December 9, 2024

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 (Click here for a PDF of this letter)

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 important enhancements to the New York State Historic Preservation Tax Credit (NYS HTC) program that will advance the development of affordable housing and community development projects in New York State, while saving the state money. We urge you to include these enhancements to the Historic Preservation Tax Credit in your FY 2025-26 Executive Budget proposal.

The 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 NYS HTC has been responsible for the creation of 29,173 housing units, 15,400 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, or “bifurcating” the credit, would open up and broaden the investor market. The additional step of “certificating” the credit, would further serve to increase the value of the credit, thus injecting more equity into these projects.

Current law also requires projects to be “in whole or in part located within a census tract which is identified as being at or below one hundred percent of the state median family income.” This limitation restricts the ability to access NYS HTCs for many low-income buildings in nearby census tracts that are above the one hundred percent threshold. Accordingly, we support authorizing NYS HTCs to be used for any qualified historic rehabilitation projects, regardless of census tract, provided such projects satisfy the criteria for affordable housing. This simple change would create greater flexibility in the use of NYS HTCs and expand the number of projects that can be rehabilitated for affordable housing.

Enhancing the NYS HTC in this modest yet impactful way would have some big benefits.

1. More affordable housing. A more flexible program would increase the attractiveness of tax credits amongst new investors who would provide greater private investment dollars in New York State projects.

2. Less cost to New York State. With greater private investment, New York State will be relieved of the need to add additional public funds to get these projects done.

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.

Notably, the Assembly and the Senate introduced legislation during the 2024 session (A.9722/S.9071) that would have made the bifurcation and certification improvements discussed above. While the legislation unanimously passed the Senate, it unfortunately did not pass in the Assembly prior to the end of session.

Let’s make these meaningful enhancements to the NYS HTC now and build a better New York one building at a time.

Sincerely,

Adirondack Architectural Heritage, Erin Tobin Executive Director
C.B. Emmanuel Realty, Ben Upshaw Managing Partner
Carmina Wood Design, Steven J. Carmina, AIA President/CEO
Carmina Wood Design, Paul R. Lang, AIA Managing Principal
Common Bond Real Estate LLC, Jason A. Yots, President
Historic Albany Foundation, Pamela Howard, Executive Director
Historic Districts Council, Frampton Tolbert, Executive Director
Historic Ithaca, Christine O’Malley, Preservation Services Director
Home Leasing, Bret Garwood, CEO
Johnson-Schmidt Architect, P.C., Elise Johnson-Schmidt, AIA
Landmark Society of Western New York, Wayne Goodman, Executive Director
Monroe Building LLC, Derek King, Manager
New York Landmarks Conservancy, Peg Breen, President
New York State Association for Affordable Housing, Jolie Milstein, President and CEO
Otsego 2000, Ellen Pope, Executive Director
Preservation Association of Central New York, Andrew Roblee, President
Preservation Association of Central New York, Nicole 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
Preservation Studios LLC, Mike Puma, Director of Technical Services
RUPCO, Kevin O'Connor, CEO
Ryan, Albert Rex, Principal, Tax Credits
Saratoga Springs Preservation Foundation, Samantha Bosshart, 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

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

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

The undersigned organizations write in support of A.1808 (Zinerman) / S.224 (Myrie), which proposes to improve access to the NYS Historic Homeowner Rehabilitation Tax Credit for longterm homeowners in historic neighborhoods in New York City. Currently, the credit is only available in Qualified Census Tracts (QCTs), which are tracts at or below 100% of the state median family income in the most recent federal census. As numerous neighborhoods in New York City experience economic changes, some former QCTs no longer qualify due to rising income levels. This bill would allow homeowners in NYC who have owned their houses since at least January 1, 2010, and live in a census tract that was a QCT as of January 1, 2017, to use the Historic Homeowner Rehabilitation Tax Credit to offset part of the cost of rehabilitating their houses, even if the tract now exceeds the income limit for QCTs.

When neighborhoods experience rapid increases in income levels and housing costs, long-time homeowners who have contributed to the stability and appeal of their neighborhoods are often at risk of being displaced. Expanding Historic Homeowner Rehabilitation Tax Credit eligibility to longterm owners in gentrifying areas will make the program more equitable and help these owners defray the cost of maintaining and improving their homes.

The Historic Homeowner Rehabilitation Tax Credit is an important tool for owners of historic houses listed in the State and/or National Registers of Historic Places. When they undertake a rehabilitation project costing at least $5,000, they can qualify to claim a tax credit equal to 20% of the project cost. Rehabilitation work can include both interior and exterior projects, when at least 5% of the work is on the exterior of the building. Typical projects include roof, window, and facade repairs, and energy upgrades such as storm window installation and weatherstripping. The tax credits help to defray the cost of caring for these buildings, which require regular maintenance and repair.

Our organizations support this bill, as well as its broader goal of supporting owners who have invested many years in their neighborhoods and wish to continue maintaining their homes. We thank Senator Myrie and Assemblymember Zinerman for their leadership, and urge the Assembly to pass A.1808 in the remaining days of the 2023 legislative session.

Click here for a PDF of this support memo.

This week, the extended state budget process is coming to an end, following several extra weeks of negotiations between the Governor and Legislature. Several budget bills have already been passed by the Senate and Assembly, and more are expected imminently, as is the Governor’s signature.

The League is thrilled that a five-year extension of the NYS Historic Commercial and Homeowner Tax Credit Programs is included in the budget agreement. The tax-credit programs were due to expire in 2024, so an extension was necessary to ensure these programs did not sunset. We thank Assemblymember Carrie Woerner and Senator Timothy Kennedy for championing this extension, and thank the Governor, Senate, and Assembly for all including the extension in their budget proposals and ensuring its inclusion in the final agreement.

The “White Elephant Program,” also proposed by Assemblymember Carrie Woerner and Senator Ted Kennedy, did not make it into the final budget. This program aims to facilitate the rehabilitation of large, vacant buildings that often languish due to their high rehab costs and scarcity of investors. We understand our legislative sponsors intend to work toward passage of the white elephant program as a standalone bill in the remainder of this session, and we will continue advocacy efforts toward that goal.

We are pleased that the budget bills now in the process of being passed by the Legislature and signed by the Governor include provisions to protect remains in unmarked burial sites that are discovered on private property. The League has advocated for the establishment of such a process for the last several years, inspired in part by our Seven to Save listing of Elmhurst African American Burial Ground in Queens in 2020.

A similar bill that passed the Legislature last year was vetoed by the Governor, citing what she saw as inadequate protections for private property owners. The bill establishes a process and timeline for the remains to be protected, the appropriate descendants or culturally affiliated groups notified, and a resolution to be worked out between the descendants and the property owner as to keeping the remains in place or moving them to a different location. New in this bill is that if the culturally affiliated group and property owner cannot come to an agreement – if the descendants want the remains to stay in place and the property owner wants to remove them, for example – the property owner can, after 90 days, pay to have them removed in a respectful manner, with the culturally affiliated group having the right to monitor the removal. We are grateful for the efforts of former Assemblymember Steve Englebright, who had championed this issue for many years, and Assemblymember Fred Thiele, who sponsored the revised bill that was incorporated into the budget. We also acknowledge the efforts of Indigenous activists who have worked tirelessly in support of this long overdue legislation.

The New York State Council on the Arts (NYSCA), an important partner to the League, has announced that their FY 2024 budget allocation is $110 million; their available funding for FY24 grants is $127 million ($90 million for organizations and artists, plus $37 million in capital project funding). NYSCA’s funding has seen significant bumps the last few years in recognition of the need to invest in the recovery of the arts sector; while this year’s funding is not as high as last year’s historic peak of $140 million, it does recognize the state’s ongoing commitment to the arts, and improves significantly on the original executive budget proposal. We join NYSCA in thanking the Governor and Legislature for their leadership in investing in New York’s important arts sector.

The budget also includes $400 million for the Environmental Protection Fund (EPF), plus $200 million in capital funding the Office of Parks, Recreation and Historic Preservation to invest in enhancing state parks. We will share details of funding for historic preservation as those become available.

Click here for a PDF of this support letter.

April 3, 2023

Supervisor Peter Van Scoyoc and Members of the Town Board
Town of East Hampton
159 Pantigo Road
East Hampton, New York 11937

Dear Supervisor Van Scoyoc and Members of the East Hampton Town Board,

The National Trust for Historic Preservation and the Preservation League of New York State were pleased to learn that Michael Devonshire of Jan Hird Pokorny Associates presented a Building Conditions Report of the James Brooks and Charlotte Park Studios and Residence to the East Hampton Town Board on March 21, 2023.

We understand that the Town Council was supportive of the Building Conditions Report, expressing a desire to stabilize and restore the property. Our organizations, along with local, statewide, and national advocates, are requesting clarity on next steps and a timeline to preserve this collection of historically significant structures where Charlotte Park and James Brooks, two very important Abstract Expressionist artists, lived and worked.

The report notes that “the rich cultural importance of the Brooks Park association with the site renders it deserving [of] a restorative approach, emphasizing a period of interpretation of the 1970s-1990s be taken, in order to retain as much as possible of the artifactual remains of the buildings in which these two immensely gifted artists performed their acts of creation.” We could not agree more and urge the Town to take meaningful steps to ensure the long-term preservation and re-use of this property.

We continue to have serious concern for the buildings’ condition if they remain poorly maintained, and urge, in the strongest possible terms, the Town of East Hampton to take swift and significant steps to stabilize and protect the Brooks-Park Studios and Residence, while determining a restoration plan. The Town has the authority as well as the funding necessary to stabilize the buildings, through the Peconic Bay Region Community Preservation Fund.

We thank you for your ongoing attention to the future of the Brooks Park Home and Studios and we look forward to hearing from you.

Sincerely,

Seri Worden
Senior Field Director, National Trust for Historic Preservation

Katie Eggers Comeau
VP for Policy and Preservation, Preservation League of NYS