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Historic Tax Credit Tool Box: Change Over Time: Certification of Altered Buildings

Published by John M. Tess on Thursday, May 4, 2017

Journal cover May 2017   Download PDF

Commercial buildings are not static and do not exist in a vacuum. Intact buildings are rare. Rather, commercial structures are creatures of the real estate market and success invariably means they must be updated to meet evolving market expectations.

One apparent example is when a 1920s office tower is retrofitted with air conditioning. Other examples include modernized storefronts, window replacement, updated lobby spaces and modified floor plans. In some instances, these changes occur piecemeal when new tenants lease space. Sometimes a building owner will opt for a wholesale modernization to reposition the property in the marketplace.

Invariably, these changes alter the character of a building. Often, the changes reduce the character, such as the removal of a decorative cornice. And sometimes, the changes add, such as the installation of a modern storefront. The Secretary of the Interior’s Standards for Rehabilitation recognize that character changes over time and sometimes those changes acquire significance on their own. But then sometimes they do not.

Within the context of the historic tax credit (HTC) program, a property must be certified as a historic structure. In the case of a contributing building within a district, the challenge is simply to show that the building is not significantly different from when the district was listed on the National Register. Most often, these cultural resource values are embedded in the exterior and commonly buildings in historic districts face local historic design review, often based on the Secretary of the Interior’s Standards.

When the building is not located in a district, certification of an altered building potentially requires a more thoughtful and rigorous approach. Individual listing requires that a property have sufficient integrity to convey its historic values. But integrity and alteration should not be confused.

Alteration is a change to the building. Integrity is different. It is a function of significance and varies by situation. Integrity relates to why the building is historic. For example, if a building is important as a work by a prominent architect, then obviously alterations to the original design impact integrity. By contrast, alterations to a building of similar age and design may be less important if that building is important for its association with a historic person or trend. And if those alterations actually occurred before the period of association, those alterations actually can become character-defining features and contribute to the significance. 

This is the case of two downtown office buildings in Wichita, Kan. They were important as historic resources not for their original architecture, but for their post-World War II renovations, which represented the effort of early 20th-century buildings to survive and thrive in an automobile-friendly, postwar era.

Bitting Building

The Bitting Building was named for the Bitting brothers, local purveyors of dry goods. The building was constructed as a four-story building in 1911 and in 1919 seven stories were added. The completed expanded building was a handsome 11-story, classically inspired tan brick building with terra cotta detailing. At the time, it was considered the tallest building in the state.

In the ensuing decades, the building functioned as a successful office building and was fully occupied with an assortment of tenants. By the mid-1950s, however, the building was tired, while its systems were old and common amenities such as air conditioning were lacking. It faced dwindling revenues, increasing maintenance, higher vacancy and higher turnover. 

In 1959, the property was sold and the new owners launched a comprehensive $400,000 renovation. This renovation not only upgraded systems and finishes, but reskinned the exterior, which in essence created the image of one of Wichita’s new office towers, one befitting the prestige of the Bitting moniker. Exterior work included the replacement of the storefronts and main entrance, installation of a black Amazon granite base, installation of new aluminum-framed windows and installation of porcelainized fluted aluminum spandrels at the base and cornice. These renovations focused on creating a sleek and modern look. These changes then continued on into the lobby and upper floors.

Image: Courtesy of Heritage Consulting Group
The Fourth National Bank Building in Wichita, Kan., was built in 1916, but its historic character comes from alterations to compete in the post-World War II era.

Fourth National Bank Building

Directly across the street from Bitting is the Fourth National Bank Building, which originally housed the bank headquarters as well as speculative office space. The building was constructed in 1916 as a six-story classically inspired building that was expanded with a seventh story in 1923. Again, by the mid-1950s, the building had grown tired and was perceived as a stodgy, old-fashioned enterprise. 

As with Bitting, in 1958, a comprehensive renovation was completed. Embracing the then-popular Modern style of architecture, work included installation of a new façade skin that featured flush pink marble panels and deep red granite with aluminum-framed, single-light elongated sash and aluminum-fluted spandrels. With the bank as the sole occupant, this work extended into the interior with a redesign of the main banking hall, building lobby and upper floors.

National Register Listing

Were either project to seek certification as a historic structure based on the original architecture, that would have been problematic. Today, they no longer look as when built. But both buildings were not important for their 1920s construction. They were important as emblems of the struggle of older downtown buildings to survive in post-World War II, automobile-friendly Wichita. In both instances, the 1950s-era alterations became important character-defining features which fully illustrated the historic event for which the building were important. 

Image: Courtesy of Heritage Consulting Group
The Bitting Building and the Fourth National Bank Building, located across the street from each other (middle of photo) were renovated with historic tax credits (HTCs), with focus on their mid-century alterations, rather than their original structure.

Historic Tax Credits

In recent decades, both buildings were at least one generation old and faced a challenge similar to 1950s downtown commercial decline. Both were tired and facing a debilitating downward economic cycle of lower rents, higher costs and vacancy. By thoughtfully and subtly applying the National Register standards, both buildings gained access to the federal HTCs. Because the National Register nominations included the midcentury period, the corresponding alterations became character-defining features. 

Owner John McWilliams of KS1 LLC recently completed renovations of both the Bitting and Fourth National buildings, creating first-floor commercial tenant space with market-rate apartments on the upper floors and a unique rooftop pool amenity. Completion of these projects is integral to the transformation of the Douglas Avenue corridor and an important component of Wichita’s plan to become what local stakeholders call the next great river city. 


It important to recognize that the National Register and HTC programs are both flexible programs intended to recognize, preserve and rehabilitate a variety of building types in varying situations. That said, it is incumbent upon the applicant and consultant to fully understand that flexibility and to articulate the history, significance and character-defining features of the resource as it exists. This requires an intelligent and thoughtful approach to listing, articulating why a building is historically, architecturally or culturally significant. 

John M. Tess is president and founder of Heritage Consulting Group, a national firm that assists property owners seeking local, state and federal historic tax incentives for the rehabilitation of historic properties. Since 1982 Heritage Consulting Group has represented historic projects totaling more than $3 billion in rehabilitation construction. He can be reached at 503-228-0272 or [email protected].  

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