FAQ
Frequently Asked Questions about HABS, HAER, HALS and CEQA (HABS-Like) photography and the documentation of historic architecture, engineering and landscapes.
© 2023 Stephen D. Schafer
Speedread: WHAT IS HABS HAER & HALS PHOTOGRAPHY IN A NUTSHELL?
• The Historic American Buildings Survey, Historic American Engineering Record and Historic American Landscapes Survey are United States government programs (abbreviated HABS/HAER/HALS).
• They are administered by the Heritage Documentation Programs Department of the National Park Service (HDP and NPS).
• These programs document the historic built environment and cultural landscapes in America and work with the Library of Congress (LoC) Prints and Photographs division to archive architectural plans, historic reports and documentary photographs for the public in perpetuity.
• HABS, HAER and HALS are considered the gold standard of photographic documentation programs.
• Photographic documentation for these programs meets the Secretary of the Interior’s Standards for Architectural, Engineering and Landscape Documentation (SIS Doc Standards).
IS FILM STILL REQUIRED IN 2023?
Yes, large format, black and white film is still the only media that meets the photography guidelines for inclusion into the HABS, HAER and HALS (H3) collections.
Photographs from digital cameras (known as BORN-DIGITAL PHOTOGRAPHS) do not yet meet the Secretary of the Interior’s Standards for Architectural, Engineering and Landscape Documentation. The issue isn't sufficient resolution or megapixels, there are complex issues including data delivery, long-term storage and data manipulation that are still being considered by NPS and the LoC. Born-digital is coming, but currently analog large format photography is the only way to meet the Secretary of the Interior's Documentation Standards.
Many historic preservation mitigation requirements, for instance NEPA, Section 106 of the National Historic Preservation Act of 1966 (NHPA) and the California Environmental Quality Act (CEQA; EIRs, MNDs), reference the H3 guidelines specifically, and therefore they must also be recorded on archival, large format film to comply.
BLACK AND WHITE… WHY NOT COLOR?
All three programs, HABS/HAER/HALS (H3), require photographs be taken on black & white film. The technical requirement is silver-halide on a polyester base (similar to Ilford HP-5 or Kodak Tri-X). This film, if properly washed, is considered archival and resists fading resulting in a predicted Life Expectancy of 500 years (LE500) or more under proper storage conditions. Color film uses dyes and does not meet the LE500 requirement. Some resources that have colorful character defining features and many HALS landscape documentations may require both black and white and duplicate views on color transparency film. Additionally color digital images of the resource are often included in the field-notes (field notes are not required to meet the LE500 standard).
WHAT DOES LARGE FORMAT REFER TO?
Large format photography is captured by cameras that are capable of exposing large sheets of film that are a minimum of 4 x 5 inches. 5 x 7 inches or 8 x 10 inches are also common large format sizes. 5x7 is the preferred format for HABS/HAER/HALS documentation used by in-house NPS photographers at Heritage Documentation Programs in Washington DC.
Very important resources like the Golden Gate Bridge and the Statue of Liberty were recorded on 5x7. Large Format aerial photos are customarily made with 4x5 cameras because they can be hand-held in aircraft. 8x10 cameras are often used for studio copy-views of historic photos, blueprints and maps but are rarely used in the field because they are generally too heavy and cumbersome for extensive location photography.
WHY IS LARGE FORMAT REQUIRED FOR HABS?
Quality, Consistency, and Life Expectancy.
The long answer is a bit more wonky… The National Historic Preservation Act of 1966, [as amended, now codified in various sections of subtitle III of Title 54 U.S.C.] requires documentations meet the Secretary of the Interior’s Standards for Architectural and Engineering Documentation. [48 Fed. Reg. 44,716 (1983)]. The “Standards” require large format film photography because it is durable, archival and records maximum data. The National Park Service and Library of Congress (LoC) have systems and collections in place for archiving and disseminating the large format images to the public making them accessible.
Because the HABS documentation guidelines and specifications are the best practices for photographic documentation, state and regional policies have now adopted the HABS standards. So from NEPA and CEQA to city ordinances and school districts the HABS guidelines, requiring large format photography, are now the de facto standard. If historic resources are impacted by new projects, demolition or alteration, there is often a requirement to document the historic property by following the HABS\HAER\HALS recording guidelines (which means the SI Standards).
WHAT 3 THINGS CONSTITUTE A QUALITY DOCUMENTATION?
Documention that meet the intent of the Standards have three main elements:
2.) The film negatives, archival prints, report, measured drawings and captions must all be created on archival materials, and the film shall be processed to archival standards to insure of 500+ year Life Expectancy (LE500).
3.) In order to truly be a public benefit, the photos and report must be accessible to the public. This is the reason records are sent to the Library of Congress and the reason the HABS/HAER/HALS online collection is one of the most popular. (It receives nearly 50,000 visitors a month.) In order for documentations to indeed mitigate impacts they must be in the public domain (uncopyrighted) and accessible to provide architects, engineers, scholars, preservationists, and interested members of the public with information on the historical, technological, and cultural significance of America's historic resources.
The only way to meet the SIS is through a process that insures that the photographs, reports and/or drawings are transmitted to the HABS/HAER/HALS Preservation Documentation Program of the NPS, and then the NPS can transmit the documentation to the Library of Congress for public dissemination. When donation to the NPS/LoC is not possible, it is imperative that the documentation be 1. max-data, 2. archival and 3. public. Local museums, archives or libraries can serve this purpose, though not with the reach and storage ability of the LoC. Archives selected to receive a mitigation project need to be be easily accessed and used by the public. A documentation/mitigation that ends up on a shelf in city hall or in a sealed military library or damp basement archive accessible only by secret handshake, fails at providing public benefit of any kind.
HABS-Style, HAER-Like and Diet-HALS (H3-Like) are made-up terms, and as such, they require definition on a case by case basis. In our experience, these parameters are an attempt to establish an lower-quality record than official HABS/HAER/HALS documentations. There is no formal definition for HALS-Like or HAER-ISH or Diet-HABS because the consultants writing the mitigation – not the NPS – are making up new rules.
In our experience it usually means that H3 guidelines for approach, content and deliverables are followed closely but the finished documents (prints and negatives) may not be submitted to the Library of Congress. Sometimes the photos, drawings and reports are distributed locally only. Sometimes only prints are required, sometimes 35mm film or digital capture and color prints. Some of the weaker documentary surveys in California triggered by CEQA to mitigate significant impacts in Environmental Impact Reports (EIRs) or Mitigated Negative Declarations (MNDs) are HABS-like, but note that while H-Like documents may be required by a local lead-agency, they do not meet the mitigation requirements in federal projects and they do not meet the Secretary’s Standards for Architectural and Engineering Documentation. Until records are transmitted to the NPS Regional Office for review or a donation of H3 records is submitted to NPS and official numbers assigned, they are not real HABS, HAER or HALS documentations*. In state or local H3-like documents, it is important to put the photographs in the public domain and make copies of the report available to the public in multiple, accessible locations.
* Note: To avoid confusion, documentations not sent to NPS/LoC should never have the acronyms HABS/HAER or HALS printed anywhere or have a HABS/HAER/HALS number that implies acceptance to NPS/LoC.
HOW MANY PICTURES DO YOU NEED FOR A TYPICAL HABS/HAER/HALS PHOTO PROJECT?
Number of views is always a complex question. The answer is as diverse as the historic heritage we document. It comes down to significance, budgets, time, access, motivations, lawsuits, insurance, etc. If the building is a little garage in a historic district, a couple-three views may be sufficient. If that garage is the "HP Garage" birthplace of the Silicon Valley, then it would likely warrant more views. For example, what about demolition of Heim Bridge in Long Beach, the largest lift-span bridge in the Western United States? 27 views? 39 views? 75? Or 111?
In complex recording projects, the scope needs to be informed by the size of the resource, its context, its complexity and its significance. In the Heim Bridge example, forty HAER field-views were taken in the field, forty copies were made of original engineering drawings to explicate the bridge's engineering significance. Without access to the historic blueprints and plans, many more detailed field view photographs of the bridge would have been warranted.
How was that quantity determined? Scouting, asking a lot of questions and working with an architectural historian to analyze the bridge's significance and character defining features. There is no simple guideline, but working with a preservation expert and an experienced HABS/HAER/HALS photographer can help with complex scoping. The intent is to tell a complete story about the resource which may mean interiors, context, landscape, details and possibly even aerials if the resource is a large district or property. However the documentation should not be excessive, punitive or disproportionate to the significance of the resource.
HOW MANY DELIVERABLE COPIES ARE PRODUCED FOR A TYPICAL HABS/HAER/HALS SURVEY?
Two or more usually. If the documentation package is formally reviewed by the National Park Service (NPS) Regional Office for transmittal to the Library of Congress, then customarily 1 set of negatives and 2 sets of prints are delivered. Often additional copies are requested by the lead-agency, the State Historic Preservation Officer (SHPO), consulting parties or the Advisory Council on Historic Preservation (ACHP) to fulfill local mitigation obligations or conditions. Local museums are typical recipients of documentation reports. Often libraries, historic societies, state museums, universities, the State Historic Preservation Office (SHPO) and even advocacy groups are listed to receive copies of records.
It again comes down to significance. If the building is the "HP Garage," birthplace of the Silicon Valley, its regional importance could warrant duplicate copies in every library in the Silicon Valley. State and local H3-Like documentations require one or more sets of negatives and multiple print-only copies to archives such as state or regional museums, historic societies, university libraries and regional information centers. Because the negatives and prints are expensive to produce, original copies may not be warranted for all archives. Archival laser-copies or a DVD of digital scans may be sufficient for historic societies, local libraries; planning departments may only need a digital copy to sign off on the mitigation and they may not be able to store original negatives or prints in controlled conditions. It might seem that uploading reports and images to the web would be much easier but the necessity of maintaining a website, links and hosting digital documents in perpetuity makes printed copies more reliable (Have you ever been linked to a website that didn't exist?).
IS THERE A WAY TO DO HABS-Like DOCUMENTATION FOR LESS?
Accepted HABS/HAER/HALS documentations are transmitted to the Library of Congress (LoC). The negatives, drawings and history are (eventually) scanned and made keyword searchable. They are made available on the LoC website for easy access and download by anyone worldwide. The negatives are archived to achieve a 500-year life expectancy in secure, temperature- and humidity-controlled conditions at Fort Meade in Maryland. The prints are always available for viewing by the public in the LoC Prints & Photographs Division in the Madison Building in Washington, DC.That sure is a perfectly stored, and publicly accessible document! It’s counterintuitive, but you can save time and money on local documentations if the record meets the HABS/HAER/HALS guidelines and the documentation is donated to the H3 Collections through the HDP direct-donation procedure. Costly duplicate copies are not required. Multiple costly negatives are not required negatives. No time is wasted on NPS regional office review. No chasing down acceptance forms from local historic societies and museums. If your record already meets H3 guidelines, then making multiple sets of will cost more (and still never be as good), and making one set for NPS/LoC will cost less. One way to save money is by making one set of photos and donating them to the HABS/HAER/HALS collection. To donate a record to any of the H3 collections using direct-donation see this HOW-TO on my HABS MADE BETTER & CHEAPER page.
HOW TO HIRE A HABS, HAER or HALS PHOTOGRAPHER.
Large documentation projects can be quoted directly by phone or RFP. It is advisable to consult a professional familiar with Historic surveys (architectural historian, preservation planner, photographer) to help with the scope of a RFP. The sixteen most important questions to answer when contracting H3 surveys are listed here:
1. Number of HABS/HAER/HALS views required?
2. Is one set going to the Library of Congress as a donation or through NPS review?
3. What format: archival large format film (4x5, 5x7), digital, or other?
4. How many sets of film negatives per view?
5. How many archival mount card sets are needed for distribution?
6. Are duplicate color digital views required for each B&W film view?
7. Who is creating the final HABS captions and Photo Index and key maps (photographer or client)?
8. What people or agencies are reviewing the drafts?
9. What is the underlying project that requires documentation?
10. Is there a specific MMP, MOA, EIR mitigation, or condition of approval that the documentation must fulfill?
11. Daylight hours of access permitted?
12. Access issues: dirt roads, boats, boarded windows, stairs, locked access gates, security clearance or escort required?
13. Known conditions on site: snow, water in creek under bridge, bees, fleas, rats, bats, feral cats, pigeons, poison oak, hostile tenants, crackheads?
14. PPE required (Boots, hardhats, vests), security escort, lift equipment, climbing harnesses, aircraft, breathing masks, hazmat suits?
15. Electricity available, do elevators work, lights for interiors?
16. Is 2M/4M enough insurance coverage for the contract?
CAN ANY PHOTOGRAPHER DO HABS/HAER/HALS?
Yes, the HABS/HAER/HALS photography guidelines can be downloaded from the NPS website. Any photographer with experience using large format cameras and film (4x5 and 5x7 cameras) and familiar with perspective control can do a H3 photo survey. If you have the time to learn, 4x5 cameras, can be rented in larger markets like New York, San Francisco and Los Angeles for those wanting to try out the equipment. It should be noted that the requirements for acceptance of records are stringent. The guidelines for recording, processing and transmitting HABS/HAER/HALS surveys are available for download (PDF 32 Pages) and it takes some time to master the field photography workflow, logistics, field notes, maps, darkroom work, archival washing and printing. We have found that for every day of fieldwork making photographs, there are four additional days of darkroom and post production required to complete and ship final deliverables. Unfortunately we have also been called to redo documentations submitted to HDP by inexperienced photographers that were rejected because they did not meet archival specifications. Some photographers may not carry the required insurance or may not wish to sign away their copyright to photographs and release them into the public domain (a copyright release is required with every HABS, HAER and HALS transmittal). Therefore, you may only find a handful of photographers in any region with the desire, training, equipment and experience to deliver a HABS/HAER or HALS survey on time and on budget.
Suggested reading for photographers:
Recording Historic Structures (2nd edition)
A Record in Detail by Jack E. Boucher.
Industrial Eye by Jet Lowe.
A Constructed View by Julius Shulman.
DOES A HABS DOCUMENTATION NEED TO BE PRINTED IN A DARKROOM?
An in-house darkroom can improve turn-around times and keeps the negatives from being shipped off-site for developing and printing, but since June 2015, HABS guidelines have allowed for "Digital Print Cards.”
The resource is still photographed on large-format film and the film processed and archivally washed as before. Then, instead of being contact-printed in a wet darkroom, the negative is scanned and printed on a digital pigment printer using archival inks. This generally does not save time, but it allows photographers without darkrooms to make H3 prints. "HABS Digital Print Cards" may also be a less time consuming way to make large numbers of printed copies for numerous museums and libraries.
DOES A SITE NEED TO BE ON THE NATIONAL REGISTER TO BE INCLUDED IN HABS?
Sites documented for the HABS, HAER, HALS collections should be historically significant. However, sites do not need to be formally registered on the National Register of Historic Places or be Landmarks to be documented. The HABS/HAER/HALS collection seeks to record "A Complete Resume of the Builders' Art", including folk and vernacular examples of historic resources and sites that may only be locally significant. In 2017, the Associate Director, Cultural Resources, Partnerships and Science, in a memo [H1817(2270)] to all State and Tribal Historic Preservation Officers, clarified that "…HDP, will accept all documentation of National Register and National Register-eligible properties of national, state, regional or local significance…” So if a building, district, object, structure or site is Local, State or National Register eligible then large format photography would be the prescribed mitigation.
WHAT MAKES A MORE MEANINGFUL HABS PHOTO MITIGATION?
How to make a good documentation better? Even More meaningful? Try adding ten Print On Demand (POD) books of H3 reports, drawings and photographs to the requirements and add another method of public accessibility and make your mitigation work even harder. Schaf Photo has created a number of easily distributable H3 Books, and one example is the Lovelace Garden HALS book linked below. The beauty of these inexpensive POD books is they can be printed on demand and distributed to a bunch of local libraries that have a familiarity with storing, shelving and sharing paperback BOOKS, but may not have the facilities or ability to properly store and share delicate negatives, loose archival prints or full size drawings. The printer we use for these books is HP Magcloud because an additional benefit is that every book they print is available perpetually online for free download to a computer or a tablet as an E-Book. Order a book from the Magcloud website and it will be printed and shipped On-Demand or download the book to any phone anywhere free. Look at samples of complete HABS documentations here and download digital versions:
LINK TO OUR SAMPLE MAGCLOUD BOOKS
In order for a documentation to be meaningful and truly counterbalance an adverse impact it needs to be useful and available. In order to implement meaningful mitigations that are both a public benefit and contain all the information needed for a comprehensive scope, we created some suggested text for a typical HABS/HAER/HALS mitigation as you might find in an EIR or EIS. It is linked here as a PDF, or search the web for "CULTURAL HABS PHOTO MITIGATION." PDF > DOCUMENTATION MITIGATION SAMPLE TEXT
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STEPHEN SCHAFER ©2023
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