Identifying Historic Properties for Project Review

Under Section 106 of the National Historic Preservation Act, federal agencies must consider the effects of their actions on properties that are listed in, or eligible for listing in, the National Register of Historic Places. The Maryland Historical Trust Act requires state agencies to follow the same process. 

Before they can consider effects, agencies must first identify historic properties in consultation with the Maryland Historical Trust (MHT). They can do this by:

• searching existing data
• conducting new research
• completing Determinations of Eligibility (DOEs)

Learn more about the state and federal project review process.

Searching existing data

MHT maintains extensive records and information on the state’s historic and archaeological resources, including National Register-listed properties, in:

• Medusa, the state’s cultural resource information system, and
• the MHT Library.

Local government planning offices may also have data on historic and cultural resources in the area that will be affected by the project.

Conducting new research

In some cases, existing data may not be sufficient for project review, and agencies (or recipients of agency assistance) may need to do field research. Before conducting new research, however, it is important to consult with MHT to develop the necessary scope of work.

MHT provides helpful guidance for completing archaeological studies as well as architectural field research:

• Standards and Guidelines for Archaeological Survey and Excavation - PDF - 28.06 MB
• Standards and Guidelines for Architectural and Historical Investigations - PDF - 16.88 MB

The National Park Service, which maintains the National Register, also offers extensive guidance for documenting historic properties and assessing National Register eligibility.

In most cases, agencies (or recipients of agency assistance) will need to hire qualified consultants to complete field research. Before beginning work, consultants should request copies of all MHT correspondence related to a project from their client. 

When existing data or new research identifies previously unevaluated properties — typically 50 years of age or older — agencies prepare a DOE to evaluate National Register eligibility, in consultation with MHT.

Completing DOEs

This section outlines the requirements for completing architectural DOEs. 

Before beginning survey documentation, contact the Architectural Registrar (contact details below).

If your project includes properties that do not have Maryland Inventory of Historic Properties numbers yet, request one at this time. Requests to the Architectural Registrar should include:

• property name and address
• USGS 7.5-minute quadrangle map (1:24,000 scale) showing the property location
• zoomed-in map clearly showing the property boundary
• tax map for urban properties 

Even if new Maryland Inventory numbers are not needed, contact the Architectural Registrar so that a Microsoft Teams channel can be created for the project. To establish a Teams channel, provide:

• name of project
• name of agency undertaking the project
• email addresses of all staff who require access (agency and consultant staff) 

Preparing the DOE form

The DOE form is designed to comply with Title II of the Americans with Disabilities Act and should be completed using the fillable fields and check boxes provided.

Incorporating supporting documentation

All supporting documentation must be embedded within the DOE form rather than submitted as separate documents. This typically includes:

• maps
• figures and drawings
• photographs
• photo log 

To insert supporting documentation:

1. Click within the designated field to insert a figure, drawing, map, or photograph.
2. Use the “+” icon in the caption field to add additional images.
3. Add alt text to each image by right-clicking the image and selecting View Alt Text. Alt text should be brief and specific (generally 35–100 characters), e.g., “Red-brick Georgian building with a large, white timber dome.”
4. Compress images by selecting Picture Format → Compress Photo → Print quality. 

Digital photographs

Photographs should give a complete view of the property, including front and side elevations, surrounding setting, distinctive features, and any significant alterations. In most cases, no more than 20 images are needed.

Each image must include a clear caption in the DOE form that corresponds to an entry in the photo log.

Use original or uncompressed source images. Save files as uncompressed TIFFs at a minimum resolution of 3000 × 2000 pixels at 300 dpi. Avoid unnecessary enlargement – images should be high quality but reasonably sized for transfer. 

Name all files according to the Standards and Guidelines for Architectural and Historical Investigations.

Before submitting the DOE

Before uploading materials to the project Teams channel, confirm the following:

1. National Register evaluation

• The DOE must clearly state whether the property is eligible or not eligible for listing in the National Register.
• Identify applicable National Register Criteria (A–D) and any relevant Criteria Considerations (A–G).
• Explain how historic integrity supports the determination. Detailed historic context should be reserved for Section 8 (Significance).

2. Form content

• Section 7 (Description): Begin with a brief summary, then describe the property as it exists today, including form, materials, construction methods, condition, setting, and alterations over time.
• Section 8 (Significance): Provide a narrative history explaining why the property is important, based on research such as deeds, maps, newspapers, and other sources. Do not repeat the eligibility determination here.

3. Accuracy check

• Ensure property name and location in Sections 1 (Name of Property) and 2 (Location) exactly match information provided to the Architectural Registrar. Report any changes immediately.
• Verify contributing vs. non-contributing resource counts in Section 6 (Classification).
• Confirm Section 10 (Geographical Data) includes accurate acreage required for reporting. 

Submitting materials 

Upload all files to the Teams channel established by the Architectural Registrar.

Create a separate folder for each property, named using its assigned Maryland Inventory number. Do not combine multiple properties in one folder. Each folder must include:

• completed DOE form with all documentation embedded
• separate TIFF image files

Once uploaded, files should not be altered, replaced, or deleted unless specifically requested by MHT staff. The Teams channel serves as a temporary submission workspace; materials will be transferred to MHT’s permanent archive and then removed from Teams. Maintain your own backups.

All Section 106 consultation materials and project correspondence must be submitted through MHT’s e106 Project Submission Portal. The Teams channel is used only for DOE file transfer and is not monitored for comments or questions. Direct all inquiries to your assigned MHT project reviewer.