwood did not simply grow up around San Mateo — it was designed and built with intention. In the early 1920s, the land where Glazenwood now stands was the site of the Peninsula Hotel, a grand resort on the former Hayward Mansion grounds in the Hayward Park neighborhood just south of Central Park.

When fire destroyed the hotel on June 25, 1920, the land was subdivided into a carefully planned residential neighborhood and given the name Glazenwood.

What emerged was something distinctive: a cohesive collection of Spanish Colonial Revival homes, built in a consistent architectural style that gave the neighborhood a unified, historic character from its earliest days.

The stucco-covered brick entry pillars at Laurel at 9th Avenue, Rosewood at 9th Avenue, and Hayward at Palm — still standing today — were built to mark the neighborhood’s identity. Neighbors have worked to restore and maintain them.

The City of San Mateo recognized Glazenwood’s significance as early as 1989, when the neighborhood was identified in the City’s official building survey. That recognition has been reaffirmed twice in the City’s General Plans — both the 2030 General Plan and the 2024 General Plan list Glazenwood as a historic district.

The current designation process is therefore not the creation of something new. It is the formal restoration of what has long been acknowledged — a neighborhood that has preserved its architectural heritage and community character across more than a century, and whose residents are committed to ensuring that legacy endures.
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Glazenwood Historic District: Key Timeline
June 25, 1920 Peninsula Hotel destroyed by fire; land subdivided for residential development.

Early 1920s Glazenwood neighborhood developed as a planned community of Spanish Colonial Revival homes.
1989 City of San Mateo’s official building survey identifies Glazenwood as historically significant.

Early 1990s City designates Glazenwood as a local historic district. 2030 General Plan Glazenwood listed as a historic district in the City’s long-range planning document.
2024 General Plan Glazenwood again listed as a historic district, reaffirming its recognized status.

January 28, 2026 Glazenwood residents appear before City Council to address the historic designation question.

February 2, 2026 Community gathering with Mayor and Council representative Lisa Diaz-Nash; residents express unified support.

April 17, 2026 Petition submitted to City Council: 30 households, representing approximately 83% of district homeowners.

April 20, 2026 City Council meeting at 7:00 PM. Glazenwood residents plan to attend and speak in person. Full unredacted petition to be presented. 491 of 605
The Glazenwood Historic District: Boundaries and Character The Glazenwood Historic District is located in the Hayward Park neighborhood of San Mateo, California.

It is a compact, walkable residential area bounded by four streets, each contributing homes to the district’s 36-property total.

The district is entered from three directions, each marked by the neighborhood’s signature stucco-covered brick entry pillars: at Laurel Avenue at 9th Avenue, at Rosewood Drive at 9th Avenue, and at Hayward Avenue at Palm Avenue. These pillars, built in the 1920s and restored by neighbors in more recent years, define the neighborhood’s identity as clearly as any map.

Note: A map of the district is available from the City of San Mateo Planning Division and the San Mateo Heritage Society.
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1 Alby Calles
From: Andrew Ryan
Sent: Friday, April 17, 2026 1:39 PM
To: City Council (San Mateo); Alex Khojikian; Zachary Dahl; Prasanna Rasiah Cc: Frank Elliott; Anna Kuhre; Kolja Schlütter
Subject: The "Glazenwood Standard" is NOT what consent looks like and endangers Baywood too
The resolution for making Glazenwood historic states the following as justification:
"WHEREAS, City Council received many testimonials and comments at the January 26, 2026 study session and the subsequent Glazenwood Neighborhood meeting on February 9, 2026 from residents of the Glazenwood neighborhood as to their preference for Glazenwood to be formally considered a historic district"
Clearly, "many testimonials and comments" is *not* the demonstrated 60% consent which the City Council has mandated as part of the Historic Ordinance Update.

Council, why are you rushing Glazenwood's designation and undermining your own historic ordinance by ignoring your own consent requirement?
If the residents of Glazenwood really do support this designation, then it should only take a few weeks to get the signatures.

Have Glazenwood's homeowners even been informed of their rights and upcoming responsibilities as part of the new historic ordinance that is scheduled to be passed in two weeks? Why not take a few more weeks and do this properly with proper notification and consent from the 39 affected homeowners? Glazenwood isn't going anywhere and a historic designation is a permanent, one-way door.

I have no position on whether or not Glazenwood should or should not ultimately be a historic district, but as a resident of Baywood, I am now very worried because the "Glazenwood standard" could *easily* be applied to us in Baywood. In fact, the "Glazenwood standard" has already been met for Baywood, since there is no doubt that Council has received "many testimonials and comments" that Baywood is also historic, even though a documented majority of the homeowners oppose the historic designation.

A future City Council, or even this one, could easily declare Baywood -- or San Mateo Park, or anywhere in San Mateo -- historic without consent under the same "Glazenwood Standard". Having advocated so strongly for consent over the past 2 years, that possibility really concerns me.

Andrew Ryan
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Glazenwood
Historic District
Zachary Dahl, AICP
Community Development Director
April 20, 2026
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Background
• Identified a historic district eligible for the National Register of Historic Places in 1989 Survey.
• 1994 City Council Study Session on potential district designation, but no subsequent action
• 1995 Ordinance update noted Downtown District, but not Glazenwood • 2009/2010 General Plan Updates noted Glazenwood as a historic district • But no mention of a local designation action or supporting documentation • General Plan 2040 referenced carried over from 2030 Geneal Plan • Research concluded not locally designated, but remains an eligible district 519 of 605
Background
• Questions and comments surfaced as part of Historic Policy Update Effort.
• City Council provided direction at February 2, 2026 meeting • Prepare information to support designating Glazenwood Historic District at the local district via resolution.
• Updated documentation required
• 1989 Survey information 37 years old and incomplete
• Rincon Consultants updated survey and historic status documentation • Necessary to support legal basis and future administration 520 of 605
Methods
• Survey • Intensive survey
effort with photodocumentation
• Archival research • Primary and
secondary sources
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Findings
• Harmonious, well-designed residential neighborhood constructed on the land of the former Peninsula Hotel, which burned in 1920. • San Mateo Improvement Company redeveloped the land as a restricted residential tract.
• Subdivided in 1921
• S.A. Born Co. constructed many of the houses in popular Revival Styles. • San Mateo Improvement Company dissolved in 1929.
• Development stalled and some infill development continued into the 1930s.
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Findings
• Recommended eligible for the NRHP/CRHR under Criteria A/1 (Events). • The Glazenwood Historic District is significant at the local level for its associations with urban planning and development as a residence park. Designed before Euclidean zoning was common, its construction as a planned residential park reflected the emerging trend toward suburbanization in San Mateo during this period. • Recommended eligible for the NRHP/CRHR under Criteria C/3 (Design). • Though common during the period in which it was developed, the execution of the revival styles in the Glazenwood Historic District illustrates an important period of residential development in San Mateo, from 1921 through 1936. Buildings within the historic district embody the style, including stucco exteriors, red clay tile roofs, arched openings, decorative wrought iron elements, and ornamental tilework. Many residences feature asymmetrical massing, recessed entries, arcades, and interior courtyards, reflecting revival styles adapted for modern living. Additionally, the district is significant as a good example of the work of the S.A. Born Building Company.
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Findings • 39 properties/features • 36 contributors • 3 non-contributors • Period of Significance • 1921-1936 • Boundary Justification • The historic district encompasses all those parcels that were developed as originally envisioned by the
San Mateo Improvement Company, composed of
mostly single-family residences. Though plotted as
part of the original subdivision, parcels south of
Hayward Avenue on Palm Avenue and on the east
side of Rosewood Drive were excluded because
they were developed many decades later and their
designs do not reflect the popular revival styles that
characterize the neighborhood’s early development
• Would be added to the San Mateo Historic
Resources Inventory upon adoption of the
updated Historic Preservation Ordinance
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Recommendation
Adopt a resolution designating the Glazenwood Historic
District at the local level and find that the action is exempt under California Environmental Quality Act (CEQA) Guidelines Section 15061 (b)(3) (Common Sense Exemption)
and 15308 (Actions by Regulatory Agencies for Protection of the Environment).
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CITY OF SAN MATEO

CITY OF SAN MATEO
Agenda Report
City Hall
330 W. 20th Avenue
San Mateo CA 94403
www.cityofsanmateo.org
Agenda Number: 16 Section Name: NEW BUSINESS Account Number: 10-4661 File ID: 26-11040 TO: City Council
FROM: Alex Khojikian, City Manager
PREPARED BY: Public Works Department
MEETING DATE: April 20, 2026
SUBJECT:

Connect Bay Area Local Investment Plan — Informational
RECOMMENDATION:

Receive an informational presentation from the San Mateo County Transit District (SamTrans) on the Connect Bay Area Local Investment Plan.

BACKGROUND:

SamTrans is the principal public transportation provider in San Mateo County, managing SamTrans bus, Ride Plus on demand ride-share, and Redi-Wheels and Redi-Coast paratransit services throughout the County. These transit services connect residents to jobs, healthcare, their communities, and regional transit systems.

Several San Francisco Bay Area transit operators – including Caltrain, BART and SF Muni, all of which serve San Mateo County – are facing significant budget deficits. Senator Scott Wiener introduced the Connect Bay Area Act (SB 63) to authorize a regional sales tax measure to be put before Bay Area voters in hopes of minimizing or avoiding public transit service reductions and other cuts because of these deficits. SB 63 authorized a tax measure to be placed on the November 2026 ballot in San Francisco, Santa Clara, Alameda, San Mateo, and Contra Costa Counties, to take effect in 2027 and last 14 years. Governor Newsom signed SB 63 on October 13, and the bill officially became law on January 1, 2026.

This potential measure is currently being circulated as an initiative petition by an independent group of citizens. If the measure qualifies for the November 2026 ballot and is approved by voters, the resulting regional tax would stabilize public transportation funding to offset planned transit service cuts and prevent station closures across the Bay Area, including in San Mateo County.

Additionally, the measure would provide approximately $50 million in annual, locally controlled funding dedicated to public transit in San Mateo County to be administered by the San Mateo County Transit District (District). This local funding would be entirely for transit within San Mateo County — no funds could be taken by the State or outside counties.

The District is developing a local plan for how to invest this additional $50 million in annual local transit funding should the measure be approved. Potential uses for this funding include:

1. Improve transit routes to reduce traffic on the most heavily traveled corridors

2. Continue free and reduced fare programs for seniors, students, and people with disabilities

3. Protect transit infrastructure against sea-level rise, flooding, and extreme weather

4. Increase safety, cleanliness, and accessibility at bus stops

5. Enhance bus service to be more efficient, faster, and more reliable

6. Expand access to transit for communities that are currently underserved 526 of 605

CITY OF SAN MATEO

7. Make repairs and upgrades to aging paratransit vehicles to ensure reliable service

8. Reduce greenhouse gas emissions and improve air quality by transitioning to zero-emission buses

9. Repair potholes and fix streets along bus routes

10. Offer affordable ride-share and on-demand programs to more communities Stakeholder engagement and community input are critical components of this planning process. The District has held Agency Advisory Group and Stakeholder Advisory Group meetings to gather input on local transit priorities from senior city staff and community partners, including business, labor, special districts, and nonprofits. The District also launched a brief public survey asking residents to rank investment priorities for potential local funding.

District staff are presenting to city councils and other groups and bodies across the county in late March and April to promote the public survey and collect additional feedback. They also are asking agency and stakeholder partners to help amplify this outreach by sharing multilingual fact sheets, social media content, and printable flyers with tear-off survey materials available at samtrans.com/projects/Local Funding Plan.

BUDGET IMPACT:

There is no funding impact in receiving this information item.

ENVIRONMENTAL DETERMINATION:

This informational presentation from SamTrans to the City Council is not a project subject to CEQA, because it is an organizational or administrative activity that will not result in direct or indirect physical changes in the environment. (CEQA Guidelines Section 15378(b)(5).)

NOTICE PROVIDED
All meeting noticing requirements were met.

ATTACHMENTS
Att 1 – Connect Bay Area Local Investment Plan City Council Presentation

STAFF CONTACT
Jay Yu, Engineering Manager
[email protected]
(650) 522-7323
Matt Fabry, Public Works Director
[email protected]
(650) 522-7309
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San Mateo
April 20, 2026
Connect Bay Area Local Investment Plan
1 528 of 605
• SamTrans Snapshot
• Key Issue
• Connect Bay Area Measure
• Transportation Funding in San Mateo County
• SamTrans Financial Outlook
• Local Investment Plan
• Take the Survey and Spread the Word
Agenda
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▪ Established in 1976 – Celebrating 50 Years!
• San Mateo County, parts of San Francisco, City of Palo Alto • 300+ buses serving 76 bus routes, 10 million annual boardings • Other services: Redi-Wheels and RediCoast paratransit, Ride Plus ondemand rideshare (two zones), shuttles • School-oriented bus service
▪ Rider Profile
• 94% low income (68% extremely low income) based on SMC affordable housing metrics
• Lowest household income among major Bay Area transit agencies • 40% speak a language other than English at home
• Nearly 80% do not drive/own a car
• 98.8% of pre-pandemic ridership
3 SamTrans Snapshot
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• Caltrain, BART, SFMTA, and AC Transit are facing deficits as post-pandemic fare revenue lags and operating costs
rise
• Despite ridership gains and cost efficiency measures, expenses are outpacing revenues
• Federal and state support has declined
• Need for a stable, predictable source of funds to keep these agencies operating at current service levels
4 Key Issue
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• 14-year, 1/2 cent sales tax in 4
counties (San Mateo, Santa Clara,
Alameda, Contra Costa), full cent
in San Francisco
• Would generate approx. $980
million annually
• Includes accountability and
oversight provisions
• 24% of SMC sales tax to Caltrain,
27% to BART, 7% to Muni, 37%
SamTrans Local Investment Plan
5 Connect Bay Area Measure
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• Approximately $50M annually for 14 years for public
transit in San Mateo County; Total = $700M
• Funds may be used for:
• Public transit operations and capital
• Public transit components of larger capital projects
• Targeted pavement repairs on local roads served by fixed-route transit
6 Connect Bay Area Measure –
San Mateo County
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Transportation Funding in SMC
7 Measure A generates approximately $120 million annually. Measure W generates approximately $60 million annually for SamTrans local transit and $60 million annually for SMCTA to allocate for broader transportation improvements and operations throughout the county. 534 of 605
8 SamTrans Financial Outlook
FY26-FY36 Operating Outlook (assumes zero new tax revenue) $M
• Operating deficit projected
to begin in FY28
• Average annual deficit over
next 10 years of nearly $30M
• Increased labor, energy, and
contracted services costs
• Cost saving measures
• No new positions approved,
reducing consultant use
• Cuts across all discretionary
spending $-
$100
$200
$300
$400
$500
$600
FY26 FY27 FY28 FY29 FY30 FY31 FY32 FY33 FY34 FY35 FY36
Operating + Debt Service Only
Net Operating Surplus Net Operating Deficit Total Sources Total Uses 535 of 605
• SamTrans’ Local Investment Plan will be informed
by:
• San Mateo County Transit District Strategic Plan
and Capital Improvement Plan (CIP)
• SamTrans Board of Directors
• Stakeholder and Agency Advisory Group
meetings
• City Council presentations
• Public outreach
• Goal is to have a Board-adopted plan in June 2026
9 Local Investment Plan:

Your Input Matters!
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Local Investment Plan Categories
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Local Investment Plan
JunMayAprMarFeb
Stakeholder and Agency Advisory Group Meetings:

February – April, May (if needed)
Public Communications Effort: March – May
City Council and other presentations: March – May
Board Information Item: May 6
Board Action Item: June 3
11 Approximately 10 weeks for public engagement
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Take the Survey and Spread the Word!
12 Visit
https://www.samtrans.com/projects/LocalFundingPlan
• Multilingual online survey + printable mailreturn version • Multilingual fact sheets
• Social media toolkit
• Translations in Spanish, Simplified Chinese,
Tagalog
• Additional support and language assistance
available at 1-800-660-4287
539 of 605
Questions/Comments?
13 Contact us!
[email protected]
540 of 605
Thank You
14 541 of 605

San Mateo
April 20, 2026
Connect Bay Area Local Investment Plan
1 546 of 605
• SamTrans Snapshot
• Key Issue
• Connect Bay Area Measure
• Transportation Funding in San Mateo County
• SamTrans Financial Outlook
• Local Investment Plan
• Take the Survey and Spread the Word
Agenda
2 547 of 605
▪ Established in 1976 – Celebrating 50 Years!
• San Mateo County, parts of San Francisco, City of Palo Alto • 300+ buses serving 76 bus routes, 10 million annual boardings • Other services: Redi-Wheels and RediCoast paratransit, Ride Plus ondemand rideshare (two zones), shuttles • School-oriented bus service
▪ Rider Profile
• 94% low income (68% extremely low income) based on SMC affordable housing metrics
• Lowest household income among major Bay Area transit agencies • 40% speak a language other than English at home
• Nearly 80% do not drive/own a car
• 98.8% of pre-pandemic ridership
3 SamTrans Snapshot
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• Caltrain, BART, SFMTA, and AC Transit are facing deficits as post-pandemic fare revenue lags and operating costs
rise
• Despite ridership gains and cost efficiency measures, expenses are outpacing revenues
• Federal and state support has declined
• Need for a stable, predictable source of funds to keep these agencies operating at current service levels
4 Key Issue
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• 14-year, 1/2 cent sales tax in 4
counties (San Mateo, Santa Clara,
Alameda, Contra Costa), full cent
in San Francisco
• Would generate approx. $980
million annually
• Includes accountability and
oversight provisions
• 24% of SMC sales tax to Caltrain,
27% to BART, 7% to Muni, 37%
SamTrans Local Investment Plan
5 Connect Bay Area Measure
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• Approximately $50M annually for 14 years for public
transit in San Mateo County; Total = $700M
• Funds may be used for:
• Public transit operations and capital
• Public transit components of larger capital projects
• Targeted pavement repairs on local roads served by fixed-route transit
6 Connect Bay Area Measure –
San Mateo County
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Transportation Funding in SMC
7 Measure A generates approximately $120 million annually. Measure W generates approximately $60 million annually for SamTrans local transit and $60 million annually for SMCTA to allocate for broader transportation improvements and operations throughout the county. 552 of 605
8 SamTrans Financial Outlook
FY26-FY36 Operating Outlook (assumes zero new tax revenue) $M
• Operating deficit projected
to begin in FY28
• Average annual deficit over
next 10 years of nearly $30M
• Increased labor, energy, and
contracted services costs
• Cost saving measures
• No new positions approved,
reducing consultant use
• Cuts across all discretionary
spending $-
$100
$200
$300
$400
$500
$600
FY26 FY27 FY28 FY29 FY30 FY31 FY32 FY33 FY34 FY35 FY36
Operating + Debt Service Only
Net Operating Surplus Net Operating Deficit Total Sources Total Uses 553 of 605
• SamTrans’ Local Investment Plan will be informed
by:
• San Mateo County Transit District Strategic Plan
and Capital Improvement Plan (CIP)
• SamTrans Board of Directors
• Stakeholder and Agency Advisory Group
meetings
• City Council presentations
• Public outreach
• Goal is to have a Board-adopted plan in June 2026
9 Local Investment Plan:

Your Input Matters!
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Local Investment Plan Categories
10 555 of 605
Local Investment Plan
Feb Mar Apr May Jun
Stakeholder and Agency Advisory Group Meetings:

February – April, May (if needed)
Public Communications Effort: March – May
City Council and other presentations: March – May
Board Information Item: May 6
Board Action Item: June 3
11 Approximately 10 weeks for public engagement
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Take the Survey and Spread the Word!
12 Visit
https://www.samtrans.com/projects/LocalFundingPlan
• Multilingual online survey + printable mailreturn version • Multilingual fact sheets
• Social media toolkit
• Translations in Spanish, Simplified Chinese,
Tagalog
• Additional support and language assistance
available at 1-800-660-4287
557 of 605
Questions/Comments?
13 Contact us!
[email protected]
558 of 605
Thank You
14 559 of 605

CITY OF SAN MATEO

CITY OF SAN MATEO
Agenda Report
City Hall
330 W. 20th Avenue
San Mateo CA 94403
www.cityofsanmateo.org
Agenda Number: 17 Section Name: NEW BUSINESS Account Number: 10-2021 File ID: 26-11096 TO: City Council
FROM: Alex Khojikian, City Manager
PREPARED BY: Finance Department
MEETING DATE: April 20, 2026
SUBJECT:

General Fund 2026-27 Operating Budget — Preview and General Fund Ten-Year Forecast RECOMMENDATION:

Receive the General Fund 2026-27 operating budget preview and General Fund ten-year forecast.

BACKGROUND:

On February 23, 2026, staff presented a mid-year budget update to Council on the City’s financial status. The General Fund budget deficit for fiscal year (FY) 2025-26 is projected at $6.9 million, an improvement from the original $12 million shortfall. This reflects better-than-expected investment earnings and real property transfer taxes, as well as budget savings from vacancies. Despite the projected deficit, the General Fund balance is expected to remain strong at year-end, with an estimated $112.6 million.

In addition, since last December, City staff has been working to develop the FY 26-27 budget in accordance with City Council priorities, to meet operational needs and maintain financial sustainability. As a precursor to the proposed budget annual public hearing in June, staff is providing a preview of the General Fund’s 2026-27 budget estimates for Council comment and direction. The sections that follow provide an overview of current economic conditions and staff’s budget forecast for fiscal year 2026-27 General Fund revenue and expenditures. Additionally, this report includes a ten-year forecast of the General Fund to support budget planning discussions.

General Economic Conditions
This year’s budget development has encountered notable challenges due to economic uncertainties, particularly concerning interest rates, inflation, and expected economic growth. Although the U.S. and local economies have remained strong, despite the shifts in U.S. trade policies, the most recent war in Iran is expected to provide a significant shock to the world economy. As a result, local government agencies will most likely continue to grapple with sustained inflation and higher interest rates while also anticipating the effects of oil shocks on the growth of the economy. • Economic Growth: U.S. real GDP growth slowed materially through late 2025 and the U.S. Bureau of Economic Analysis reported real GDP growth of 0.5 percent at an annual rate in the fourth quarter of 2025, down from 4.4 percent in the third quarter. Currently, real GDP is expected to grow moderately, about 1.5 - 2.5 percent throughout 2026 and 2027, assuming the effects of the war do not dampen those estimates. • Labor Market: The labor market remains stable despite global uncertainties with the U.S. unemployment rate at 4.3 percent as of March 2026. Although the unemployment rate remains low, the civilian labor force has declined lowering the participation rate and for some segments of the labor market, unemployment is much higher. San Mateo County’s unemployment rate from December 2025 remained below the national average at 3.5 percent. 560 of 605

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• Inflation: Inflation, measured by the Core Personal Consumption Expenditure Price Index (PCE), has not changed much over the past two years and saw a slight uptick to 2.9% in February 2026. Inflation continues to be higher than the Fed’s long-term 2% target and a reduction in the core PCE index, which signifies easing inflation, is not expected given the current economic conditions. As such, inflation remains a concern to the economy. • Interest Rates: Throughout 2024 and 2025, the Federal Open Market Committee (FOMC) worked to reduce the federal funds rate target such that by March 2026 the rate was about 3.64 percent, with the goal of keeping the target between 3.5-3.75 percent. This rate has held constant since December 2025 and the FOMC projected just one rate cut in 2026 depending upon the economic growth, labor market, and inflation trends. Although the previous reductions had brought down mortgage interest rates, no additional reductions are expected without a rate cut and mortgage rates are expected to hover around 6% for most of 2026.

These broader economic indicators, especially those related to interest rates, inflation, and the labor market, have direct implications for the City’s revenue projections and fiscal outlook. Due to the degree of uncertainty, staff have taken a conservative approach in developing the FY 2026-27 budget.

Current Legislative Environment
At the same time, several factors within the Federal and State legislative environments are impacting the City‘s revenue projections and future financial sustainability.

Federal Rules and Regulations Issues
At the federal level, the current administration is trying to limit grant funding to the City and other agencies through its various attempts to require certain organizational policy certifications, covering DEI, immigration, and anti-terrorism in federal grant agreements, including CDBG agreements. In addition, the administration is working to include these same policy certifications in the annual renewal of an agency’s SAM.gov registration, which is a required registration for receiving federal funds. The City is working to combat these new policy certifications, both by participating in a lawsuit against the new certifications in grant agreements and by opposing any changes to the SAM.gov regulations.

State Legislative Issues
At the State level, two main challenges could impact the City’s revenues in FY 26-27 and beyond.  Property Tax In-Lieu of Vehicle License Fee: The uncertainty around whether or not the City would receive its Property Tax In-Lieu of Vehicle License Fee (VLF) shortfall revenue, a long-time financial risk, increased at the end of FY 24-25. Historically, the State has reimbursed counties and cities for any in-lieu VLF shortfalls through a special appropriation in the State budget. However, as the county-wide VLF shortfalls continue to widen, the State’s willingness to fund this obligation has diminished, particularly during fiscal years when the State experiences significant deficits. At the end of FY 24-25, the State decided to only reimburse 67 percent of the City’s VLF shortfall due in FY 25-26 from FY 23-24. The City along with the County of San Mateo and all the other cities within the County have filed a lawsuit with the State over the unpaid amount, which totaled $2.2 million for San Mateo.

As a City, we will continue to fight for the VLF revenue due to us, but there is significant risk that the City will not receive the shortfall due in FY 26-27 of about $6.9 million.

 Real Property Transfer Tax: A new initiative, pending qualification with the California Secretary of State for the November 2026 ballot, threatens to eradicate a significant form of General Fund revenue, our Real Property Transfer Taxes (RPTT). The new initiative, titled Local Taxpayer Protection Act to Save Proposition 13, has two important provisions that affect the City. First, the measure aims to prohibit any new RPTT and second, it proposes to make null and void any previously approved taxes not in compliance with the measure, such as our RPTT which includes Measure CC revenues approved by San Mateo voters in November 2022. The City typically budgets about $8-9 million per year in RPTT revenue, although the amount the City collects varies from year to year based on real property transfers, with a recent high of $17.2 million (FY 24-25) and a recent low of $7.4 million (FY 22-23). 561 of 605

CITY OF SAN MATEO
General Fund 2026-27 Budget Preview
The FY 2026-27 General Fund budget preview reflects a cautious approach in response to both external economic conditions and internal operational needs. Budget assumptions were thoroughly reviewed and updated to reflect the best estimates available. These assumptions are summarized in Attachment 1 for Council review.

General Fund Revenues
General Fund revenues for FY 2026-27 are projected to be $174.0 million, a decrease of $2.8 million (-1.6%) from the FY 2025-26 mid-year projections of $176.8 million. The decrease is primarily due to the VLF shortfall of $6.9 million that City staff did not include in the Property Tax budget since we do not know if we will receive it. All other major revenues are expected to remain relatively flat with minimal increases.

Property Tax: Property Tax is the largest revenue source for the General Fund, accounting for approximately 50% of total revenues. For FY 2026-27, property tax revenue is projected at $85 million, a decrease of $2.2 million (-2.5%) compared to the 2025-26 mid-year projection. Currently, the local real estate market remains relatively stable with secured property taxes, which make up over 60% of total property tax revenues, anticipated to increase 3.17% for FY 26-27 based on the County Assessor‘s Office estimated tax roll. Approximately 75% of San Mateo’s secured property tax base is residential.

Sales Tax
Sales tax is projected to remain flat at $28.0 million, comprising of $20.6 million from the local 1 percent Bradley-Burns sales tax, $0.4 million from Proposition 172, and $7.0 million from the local ¼ percent Measure S transaction and use tax.

Ongoing inflation, high interest rates, and trade conflicts continue to weigh on consumer spending. San Mateo's sales tax base is relatively diversified, reducing the City’s exposure to high-volatility sectors such as auto sales. While the City does not experience rapid growth in sales tax revenue during economic booms, unlike cities with major auto dealership or retail hubs, the City’s sales tax tends to be more stable during a downturn.

Real Property Transfer Tax (RPTT)
San Mateo’s RPTT is set at 0.5% on sale or transfer value of any property within the City. The voter approved Measure CC portion of RPTT increases the rate to 1.5% on properties sales or transfers of property with a value of $10 million or more.

For FY 2026-27, RPTT is projected to be $9.0 million, including $8.4 million baseline budget and an estimated $0.6 million from Measure CC.

Given the ongoing economic uncertainty, General Fund revenues are expected to remain flat or have minimal growth at 562 of 605

CITY OF SAN MATEO
this time. Overall, San Mateo’s revenue remains resilient, supported by stable property tax and consistent sales tax. This provides the City with certain insulation during economic downturns.

General Fund Expenditures
Total General Fund expenditures for FY 2026-27 are expected to reach $190.0 million, an increase of $2.3 million (1.2%) compared to the prior year’s adopted budget.

Personnel Costs
Personnel costs are projected at $97.0 million, consisting of salaries, benefits, and pension unfunded liability payments.

This reflects an overall 3% increase over the prior year and accounts for approximately half of the General Fund budget.

When including San Mateo Consolidated Fire Department‘s personnel and legacy costs, total personnel-related costs represent about 72% of the General Fund budget.

For FY 2026-27, staff needed to develop a new approach to estimate the personnel budget since this is the first year that the data for personnel costing is coming from our Workday ERP system. Workday categorizes salaries and benefits a bit differently in some areas, which made it difficult to compare this year’s costing to past year’s data. After incorporating salary adjustments based on negotiated labor contracts and scheduled step increases, as is past practice, and refining the data from Workday; staff believes the Workday model of personnel budgeting should bring budget closer to actuals at year end.

Also, given the ongoing financial sustainability plan, staff reviewed opportunities to reduce the personnel budget and keep increases to a minimum. Again, this year, staff plans to maintain a lower contribution to the City’s self-insured Workers’ Compensation Program (a reduction of $1.5 million) and draw down on excess fund balance from the Workers’ Compensation Fund and maintain higher CIP chargebacks to reduce the General Fund burden.

Other Operating Expenditures
Non-personnel operating expenditures are projected to be $44.7 million, increasing by $2.4 million (5.7%). For the most part, this budget reflects maintaining a baseline budget, with minor inflation adjustments, since the majority of operating expenses increased by about 3 percent. Other expenses, though, outside of the City‘s control have increased at a much higher rate. As a whole, utilities throughout the City have increased with an 18% increase in PG&E costs and a 15% increase in water costs from last year. In addition, insurance premiums continue to increase with an over 20% increase budgeted for this year. These higher increases contributed to the overall 5.7 percent increase in operating budget.

Transfers out, anticipated to be about $7.6 million, are smaller this year because staff is recommending decreases in the contributions from the general fund and Measure S to capital. Staff is proposing a one-time contribution of $1.25 million in Measure CC funding to capital, but this still leaves capital contributions to the Capital Project Fund for CIP projects low with only $4.2 million in contributions. This is added to the $3.0 million for debt service and $0.4 million annual contribution to the Equipment and Vehicle Replacement Fund for major building component replacement to make-up the total transfers out.
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General Fund Balance
In summary, General Fund total expenditures are projected to exceed total revenues in 2026-27, resulting in a budget deficit of approximately $16 million. If the deficit is realized at the end of the year, the City would need to draw on the General Fund’s Budget Stabilization Reserve to maintain core services and investments in capital projects. Fortunately, the City’s strong General Fund reserves place us in a strong position, allowing time to address the structural deficit.

General Fund Ten-Year Forecast Scenarios
This year’s General Fund ten-year forecast has been challenging due to two major uncertainties: (1) VLF shortfalls and (2) the potential legislation around RPTT.

VLF Shortfalls
Property tax in-lieu of Vehicle License Fee (VLF) is a key component of the City’s property tax revenues, accounting for approximately 20% of total property tax revenues or approximately 10% of total General Fund revenues. As discussed in previous City Council meetings, there is currently no reliable funding source for VLF shortfalls. Also, with more school districts shifting from non-basic-aid to basic-aid status, the County of San Mateo’s VLF shortfall continues to grow. The county-wide VLF shortfalls are expected to be $119 million for fiscal year 2024-25 and $125 million for fiscal year 2025-26.

The City’s share of the countywide VLF shortfall is roughly 6%, translating to $6.9 million and $7.1 million for 2024-25 and 2025-26, respectively. Currently, there are only five non-basic-aid school districts remaining in San Mateo County. The City is forecasting that three of the school districts will become basic aid within the 10-year forecast and two will remain non-basic aid. Thus, the ten-year forecast predicts the City’s VLF shortfall will reach $17.2 million by 2035-36.

Real Property Transfer Tax
As mentioned, a new initiative, titled Local Taxpayer Protection Act to Save Proposition 13, is threatening to make null and void any prior approved Real Property Transfer Taxes (RPTT). This could potentially eliminate the .5% real property transfer tax paid on all property transfers in the City and the additional 1.0% real property transfer tax paid on all property transfers over $10 million dollars as approved by 71% of San Mateo voters in November 2022. For fiscal year 2026-27 and going forward, the City estimates this revenue to be about $9 million per year.

SCENARIO ANALYSIS:

The General Fund ten-year forecast (Attachment 2) illustrates the fiscal challenges and uncertainties facing the City, including VLF shortfalls, challenges with State legislation, limitations on Federal funding, and revenue increases that cannot keep up with inflation and the increase in expenses. To demonstrate the impacts of these fiscal challenges, staff developed four scenarios - optimistic, practical, grave and dire - to outline potential fiscal outcomes and highlight the need for strategic planning and preparedness in the face of current issues.

Optimistic Scenario: This baseline scenario projects the highest growth in revenue over the ten years, assuming favorable budget conditions for most revenues. Property tax, as the primary revenue source, is projected to experience stable annual growth (averaging 4% annually), sales tax is set at a steady 2% growth rate, RPTT is set at a consistent $9 million baseline and modest increases are built in for other tax revenues. The scenario is optimistic because although it shows the current proposed budget with no VLF shortfall paid, losing $6.9 million, it assumes that the State will pay 100% of the VLF shortfall starting in fiscal year 2027-28 and beyond. As shown in Attachment 2 – Scenario A, this scenario reflects continued economic growth with a consistent reimbursement of VLF shortfalls. Under this optimistic scenario, the General Fund faces a structural deficit until fiscal year 2034-35 because even with strong revenues, the rising labor costs, inflationary pressures, and the costs of the unfunded pension liability continue to put pressure on the City’s operations.

The General Fund balance maintains a positive balance in this scenario until fiscal year 2034-35.

Practical Scenario: This scenario Includes the baseline assumptions from the optimistic scenario and is updated to assume that the State will only backfill the VLF shortfalls by 67% going forward. As shown in Attachment 2 – Scenario B, this 564 of 605

CITY OF SAN MATEO
scenario reflects continued economic growth with a reduction in VLF revenues. The General Fund balance maintains a positive balance in this scenario until fiscal year 2033-34.

Grave Scenario: As shown in this scenario in Attachment 2 – Scenario C, the baseline assumptions are held constant and the update assumes that the State refuses to backfill any VLF shortfalls, resulting in significant revenue loss for the county and cities in San Mateo County. If this scenario were realized, the City would need to make drastic cuts to service levels to balance the budget. It highlights the importance of continuing to advocate for the VLF revenue and exercising cautious fiscal management. The General Fund balance maintains a positive balance in this scenario until fiscal year 2030-31.

Dire Scenario: Finally, as reflected in Attachment 2 – Scenario D, this scenario keeps all the assumptions from the Grave Scenario and also assumes that the City loses its Real Property Transfer Tax ((RPTT) from State legislative action. As a worst-case scenario, this attachment shows the General Fund balance maintaining a positive balance until fiscal year 2030- 31, as in the Grave Scenario, but the resulting deficit is much larger. If realized, the results would be devastating for the City and even more drastic cuts to service levels would be needed to balance the budget.

OTHER CHALLENGES
City Facilities and Infrastructure Needs
In the April 20 meeting, staff will present a five-year CIP Budget Preview to the City Council, detailing the funding needs for City facilities and infrastructure improvements. As outlined in the ten-year forecast, the scenarios assume about $6.3 - $6.75 million in annual contributions to CIP from the General Fund with about $4.25 million from General Fund and $2- $2.5 million from Measure S (a General Fund sub-fund). The City’s funding needs for CIP far exceed these baseline annual contributions underscoring the substantial gap between current funding levels and the actual needs for capital improvements.

Pension Costs
The City’s pension costs consist of two components: (1) normal cost and (2) unfunded accrued liability (UAL) payment.

While normal costs are projected to be steady with limited growth, UAL payments are projected to increase significantly over the next seven years. The current UAL payment estimates included in the ten-year forecast are based on two strong investment years for the CalPERS pension system. With returns of 9.3% in fiscal year 2023-24 and 11.6% in fiscal year 2024-25, the fund beat its projected earnings target of 6.8%. When market returns are strong and beat the earnings target, the amount of funding set aside for pension obligations increases and additional funding is not needed towards the UAL.

The balance for the current CalPERS portfolio is higher than last year, and CalPERS estimated a 7.7% fiscal year to date total return in December, but the final rate of return will not be noted until the end of the fiscal year. Depending upon the performance of the market in the next three months, the pension obligations for future years could change.

Budget Deficit and Financial Sustainability Plan
With projected revenues at $174 million and proposed expenditures at $190 million, the General Fund could be facing a $16 million budget deficit in fiscal year 2026-27. As with the previous fiscal year, City staff will work to make progress on the financial sustainability plan and reduce that deficit. Ongoing activities and initiatives include the following:
• Expenditure Control
o Frozen positions - Limit the refilling of vacant positions to reduce expenses o Non-General Fund Charges - Charge positions and hours to capital projects and non-General Fund budgets where feasible
o Benefit Savings – Reduce General Fund contributions to Workers Compensation fund as funding allows o Operating Savings – Reduce discretionary spending where feasible including reviewing options to reduce the City’s General Liability insurance
• Revenue Enhancements
o Sales Tax Measure – Conduct education and outreach around a potential quarter cent sales tax measure 565 of 605

CITY OF SAN MATEO
on the November 2026 ballot
o Revenue Agreements – Look to other options for revenues such as electronic billboards and parking agreements
• Cost Recovery & Cost Allocation
o Cost Recovery – Continue to review fees and the appropriate recovery of service costs o Cost Allocation – Review and update the Citywide cost allocation plan • Grant Opportunities
o Grants Coordination – Work with our grant consultant to review and pursue competitive grant opportunities
• Economic Development
o Work Plan Activities - Work to address priority items in the adopted Economic Development Workplan for 2026-2029
Staff will continue to work on these and other initiatives as part of the financial sustainability plan to address the current fiscal year 2025-26 deficit, the proposed fiscal year 2026-27 deficit and the longer-term structural deficit.

BUDGET IMPACT:

There is no direct budgetary impact resulting from this report. The financial status of the General Fund will continue to be monitored. Updated final estimates will be incorporated into the recommended 2026-28 Business Plan.

ENVIRONMENTAL DETERMINATION:

This report is not a project subject to CEQA, because it is a government fiscal activity which does not involve any commitment to any specific project which may result in a potentially significant physical impact on the environment. (CEQA Guidelines Section 15378(b)(4).)

NOTICE PROVIDED
All meeting noticing requirements were met.

ATTACHMENTS
Att 1 – FY 26-27 General Fund Budget Assumptions
Att 2 – General Fund Ten-Year Forecast Scenarios
Scenario A – Optimistic
Scenario B – Practical
Scenario C – Grave
Scenario D – Dire

STAFF CONTACT
Abby Veeser, Finance Director
[email protected]
(650) 522-7102
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Attachment 1

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San Mateo City CouncilApril 20, 2026

San Mateo City Council
April 20, 2026