The Advisory Council on Historic Preservation (ACHP) is developing a Program Comment on Accessible, Climate-Resilient, Connected Communities that aims to provide federal agencies with an alternate way to comply with their responsibilities under Section 106 of the National Historic Preservation Act. In doing so, ACHP invited public comment on their proposal. Along with 13 of our Preservation Colleague organizations across the state, the following letter was sent to ACHP in response to their proposed Program Comment on Accessible, Climate-Resilient and Connected Communities. Click here for a PDF of this letter.

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Advisory Council on Historic Preservation
Sarah Bronin, Chair
401 F Street NW, Suite 308
Washington, DC 20001

Dear Chair Bronin:

We appreciate the opportunity to comment on the draft Program Comment on Accessible, Climate-Resilient and Connected Communities. On behalf of the undersigned New York-based preservation nonprofit organizations, the Preservation Colleagues network, we respectfully submit the following comments.

We recognize the need to streamline the Section 106 consultation process in certain areas and appreciate that the ACHP is focusing on housing and climate. As preservation organizations, we advocate for affordable housing projects, climate resilience and sustainability in the built environment, and transportation alternatives. It is imperative that the preservation movement promote these efforts and communicate the essential role that preservation plays in advancing more resilient and equitable communities.

However, we are concerned that the draft Program Comment is too broad in scope and places too much responsibility on federal agencies and/or their consultants to review their own undertakings. As such, it runs counter to the intent of the National Historic Preservation Act and risks irreparably harming the nation’s historic resources. Specific comments are as follows:

• We support streamlining the Section 106 process and agree that many of the project types included in the Program Comment are sensible. Projects that are unlikely to impact historic resources—such as electrifying appliances, replacing non-historic playground equipment, or replacing asphalt surfacing, to name a few—should indeed be exempted from the standard Section 106 review process.

• For projects with potential adverse effects, we do not support removing SHPO (and other consulting parties) from the Section 106 process. Federal agencies should not be given full decision-making power over their own projects. Many of the project types in the Program Comment require nuanced consideration by an experienced preservation professional (or a person recognized by the relevant Indian Tribe or Native Hawaiian Organization to have expertise, where appropriate). SHPO staff provide objective assessment and have extensive experience reviewing potential impacts and applying the SOI Standards. For many project types, they are best suited—alongside design professionals and project sponsors— to explore creative solutions that accomplish the dual goals of preserving character defining features while also providing affordable housing and/or advancing climate goals.

• We want to see a re-evaluation of project types that would be covered by the Program Comment, in consultation with SHPO staff. Of particular concern is the exemption of building exteriors, including windows, doors, and the use of substitute materials. Both primary and secondary elevations should remain subject to the standard Section 106 process.

• We recommend a revision to the definition of housing to support the preservation and production of affordable housing. The current definition makes no mention of affordability; presumably the Program Comment could apply to any undertaking that involves housing, regardless of ownership or affordability.

• The lack of notification requirements is concerning and could result in the intentional or unintentional loss of historic resources and/or character defining features that have not yet been identified in surveys or listed in the National Register. This could disproportionately impact historically marginalized communities, which are generally less well documented.

• We also want to see a shorter initial duration of the Program Comment and do not support unilateral extension of the duration by the Chair.

• We strongly recommend more robust reporting requirements, including an annual report from participating federal agencies of all undertakings covered by the Program Comment, particularly in the first years that the Program Comment is in effect. Reporting should include in-depth evaluation by ACHP with input from preservation partners such as SHPOs and nonprofit preservation organizations.

• Overall, we are concerned that the broad scope of this Program Comment sends the message that preservation is an obstacle to affordable housing and climate solutions. Modern preservation best practices actively promote both. Often, the treatment that meets the SOI Standards is, in the long term, the more economical and sustainable treatment and provides building occupants with an enhanced quality of life.

While we support streamlining the Section 106 process in principle and support many of the exemptions included in the Program Comment, we do not believe that the current draft achieves an equitable balance between streamlining review processes, protecting historic resources, and providing public input in federal undertakings. Thank you for your consideration.

Sincerely,

Adirondack Architectural Heritage, Erin Tobin, Executive Director
Friends of the Upper East Side Historic Districts, Nuha Ansari, Executive Director
Historic Albany Foundation, Pamela Howard, Executive Director
Historic Districts Council, Frampton Tolbert, Executive Director
Historic Ithaca, Susan Holland, Executive Director
Landmark Society of Western New York, Wayne Goodman, Executive Director
New York Landmarks Conservancy, Peg Breen, President
Preservation Association of Central New York, Nicole M. Fragnito, Executive Director
Preservation Buffalo Niagara, Bernice Radle, Executive Director
Preservation League of New York State, Jay DiLorenzo, President
Preservation Long Island, Tara Cubie, Preservation Director
Saratoga Springs Preservation Foundation, Samantha Bosshart, Executive Director
TAP Inc., Barb Nelson, AIA, Executive Director
Village Preservation, Andrew Berman, Executive Director

Since 2022, our colleagues at Village Preservation have been requesting that the New York City Landmarks Preservation Commission provide an evaluation of the historic New York Eye and Ear Infirmary. With the closure of Beth Israel Hospital, which operated the infirmary, it’s crucial that this historic institution is designated a landmark and saved from destruction. The League provided this letter of support echoing Village Preservation’s advocacy efforts. Click here for a PDF of the letter.

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Hon. Sarah Carroll, Chair
New York City Landmarks Preservation Commission
1 Centre Street, 9th floor
New York, NY 10007

RE: Request for Evaluation for the New York Eye and Ear Infirmary, 218 Second Avenue/216-222 Second Avenue/301-309 East 13th Street

Dear Chair Carroll:

The Preservation League of New York State writes in strong support of Village Preservation’s 2022 Request for Evaluation of the New York Eye and Ear Infirmary at 218 Second Avenue/216-222 Second Avenue/301-309 East 13th Street. We urge the Landmarks Preservation Commission to swiftly designate this building as a New York City Landmark.

The building is architecturally significant as an intact example of late 19th century architecture in the East Village. Perhaps even more compelling is the building’s historic significance and its associations with Black history and disability history.

The New York Eye and Ear Infirmary as an institution became an icon of comprehensive and accessible care for the public, attracting Helen Keller to speak at the ribbon cutting for its final stage in 1903. In addition to providing trailblazing medical care for people with disabilities, it was also home to the first Black ophthalmologist in the U.S., Dr. David Kearny McDonogh, who was also the first formerly enslaved person in the country to earn a college degree.

Landmark designation of 218 Second Avenue would help preserve the stories of Black Americans and Americans with disabilities, two marginalized groups whose important stories and places have traditionally been excluded from local, state, and federal designation.

Sincerely,

Jay DiLorenzo
President

This petition is being shared on behalf of our colleagues at the New York Landmarks Conservancy.

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Everyone wants an improved Penn Station and better service for riders.

Amtrak says we need a new underground station for New Jersey Transit. Building that would likely require demolishing the block south of Penn filled with affordable homes, local businesses, and landmark quality buildings.

Proponents of through-running say it could increase capacity within Penn without demolishing anything, and improve service throughout the region.

Billions of taxpayer dollars are at stake. Who’s right? The public deserves an answer.

An independent peer review panel could answer the question.

On Friday, July 19, this open letter was sent to New York City Mayor Eric Adams and other elected officials to protest the proposed demolition of the historic Tony Dapolito Recreation Center in Greenwich Village. The letter was co-signed by the League along with out colleagues at The New York Landmarks Conservancy, Historic Districts Council, Village Preservation, Landmark West!, and Save Harlem Now!. Click here to view this letter as a PDF. For more context on this advocacy work, please visit Village Preservation’s website.

Re: Potential demolition of the historic Tony Dapolito Recreation Center, 1 Clarkson Street, Manhattan

Dear Mayor Adams, Commissioner Donoghue, Chair Carroll, Borough President Levine, Councilmember Bottcher, and Chair Kent:

We write to share our deep concerns about the New York City Department of Parks & Recreation’s announced intention to pursue demolition of the historic Tony Dapolito Recreation Center, located within the Greenwich Village Historic District Extension II. We are dismayed that the City is considering destroying a nearly 120-year-old landmarked, National Register-listed, City-owned and operated building.

The boundaries of the Greenwich Village Historic District Extension II, designated by the NYC Landmarks Preservation Commission on June 22, 2010, were explicitly drawn to include the Tony Dapolito Recreation Center (formerly the Carmine Street Public Baths, and subsequently the Carmine Street Recreation Center). In fact, in an unusual move, this and the adjacent Hudson Park branch of the New York Public Library were included in a non-contiguous section of the extension, speaking to the lengths to which the Landmarks Preservation Commission went in 2010 to ensure these buildings were designated — not a surprise given their incredibly rich history and architectural significance. In 2013, the Recreation Center was also listed in the National Register of Historic Places as a contributing structure within the South Village Historic District, recognizing its local, state, and national significance.

The building was commissioned by the City and constructed in phases, beginning in 1906-08 to a design by architectural firm Renwick, Aspinwall & Tucker, and has been serving the public ever since. First designed as a public bath house occupying the eastern end of Hudson Park (now James J. Walker Park), the building has been integral to the park’s design for the past nearly 120 years. As indicated in the LPC designation report, the bath house opened on May 6, 1908, as one of “several public bath houses constructed around the turn of the century as part of a city-wide initiative to provide bathing and hygiene facilities to all New Yorkers.” Two subsequent phases of construction occurred in 1922 (architect: Jaros Kraus) and 1929 (architect: Mitchell Bernstein).

NYC Parks’ claim at a recent Community Board 2 meeting that the structure is too difficult to repair, due in part to its phased construction, is entirely unfounded. Countless historic landmarks throughout New York City that have been restored, repaired, and preserved have also been altered over time, whether during early development (for example, the Astor Library, an individual landmark that was famously designed and built in three distinct phases), or as modern insertions, like the innumerable rooftop and rear yard additions we regularly see approved by LPC in all historic districts. Multiple phases of construction certainly do not preclude a building from being repaired, nor from preservation.

That the Recreation Center is in need of repairs, or that some of its interior facilities do not currently meet code, are also not cause to demolish a protected historic building. It is alarming to hear city officials claim that deterioration at this building, the maintenance of which is the responsibility of the City itself, should be a green light for demolition. The building is undoubtedly in need of repairs, but this is no justification for its demolition.

We strongly oppose demolition of the Tony Dapolito Recreation Center, and urge the City to take steps now to restore this historically, architecturally, and culturally significant public asset, so that the space can be reactivated and serve its intended purpose as an amenity for the people of New York.

Sincerely,

Jay DiLorenzo, President, Preservation League of NYS
Peg Breen, President, The New York Landmarks Conservancy
Frampton Tolbert, Executive Director, Historic Districts Council
Andrew Berman, Executive Director, Village Preservation
Sean Khorsandi, Executive Director, Landmark West!
Claudette Brady, Executive Director, Save Harlem Now!

Cc: State Senator Brian Kavanagh, Assemblymember Deborah Glick, Elizabeth Goldstein, President, Municipal Art Society

We need you to reach out to your representatives in the NYS Senate and Assembly and tell them you do not support the “Faith-Based Affordable Housing Act,” (A08386/S07791) unless it is amended to retain protections for landmarked properties.

As budget negotiations grind on in Albany, a bill that could have a disastrous impact on religious properties throughout the state is moving its way through committee. The innocuous-sounding “Faith-Based Affordable Housing Act” enjoys a lengthy list of co-sponsors in the Assembly and Senate, as well as the backing of a well-funded advocacy group that has opposed landmarking.

The stated purpose of this legislation is to allow religious corporations to bypass local zoning and other protections in order to expedite the construction of affordable housing on their land. Building departments would, ministerially and without discretionary review or a hearing, approve applications for building permits under the bill within 60 days of application. Full environmental reviews under the State Environmental Quality Review Act (SEQRA) would not be required so long as the landowners submit various certifications addressing soil and water issues.

There are no protections included in this legislation for landmarked historic religious properties and it could, in some cases, allow the alteration and demolition of these properties. While this legislation is presented as a housing bill, we are concerned that it could weaken and remove landmark protections more broadly.

Connect with your representatives here: NYS Assembly | NYS Senate

Click here for a PDF of this letter.

The Honorable Kathy Hochul
Governor of New York State
New York State Capitol Building
Albany, NY 12224

Re.: New York State Historic Preservation Tax Credit

Dear Governor Hochul,

On behalf of the undersigned, a coalition of advocates and practitioners in the fields of historic preservation and affordable housing, thank you for your commitment to historic preservation, affordable housing, and community development projects throughout the state.

Together, we are advocating for an important enhancement to the New York State Historic Preservation Tax Credit program that will advance the development of affordable housing and community development projects in New York State, while saving the state money.

The New York State Historic Preservation Tax Credit (NYS HTC) has been an indispensable tool for revitalization in New York State. By incentivizing the reuse of our existing historic buildings, it has encouraged sustainable, environmentally friendly development that has kept valuable building materials out of landfills, strengthened existing walkable communities, reduced greenfield development, and protected our historic buildings and downtowns. Communities throughout New York have used the NYS HTC to transform their Main Streets and downtowns. In Buffalo alone, projects that would not have succeeded without the NYS HTC include the Richardson Complex, Larkinville, Lafayette Hotel, Artspace Buffalo, and the Evergreen Lofts, among many others. It is also a highly effective tool for housing creation: since 2010, the state tax credits have been responsible for the creation of 21,929 housing units, 8,542 of which are low/moderate income units.

Current New York State law requires the NYS HTC to be allocated in the same manner, and to the same parties, as the Federal Historic Preservation Tax Credit. This required allocation depresses the pricing of both tax credits by limiting the pool of tax credit users. This means less money flowing to important community revitalization and housing projects. As development costs rise, and buildings become more challenging to develop, we need to enhance this important tool now to keep our momentum going. Allowing the allocation of the NYS HTC to investors other than those who are allocated the Federal Historic Credit would open up and broaden the investor market, increasing the value of the credit and injecting more equity into these projects.

Enhancing the NYS HTC in this small way would have some big benefits.

1. More affordable housing. A more flexible program would increase the appetite for taxcredits amongst new investors who would want to invest in New York State projects.

2. Less cost to New York State. The amount of credit received by an investor is the same, nomatter what they pay for it. If they pay less than face value, New York State is often obligatedto add additional grant funds to get these projects done. This change will increase the valueof the credit.

3. More money for projects. Credits have reduced value to an investor if they can’t take full advantage of them. We are leaving money on the table if credits are used at a reduced cost or not all.

4. We will be helping the climate. Building demolition and new construction is a major source of greenhouse gas emissions, and it pours tons of materials into our landfills each year. If we incentivize building reuse, we are helping the environment.

Let’s make this small enhancement to the NYS HTC now and build a better New York one building at a time.

Sincerely,

Adirondack Architectural Heritage, Erin Tobin Executive Director
Beacon Communities, LLC, Dara Kovel, CEO
CREA LLC, Tony Bertoldi, Co-President
Historic Albany Foundation, Pamela Howard, Executive Director
Historic Districts Council, Frampton Tolbert, Executive Director
Home Leasing, Bret Garwood, CEO
Landmark Society of Western New York, Wayne Goodman, Executive Director
Lettire Construction Corporation, Nicholas Lettire, President
LISC NY | Local Initiatives Support Corporation, Valerie White, Senior Executive Director
New York State Association for Affordable Housing, Jolie Milstein, President and CEO
Preservation Association of the Southern Tier, Andrew Roblee, President
Preservation Buffalo Niagara, Bernice Radle, Executive Director
Preservation League of New York State, Jay DiLorenzo, President
Preservation Long Island, Alexandra Parsons Wolfe, Executive Director
Rockabill, Niall J. Murray, Managing Principal & CEO
RUPCO, Kevin O'Connor, CEO
Saratoga Springs Preservation Foundation, Samantha Bosshart, Executive Director
Urban Builders Collaborative, Matthew Gross, Partner
Xenolith Partners LLC, Andrea Kretchmer, Principal

cc:

(VIA EMAIL)

Tania Dissanayake, Deputy Secretary for Housing
Ashley Dougherty, Assistant Secretary for Environment
Amanda Hiller, Acting Commissioner, Taxation and Finance
Roger Maldonado, Assistant Counsel
Karen Persichilli Keogh, Secretary to the Governor
Erik Kulleseid, Commissioner, Office of Parks, Recreation, and Historic Preservation
RuthAnne Visnauskas, Commissioner/CEO, Division of Homes and Community Renewal
Blake G. Washington, Director, Division of Budget

November 21, 2023
Governor Kathy Hochul
Executive Chamber
New York State Capitol
Albany, NY 12224

RE: FY2024-25 New York State Budget | Click here for a PDF of this letter.

Dear Governor Hochul,

On behalf of the undersigned members of New Yorkers for Clean Water and Jobs, a large coalition of conservation, environmental justice, labor, business, local government, outdoor recreation, and public health groups, thank you for your leadership on environmental conservation. State funding is essential for communities to leverage federal funds and deliver clean water, clean air, access to nature, and local jobs to New Yorkers. We applaud your dedication to growing environmental funding through the state budget, and the work of your agencies to efficiently award grants to projects throughout the state.

Thank you for your leadership on promoting the Clean Water, Clean Air, and Green Jobs Environmental Bond Act, and educating communities and organizations on the potential for programs through the recently concluded Bond Act listening tour. We were thrilled to see stakeholders come out across the state to learn about how they can work with your administration to implement this historic measure. We also thank you for working with the Senate and Assembly to ensure this year’s budget authorized necessary capacity at state environmental agencies to achieve urgently needed work to address pollution and environmental degradation across New York and realize our state’s ambitious conservation goals.

We ask that you continue to dedicate environmental funding to enable communities to thrive now and long into the future. In your 2024-25 Executive Budget Proposal, we urge you to include:

Implement the $4.2 billion Clean Water, Clean Air and Green Jobs Environmental Bond Act

Our organizations were proud to support and work towards the overwhelming passage of the Environmental Bond Act in the 2022 General Election. This measure was needed to ensure environmental funding levels – when combined with other programs including those outlined below – are better able to address the significant needs that exist in communities throughout the state. We commend you for thoughtfully beginning the implementation of this measure, including the authorization of new staff at state agencies in the last budget, the statewide listening tour, and initial program design and solicitations for proposals for some of the first disbursements.

We look forward to seeing additional information from the interagency working group regarding feedback received through the listening tour, and on program designs with processes for funding applications that are both transparent and competitive. It is important that Bond Act programs are designed to ensure distribution of funding to communities throughout the state, including to partners such as local governments and non-governmental organizations. While state agencies may directly undertake Bond Act projects as well, implementation should ensure disbursements of funding reach communities and address needs identified on the ground. This will also increase the state’s capacity for implementation by leveraging partners to deliver projects.

As you prepare your Executive Budget Proposal and your administration continues the implementation of the Bond Act, we urge you to maintain other sources of environmental funding – including the Environmental Protection Fund (EPF), Clean Water Infrastructure Act, and capital funding for the Office of Parks Recreation and Historic Preservation and the Department of Environmental Conservation (DEC). The Bond Act is a necessary long-term investment for New York State to thrive; it is additive funding, not a substitute for existing programs.

While the State’s fiscal situation is strained, reducing environmental funding, which is a very small percentage of the state budget, will not bring budget relief and will in fact set communities back as we work to provide clean water, clean air, and access to natural resources.

In order to support passage of the Bond Act, we built a strong and diverse coalition. The coalition continues to welcome opportunities to partner with the State now to ensure the Bond Act is implemented effectively and transparently.

At Least $400 Million for the Environmental Protection Fund (EPF)

As part of your Executive Budget Proposal, we urge you to continue the EPF appropriation of at least $400 million and continue to work towards increasing the appropriation to $500 million sustained annually over the long term. We appreciate that your administration has provided historic funding to the EPF and has avoided problematic proposals such as offloading agency operating costs into the fund. We urge you to continue to support agencies as they find efficiencies for program administration in order to speed up annual disbursements from the EPF to enable valuable projects across the state.

The EPF has consistently enjoyed bi-partisan support in the Legislature and has funded beneficial projects in every county of the state, including every borough of New York City. The EPF is essential to the resiliency, sustainability and quality of life in New York. EPF programs protect clean water; support our zoos, aquaria, and botanical gardens; invest in environmental justice organizations; conserve land and water including local farms and forests; create new parks and trails that promote equitable access to nature; support climate adaptation and mitigation projects on farms, in forests and in urban areas; fund community recycling programs; and prevent pollution. EPF programs also support hundreds of thousands of jobs across the state, and EPF-supported industries generate approximately $40 billion in economic activity every year. Many EPF programs have yearslong waiting lists for funding and continuing to effectively move these programs forward will complement the work that can now be done through the recently enacted Environmental Bond Act and other environmental programs that protect clean water and create jobs.

$600 Million for the Clean Water Infrastructure Act as Part of a New Five-Year $4 Billion Commitment for Clean Water

We respectfully urge you to enable New York communities to leverage significant federal funding for water projects by providing at least $600 million in new appropriations for the Clean Water Infrastructure Act (CWIA) in your upcoming budget, as a first installment in a new $4 billion commitment to clean water funding over the next five years. We support the appropriation to direct funding to specific programs so it is clear what types of projects will be funded.

We urgently need to modernize New York’s aging and failing drinking water and wastewater infrastructure that can’t keep up the state’s current needs. We have seen the tragic consequences of our infrastructure failing, from massive flooding and property loss recently in the City of Troy to an entire population of residents going without water in Watertown. These infrastructure failures put public health and safety at risk and we must continue the critically important work of upgrading across the state. At least $75 billion is needed to address New York’s outdated water infrastructure systems. The State has made important investments in water infrastructure programs, including the Water Infrastructure Improvement Act, to upgrade infrastructure, protect clean drinking water, and prevent pollution from reaching our lakes, rivers, and streams.

Your administration’s continued work to award grants to projects has been effective, and we appreciate the hundreds of millions of dollars in funding that have been announced for water quality improvement projects throughout the State since you took office. Furthermore, we understand that a significant portion of this funding is reaching disadvantaged communities. We ask you to continue this important work and discuss with stakeholders opportunities to create further efficiencies and program flexibility to expand access to these funding programs even more.

Capital Funding for New York State Parks and Department of Environmental Conservation

This year marks the centennial of our world-class state parks system, an incredible asset to all New Yorkers. Throughout the COVID crisis, state residents relied on these parks to recreate, exercise, and find solace during extremely difficult times. We can expand these benefits by creating new parks and improving existing parks, including in disadvantaged communities throughout the state. While the crisis phase of the pandemic has ended, New Yorker’s rediscovery and increased engagement in outdoor recreation and our state parks has not. Visitation remains high, and this demand requires additional investment that will generate important returns for our state’s economy. Every dollar invested in state parks generates $5 of economic activity. Local construction jobs associated with park development have been an economic lifeline for many communities. We urge you to continue to invest at least $250 million in State Parks Capital funding and announce a new goal as part of the centennial celebration to sustain this level of investment annually for the next decade.

We also ask you to invest at least $100 million in capital funds for the DEC in your budget proposal. Annual capital appropriations to DEC enable critical projects, including the “Adventure New York” program, aimed at creating new recreational opportunities and infrastructure to support the record visitation our state lands are now experiencing. These projects protect natural resources, enhance visitor safety and enjoyment, and create new access to the outdoors in all regions of the state. In addition to Adventure New York, capital funding for DEC supports critical health and safety projects that protect the environment and the people of New York State.

With your strong leadership, we can advance policies and programs in New York State that will ensure a healthy, sustainable, and prosperous future for our children and grandchildren.

Sincerely,

Adirondack Council, Kevin Chlad, Director of Government Relations
Adirondack Lakes Alliance, Scott Ireland, Executive Director
Adirondack Land Trust, Mike Carr, Executive Director
Adirondack Mountain Club, Michael Barrett, Executive Director
Adirondack Wild: Friends of the Forest Preserve, David Gibson, Managing Partner
Agricultural Stewardship Association, Renee Bouplon, Executive Director
Allegany County, Office of Planning & Tourism, Michelle M. Denhoff, Deputy Director of Planning
Alley Pond Environmental Center, Inc., Irene V. Scheid, Executive Director
American Farmland Trust, Linda Garrett, NY Regional Director
ANT Alliance, Inc, Gail Serventi, Chair: ANT Alliance, Inc
Appalachian Mountain Club, Mark Zakutansky, Director of Conservation Policy Engagement
Ausable River Association, Kelley Tucker, Executive Director
Cary Institute of Ecosystem Studies, Joshua R Ginsberg, PhD, President
Catskill Center for Conservation and Development, Jeff Senterman, Executive Director
Catskill Mountainkeeper, Katherine Nadeau, Deputy Director
Champlain Area Trails, Chris Maron, Executive Director
Chautauqua County Partnership for Economic Growth, Jacob Bodway, Jacob Bodway
Chenango Bird Club, John Knapp, President
Citizens Campaign for the Environment, Adrienne Esposito, Executive Director
Clean+Healthy, Bobbi Wilding, Executive Director
Climate Reality Project - Westchester Chapter, Suzie Ross, Co-Founder and Co-Chair
Climate Reality Project Long Island Chapter, Francesca Rheannon, chapter co-chair
Climate Reality Project, NYC Chapter, Paul Kiesler, Co-Chair
Coalition of Living Museums, Aaron Bouska, Chair
Coalition to Save Hempstead Harbor, Michelle Lapinel McAllister, Programs Director
Cranberry Lake Mountaineers Snowmobile Club, Inc, Heather C. Wilson, President
Dutchess Land Conservancy, Inc., Rebecca E.C. Thornton, President
Earthjustice, Elizabeth Moran, New York Policy Advocate
Environmental Advocates NY, Rob Hayes, Director of Clean Water
Environmental Defense Fund, Kate Boicourt, Director, Climate Resilient Coasts and Watersheds, NY/NJ
Environmental Real Estate Solutions, Jim Daus, President
Ferryland Cottage Rentals, Jan Ferry-Axman,
Finger Lakes Land Trust, Andrew Zepp, Executive Director
Friends of Clark Reservation, Angela Weiler, Chair
Friends of Connetquot, Janet Marie Soley, President
Friends of Georgica Pond Foundation, Inc., Sara Davison, Executive Director
Friends of Higley Flow State Park, Edward Fuh, President
Friends of Letchworth State Park, Carol Rathbun, President and David Mapes, Board member
Friends of Midway State Park, Robert Wooler, President
Friends of Peebles Island State Park, Inc., David DeMarco, President
Friends of Pickman Remmer Wetlands, Richard Remmer, President
Friends of Rogers Environmental Education Center, David W. Carson, Executive Director
Friends of Sampson State Park, Francis Caraccilo, President
Friends of the Bay, Heather Johnson, Executive Director
Friends of the Chemung River Watershed, Elizabeth Zilinski, Executive Director
Friends of the Genesee Valley Greenway, Inc., Carl L Schoenthal, President
Friends of the Upper Delaware River, Jeff Skelding, Executive Director
Genesee Land Trust, Lorna Wright, Executive Director
Grassroots Gardens of Western New York, Timothy Chen, Executive Director
Green Ossining, Suzie Ross, Chairperson
Groundwork Hudson Valley, Oded Holzinger, Executive Director
Harlem Valley Rail Trail Association, Lisa DeLeeuw, Executive Director

Healthy Schools Network, Claire L Barnett, Executive Director
Hudson Highlands Land trust, Inc., Katrina Shindledecker, Executive Director
Hudson River Sloop Clearwater, Jen Benson, Environmental Action Director
Hyde Hall, Inc., Jonathan P. Maney, C.E.O. & Executive Director
IMPACT: Friends Improving Allegany County Trails, Inc., Glenn Gebhard, President
Lake George Battlefield Park Alliance, John DiNuzzo, President
Land Trust Alliance - NY Program, Jamie Brown, Program Manager
Marvin Stepherson, Genesee Regional Commissioner, New York State Council of Parks
Mohonk Preserve, Kevin Case, President/CEO
Moms for a Nontoxic New York (MNNY), Kathleen A Curtis, Founding Director
Montezuma Historical Society, Cheryl Longyear, Secretary
Mothers Out Front - Tompkins, Sheila Out, Organizing Member
Natural Resources Defense Council (NRDC), Rich Schrader, Policy and Legislative Director
New York League of Conservation Voters, Julie Tighe, President
New York Outdoor Recreation Coalition, Melissa Abramson, Co-Chair
New York-New Jersey Trail Conference, Joshua Howard, Executive Director
Northeast Organic Farming Association of New York (NOFA-NY), Katie Baildon, Policy Manager
Open Space Institute, Kathy Moser, Chief Conservation and Policy Officer
Orange County Land Trust, Jim Delaune, Executive Director
Parks & Trails New York, Paul Steely White, Executive Director
Paul Smith's College, Daniel Kelting, President
Paul Smith's College VIC, Scott van Laer, Director
Peconic Baykeeper, Peter Topping, Baykeeper & Executive Director
Peconic Land Trust, John v.H. Halsey, President
Planting Fields Foundation, Gina Wouters, President and CEO
Preservation League of New York State, Jay DiLorenzo, President
Rensselaer Plateau Alliance, Jim Bonesteel, Executive Director
Riverkeeper, Jeremy Cherson, Senior Manager of Government Affairs
Rivers & Mountains, Michael Richardson, Convener
Riverside Park Conservancy, Merritt Birnbaum, President & CEO
Save the Sound, David Ansel, Vice President of Water Protection
Scenic Hudson, Carli Fraccarolli, State Policy Manager
Schroon Lake Association, Scott Ireland, President
Seneca Lake Guardian, Yvonne Taylor, Vice President
Sierra Club Atlantic Chapter, Roger Downs, Conservation Director
South Shore Audubon Society, Russell Comeau, President
Sustainable Westchester, Jim Kuster, Interim Executive Director
The Conservation Fund, Thomas R. Duffus, Vice President & NE Representative
The Friends of Fillmore Glen State Park, Lorrie Tily, Board of Directors
The Nature Conservancy, Jessica Ottney Mahar, New York Policy & Strategy Director
Theodore Roosevelt Conservation Partnership, Christy Plumer, Chief Conservation Officer
Third Act Upstate NY, Scott Ireland, Co-Facilitator
Thousand Islands Land Trust, Jake R. Tibbles, Executive Director
Tompkins County Climate Protection Intiative, Peter Bardaglio, Coordinator
Trust for Public Land, Mary Alice Lee, Interim New York State Director
Upper Saranac Foundation, Tom Swayne, President
Village of Scottsville NY, Maggie Ridge, Mayor
Walt Whitman Birthplace Association, Cynthia Shor, Executive Director
WE ACT for Environmental Justice, Sonal Jessel, Director of Policy
Westchester Land Trust, Kara H. Whelan, President
Western New York Land Conservancy, Marisa Riggi, Executive Director
Wildlife Conservation Society, John F. Calvelli, Executive Vice President, Public Affairs
Woodstock Land Conservancy, Andy Mossey, Executive Director

cc:

(VIA EMAIL)

Karen Persichilli Keogh, Secretary to the Governor
Kathryn Garcia, Director of State Operations
Micah Lasher, Director of Policy
John O’Leary, Deputy Secretary for Energy and Environment
Ashley Dougherty, Assistant Secretary for Environment
Blake Washington, Director, Division of Budget
Basil Seggos, Commissioner, Department of Environmental Conservation
Erik Kulleseid, Commissioner, Office of Parks, Recreation, and Historic Preservation

This advocacy alert is reposted from The Advisory Council on Historic Preservation.

America is suffering from a massive shortage of available housing units, and the crisis is particularly acute regarding affordable housing. Reusing existing buildings is integral to addressing this critical problem, and - since about 40 percent of America’s buildings are at least 50 years old - rehabilitating historic housing and adapting historic buildings not originally built for housing is essential. The Advisory Council on Historic Preservation is developing a policy statement on housing and historic preservation to provide expert advice to a wide range of stakeholders on the role that historic preservation can play in alleviating the housing crisis.

A draft of the policy statement on housing and historic preservation is available for public comment. Comments must be submitted in writing by 5 p.m. on November 11, 2023, by emailing housing@achp.gov. Comments received will be considered as the draft policy statement is finalized. (All comments are subject to the Freedom of Information Act and/or may be made public.)

The draft policy statement provides advice to all levels of government, community groups, nonprofit organizations, developers, and others in the private sector regarding the importance of: gathering information relating to historic preservation and housing; reusing historic buildings; accelerating project permitting and environmental review; education; and collaboration.

The draft policy statement builds upon and incorporates key principles of the ACHP’s 2007 Affordable Housing and Historic Preservation Policy Statement, which focuses principally on review of affordable housing projects under Section 106 of the National Historic Preservation Act. Portions of the 2007 policy statement appear (with revisions) in Policy Principle #9 of the current draft.

Click here for a PDF of this support letter.

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City Planning Commission
120 Broadway, 31st Floor
New York, NY 10271

Landmarks Preservation Commission
1 Centre Street, 9th Floor North
New York, NY 10271

To the Commissioners of the Landmarks Preservation Commission and the City Planning Commission,

We write this letter to express serious concern regarding the management of proposed modifications to the 60 Wall Street privately owned public space (POPS) by both the Landmarks Preservation Commission (LPC) and the City Planning Commission (CPC). The below signatories stand together in support of the full consideration of the POPS as an interior landmark before any significant alterations are made.

The application (ULURP No. M850321FZSM) by the developer proposes modifications to the POPS that are more accurately described as a gut renovation than as any sort of modification, and would definitively remove the elements that have given this space its distinctive identity for nearly forty years and in our view justify its landmarking. Below we have summarized a list of objections to both the rationale for approval and the handling of this application that should be considered by all LPC and CPC commissioners ahead of the demolition of this public space:

1. Diminution of public resources: Contrary to the narrative of the applicant, the proposed modification reduces the space by 1,450 square feet compared to the original 1985 approval; reduce the number of water features from four to two; significantly limits the amount of landscaped floor area and foliage, to be replaced by an inaccessible “green wall” counted by the applicant toward landscaping area; and replaces five retail frontages with only one.

2. Poor maintenance and neglect of space: Many of the issues with the space that the applicant, who is the property owner, offers as reasons for significant alteration have been caused by the property owner’s own thorough neglect of the space, which has led to a dysfunctional bathroom, chronically vacant retail with no effort to find tenants, empty water fountains, broken lights, and dead trees.

3. Lack of public notice or participation: The application was only posted online days before its hearing by CPC, with no opportunity for testimony, no public notice, and no notification to Manhattan Community Board 1 or the office of Council Member Christopher Marte, both of whom have previously demonstrated significant interest in the future of this unique POPS.

4. Dodging of charter mandated responsibility by LPC: In an official letter to Council Member Marte, LPC cited “support of larger citywide priorities including economic revitalization” as a major reason for acting to not consider the POPS even though the Commission had recognized that the space merits consideration in a previous letter. It is explicitly the duty of LPC to preserve architecturally significant resources throughout the city regardless of economic development strategies of property owners or of the administration, which should in no way prevent the landmarking of a qualifying site such as this one.

5. Misleading and sparse information provided to LPC and CPC commissioners: LPC commissioners were not given the opportunity to consider the widely supported demand for landmarking of this POPS, even though several commissioners have voiced interest in its designation, including Vice Chair Bland and Commissioners Chapin, Chen, and Holford-Smith. CPC commissioners were never briefed on the campaign to protect the space, and when commissioners asked if the space could still be landmarked after the approval of the proposed modifications, they were misleadingly assured that the modifications would not conflict with the space’s landmarking merits or architectural significance. As we have stated above, the opposite is true: the “modifications” would remove the very elements that have given the space its architectural importance.

As the largest privately owned public covered pedestrian space in the city, the 60 Wall Street POPS is both an invaluable public resource and a cornerstone of postmodern architecture, an era that has seen increasing recognition through the landmarking of both the AT&T Building and UN Plaza Hotel, both of which have indicated the LPC’s recognition of the significance of post-modern architecture to New York’s architectural history. To both diminish the public value of the space and to actively ignore an opportunity to preserve a beloved architectural site undermines the mandates of both LPC and CPC, presenting a dangerous precedent for other sites that may be at risk , and results in a loss to all New Yorkers.

Improvements can be made to the space to encourage economic activity that would not diminish its architectural significance or trigger extensive renovation: for example, retail spaces can be leased, trees can be cared for, lighting and seating can be changed and enhanced, and programming can be incorporated to bring more activity to the POPS. Negligence by the property owner should not justify the demolition of a space that is by law a public resource.

We, as a coalition, demand that the 60 Wall Street POPS be fully considered as an interior landmark before any alteration permits are issued by the City. Upon designation, we believe LPC and CPC can work with the property owner to find methods of revitalizing the space that reflect and respect its prominence as a unique public respite in the Financial District.

Councilmember Marte
Community Board 1
Docomomo US
Historic Districts Council
Municipal Art Society

New York Landmarks Conservancy
Preservation League of New York State
Preservation Committee of the City Club
Robert A.M. Stern
Paul Goldberger

Click here for a PDF of this letter.

October 5, 2023

Administrator Ralph V. Suozzi and Members of the Garden City Board of Trustees
Village of Garden City
351 Stewart Avenue
Garden City, NY 11530

Dear Village Administrator Suozzi and Members of the Garden City Board of Trustees:

The Preservation League of New York State is writing to voice our support for the preservation and adaptive reuse of St. Paul’s School.

The Preservation League of New York State empowers all New Yorkers to use historic preservation to enrich their communities, protect their heritage, and build a sustainable future. We believe saving St. Paul’s would be of great value to residents of Garden City. We also believe the value of this local landmark extends beyond the Village borders – it is a building of significant statewide importance. The League included St. Paul’s on our 2003 Seven to Save list of endangered historic sites. In the 20 years since that listing, the building has continued to languish. However, with roof stabilization work completed in 2021 and the recent Comparative Analysis prepared by Westerman Construction, it seems like there is a path forward for St. Paul’s.

St. Paul’s is a High Victorian Gothic-style masterpiece, designed by noted architect Henry G. Harrison. Despite years of vacancy, the building is in remarkably good shape and retains much of its original character, including terra cotta details, stained glass windows, Minton tiles, and wood craftsmanship throughout. Its prominence in the Village cannot be overstated. To tear down such an architectural gem would be a major loss.

A rehabilitated St. Paul’s would serve as a statewide model for reuse and economic development. There are myriad possible uses that could reinvigorate the building and provide space for much-needed public services. And with more building space needed to provide Village residents with things like Universal Pre-K, we strongly urge the Village to repurpose the building you already have. The costs associated with new construction are likely to outweigh those associated with adaptive reuse – especially when issues of sustainability are factored in. Even after 20 years, a new construction is unlikely to have overcome its initial carbon output. Data suggests that it would take anywhere from 10-80 years for a new construction to overcome the negative climate change impacts from its construction (sourced from Architecture 2030’s CARE Tool). Environmental remediation will be necessary whether the building is rehabilitated or demolished. And the material waste associated with demolition adds to the landfill while detracting from the Village’s cultural heritage.

We are hopeful that renewed public interest in preserving St. Paul’s will allow for fruitful conversations about how best to put the building back to active use. We strongly encourage the preservation of this incredible public space.

Sincerely,

Jay DiLorenzo
President, Preservation League of NYS