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Last Updated: Friday, February 3, 2012 11:30 AM


Exhibit 2.16: National Register & California Register comparison

Exhibit 2.16 PDF version here.

The National Register of Historic Places criteria and guidance in National Register Bulletin #15 are very similar to the California Register of Historical Resources criteria and regulations, which Caltrans uses to determine whether a resource is a historical resource under CEQA. There are some differences between the federal and state criteria. They are enumerated on the chart below. Boldfaced sections are for emphasis.

California Register Law and Regulations NR Bulletin 15 – How to Apply the National Register Criteria for Evaluation

CRITERIA

Law

States that the California Register criteria are the same as the National Register criteria. [PRC §5024.1(c)]

Regulations

"These criteria are consistent with National Register criteria, but have been modified for state use in order to include a range of historical resources which better reflect the history of California." (CCR §4852)

“A resource may be listed as an historical resource in the California Register if it meets any of the following National Register of Historic Places criteria:

  • (1) Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage.
  • (2) Is associated with the lives of persons important in our past.
  • (3) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possess high artistic values
  • (4) Has yielded, or may be likely to yield, information important in prehistory or history.”

    [PRC §5024.1(c)]

CRITERIA

National Register criteria are usually expressed in capital letters. For example, “Criterion A, association with events.”

“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 associate 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 significance 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.

INTEGRITY

Law

The legislation does not state that the California Register is more inclusive or has a lower threshold of significance than the National Register. There is no mention of integrity in the legislation.

Regulations

The California Register regulations do address integrity.

“Integrity is the authenticity of an historical resource’s physical identity evidenced by the survival of characteristics that existed during the resources’ period of significance.

Historical resources eligible for listing in the California Register must:
-meet one of the criteria of significance described in CCR §4852(b) of this chapter and
- retain enough of their historic character or appearance to be recognizable as historical resources and to convey the reasons for their significance.

Historical resources that have been rehabilitated or restored may be evaluated for listing.” [CCR §4852 (c)]

“Integrity is evaluated with regard to the retention of

  • location
  • workmanship
  • design
  • feeling
  • setting
  • association
  • materials

It must also be judged with reference to the particular criteria under which a resource is proposed for eligibility.” [CCR §4852 (c)]

Alterations over time to a resource or historic changes in its use may themselves have historical, cultural, or architectural significance.”

[CCR §4852 (c)]

INTEGRITY

“Integrity is the ability of a property to convey its significance. . . . Historic properties either retain their integrity or they do not.”

Guidance for assessing integrity is in National Register Bulletin 15, Section VIII.

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. . . Ultimately the question of integrity is answered by whether or not the property retained the identify for which it is significant.” [Section VIII]

“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. These essential physical features are those features that define both why a property significant (Applicable criteria and Areas of Significance) and when it was significant (Periods of Significance).  They are 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.” [Section VIII]

 “The quality of significance . . . is present in districts, sites, buildings, structures, and objects that possess integrity of:

  • location
  • workmanship
  • design
  • feeling
  • setting
  • association
  • materials

“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 which of these aspects are most important to a particular property requires knowing why, where, and when the property is significant.” [Section VIII]

Provides guidance for evaluating integrity under each of the four eligibility criteria. As with the California Register regulations, the National Register recognizes that alterations and changes in a property’s use over time may themselves have significance.

This is expressed most clearly under Criterion C  “A property can be significant not only for the way it was originally constructed or created, 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.” [Section VI]

ELIGIBILITY FOR INFORMATION POTENTIAL - when Integrity Lacking

Law

Eligibility under Criterion 4 when integrity is lacking is not mentioned in the law. California Register law states under criterion 4, a resource may be listed if it: “Has yielded, or may be likely to yield, information important in prehistory or history.”  [PRC §5024.1(c)(4)]  Language between the law and the regulations is different.  The language in PRC §5024.1 is closer to the National Register language.

Regulations

Language is similar to the guidance in National Register Bulletin 15 regarding eligibility under National Register Criterion D when there is a lack of integrity under the other criteria.

“It is possible that historical resources may not retain sufficient integrity to meet the criteria for listing in the National Register, but they may still be eligible for listing in the California Register.   

A resources that has lost its historic character or appearance may still have sufficient integrity for the California Register if it maintains the potential to yield significant scientific or historical information or specific data.” [CCR §4852 (c)]

The California Register Regulations uses the term “significant scientific or historical information or specific data,” but does not define it.

ELIGIBILITY FOR INFORMATION POTENTIAL - when Integrity Lacking

“The assessment of integrity for properties considered for information potential depends on the data requirements of the applicable research design. 

A property possessing information potential does not need to recall visually an event, person, process, or construction technique.  It is important that the significant data contained in the property remain sufficiently intact to yield the expected important information, if the appropriate study techniques are employed.” [Criterion D – Section VI]

“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 if they were being considered under criteria A, B, or C.” [Section VIII]

“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.” [Section VI]

NRB 15 uses the term “important information potential” and provides definitions and guidance in Section VI. 

RELIGIOUS PROPERTIES, BIRTHPLACES, GRAVES, CEMETARIES & COMMEMORATIVE PROPERTIES

Law

Not mentioned in the law.

Regulations

These resources fall under the category of “Special Considerations” in the regulations.

The following properties may be listed in the California Register:

  • religious properties
  • birthplaces
  • graves
  • cemeteries
  • commemorative resources

California Register criteria have no exceptions for these types of properties. As long as they meet the criteria in CCR §4852 (b)(1) through (4) and have integrity, they can be listed.

RELIGIOUS PROPERTIES, BIRTHPLACES, GRAVES, CEMETERIES & COMMEMORATIVE PROPERTIES

These resources are considered “Criteria considerations. Criteria considerations are usually expressed in lower case letters in parentheses.  For Example, “Criteria Consideration (a).”

The following properties are not normally eligible unless they met some very specific measurements: [National Register Criteria Considerations a, c, d, f]

  • religious properties [Consideration (a)]
  • birthplaces [Consideration (c)]
  • graves [Consideration (c)]
  • cemeteries [Consideration (d)]
  • commemorative properties [Consideration (f)]

For religious properties, it is to “avoid any appearance of judgment by government about the validity of any religion or belief.” (Section VII)

Birthplaces and graves may be “temporally and geographically far removed from the person’s significant activities, and therefore are not usual considered eligible.” (Section VII)

Cemeteries serve as a primary means of an individual’s recognition of family history and as expressions of collective religious and/or ethnic identity.” However, if cemeteries “embody values beyond personal or family-specific emotions, the national Register criteria allow for listing of cemeteries under certain conditions.” (Section VII)

Commemorative properties 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… [and] generally must be over fifty years old and must possess significance based on [their] own value, not on the value of the event or person being memorialized. ”  (Section VII)

MOVED BUILDING & STRUCTURES

Law

Not mentioned in the law.

Regulations

These resources fall under the category of “Special Considerations” in the regulations.

A moved building, structure or object that is otherwise eligible "may be listed in the California Register if:

  • it was moved to prevent its demolition at its former location and
  • if the new location is compatible with the original character and use of the historical resource.  

An historical resource should retain its historic features and compatibility in orientation, setting, and general environment." [CCR §4852 (d)(1)]

[See also the definition of object under CCR §4852(a)(4).] 

MOVED BUILDING & STRUCTURES

A moved building, structure or object under National Register criteria consideration (b) is usually not considered eligible for the National Register unless:

  • it is was moved prior to its period of significance (and is significant at its new site),
  • is significant primarily for architectural value, or
  • is the surviving structure most importantly associated with a historic person or event

Guidance for applying criteria consideration (b) is in Section VII.

PROPERTIES LESS THAN 50 YEARS OLD

Law

Not mentioned in the law.

Regulations

These resources fall under the category of “Special Considerations” in the regulations.

A resource that is less than fifty years old "may be considered for listing in the California Register if

  • it can be demonstrated that sufficient time has passed to understand its historical importance"
  • it does not have to be exceptionally important. [CCR §4852 (d)(2)]

This section states that "in order to understand the historical importance of a resource, sufficient time must have passed to obtain a scholarly perspective on the events or individuals associated with the resources."

PROPERTIES LESS THAN 50 YEARS OLD

A property that is less than fifty years old under National Register criteria consideration (g) is usually not considered eligible for the National Register unless it is of exceptional importance, a phrase that may be applied to the extraordinary importance of an event or to an entire category of resources so fragile that survivors of any are unusual.  Guidance for applying criteria consideration (g) is in NRB 15, Section VII.

"Fifty years is a general estimate of the time needed to develop historical perspective and to evaluate significance." [NRB 15 Section VII]

"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." [NRB 15 Section VII]

RECONSTRUCTED BUILDINGS

Law

Not mentioned in the law.

Regulations

These resources fall under the category of “Special Considerations” in the regulations.

A reconstructed building (as opposed to structure or object) is not listed in the California Register under CCR §4852 (b)(1)-events, (2)-lives, (3)-distinctive characteristics, etc.  A reconstructed building that is less than fifty years old "may be eligible if it embodies traditional building methods and techniques that play an important role in a community's historically rooted beliefs, customs, and practices, e.g., a Native American roundhouse." [CCR §4852 (d)(3)]

This is a broader interpretation than for reconstructions under the National Register, but it only applies to buildings, not structures, objects or districts.

RECONSTRUCTED BUILDINGS

A reconstructed property under National Register criteria consideration (e) is usually not considered eligible for the National Register unless it is accurately executed in a suitable environmental 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.  This applies mainly to reconstructions that are less than fifty years old because when they attain fifty years of age, they may qualify in their own right under any of the National Register criteria.  Guidance for applying criteria consideration (e) is in NRB 15, Section VII.