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

September 25, 2023

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

Dear Governor Hochul:

The undersigned organizations all agree with you: New York needs a world-class Penn Station. The Station is vital to the City and region’s economy. Its users, and all New Yorkers, need to know that they are getting the station that the City, State, and region deserves.

Penn should welcome residents, commuters, and visitors with an excellent experience and abundant transit capacity. This is clearly the moment when that goal can be achieved. But there is conflicting information, and confusion, about what is happening and what could happen at Penn. With so much public money involved, we believe the public deserves full transparency and explanation on several issues.

Penn Station Design: Will there be a public bidding process for the design? Will the State comment on the other designs that have been made public? The MTA has announced its own plan. How would that coordinate with a new design? With the future of Madison Square Garden’s location in question, how will any plan accommodate for its potential move?     

Transit Improvements: Many experts support through-running to expand capacity, but prior documents from the railroads have dismissed it as not feasible. Yet, another analysis of through running is being conducted now by the railroads. The public deserves a full explanation of why it is or isn’t suitable, with all studies released in full to the public, including detailed information about their methodologies. 

General Project Plan: While we acknowledge the recent decision by State Supreme Court Judge Billings dismissing challenges to the GPP, there is still confusion. You publicly “decoupled” the GPP from Penn improvements. Yet Judge Billings’decision noted that Empire State Development said the State is in talks with Vornado about certain sites. To what benefit, if there is no longer a connection to Penn? Why does the State still keep the GPP when other plans for Penn do not?

 Why has the GPP not been withdrawn?

The loss of historic Penn Station left a scar that generations have tried to heal. If this is the moment when this loss is rectified, New Yorkers must be a part of that discussion. We look forward to a robust public dialogue that leads to the Station which New York needs and deserves.

Respectfully,

Art Deco Society
City Club
CNU NYC
Community Board 5
Council of Chelsea Block Associations
Environmental Simulation Center
Historic Districts Council
Human Scale NYC
Limited Equity and Affordability at Penn South (LEAPS)
MidTown South Community Council
Murray Hill Neighborhood Association
New York Landmarks Conservancy
Penn Area Residents Committee
Preservation League of New York State
ReThinkNYC
Save Chelsea
Take Back NYC
29th Street Block Association
Union Square Community Coalition
Untapped New York
Victorian Society

The League was pleased to co-sign this letter written by our colleagues at Village Preservation in support of Our Lady of Guadalupe Church. To learn more about their advocacy around this historic site, please visit their website.

September 8, 2023

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

Re: Our Lady of Guadalupe Church, 229-231 West 14th Street, Manhattan

Dear Chair Carroll,

We write in reply to the letter Village Preservation received from the Landmarks Preservation Commission (LPC) on August 3, 2023, in response to the Request for Evaluation of Our Lady of Guadalupe Church (229-231 West 14th Street).

The undersigned elected officials, scholars of Hispanic history and culture, and representatives of Manhattan Community Board 4, preservation organizations, and neighborhood groups, are collectively disappointed by the response from the LPC regarding the request to evaluate the merits of the presently-endangered church as a potential individual landmark. In the aforementioned response letter, LPC failed to recognize the significance of the church and the congregation it served for a century.

In 1902, Our Lady of Guadalupe Church was founded at 229-231 West 14th Street, two ca. 1850 singlefamily brownstone-clad houses that were built as stately homes at a time when 14th Street was one of the most prestigious addresses in New York. By the late 1800s, the street had lost much of its prestige in favor of locations further uptown, yet these grand buildings remained, under the ownership of the Delmonico family. They were then combined to serve a need: the creation of a permanent church for a thriving population. The site has been at the center of Spanish and Latin American heritage for decades, and bears enormous significance as New York City’s very first Spanish language church or church for a Spanish-speaking congregation.

While the church and its congregation were small at the time of their origin at the turn of the century, this by no means diminishes their significance. Our Lady of Guadalupe Church was a cornerstone of a growing community, which had started out years prior as a modest group of Spanish Catholics who settled in the area surrounding West 14th Street. The community, at the time primarily comprising immigrants from Galicia, would come to be known as “Little Spain.”

LPC’s response too easily dismisses the magnitude, size, and lasting heritage of the Little Spain and Latin American community historically associated with this church, by merely stating that “a small Spanish (Iberian) community was established in the West Village south of West 14th Street in the late-19th century and was in decline by the 1920s and 1930s as the community moved uptown.” On the contrary, at its height, the enclave known as “Little Spain” extended from approximately Christopher Street to 23rd Street on the west side, with 14th Street between 7th and 8th Avenues as its core, and was home to thousands of immigrants and dozens of Spanish-owned businesses, social clubs, and religious and community centers. At its peak, Little Spain was the largest Spanish-American community in New York City. It also served as a nexus for Puerto Ricans and Latin American immigrants when other such centers did not exist, and even after they did.

Among the remaining vestiges in the neighborhood today are the Spanish Benevolent Society (La Nacional), founded in 1868 and with its Spanish flag still flying, and the physical body of the church, which was remodeled in 1921 with the present Spanish Colonial Baroque facade addition by architect Gustave E. Steinback. This noteworthy phase of immigrant history deserves to be recognized, and Our Lady of Guadalupe Church is one of its few surviving architectural remnants.

In the letter, LPC noted that “...soon after it was established Our Lady of Guadalupe’s space was considered temporary and insufficient, and inconvenient to an increasingly dispersed Spanish-speaking population that tended to worship in churches closer to their homes, attending Our Lady of Guadalupe primarily for baptisms and weddings.” This is simply untrue. The church actually expanded in 1917 to include the second row house on 14th Street, and in 1921 the grand Spanish Colonial Baroque facade was added to both structures as we see today. Though the solely Spanish population began to diminish in the 1930s, by then other Spanish-speaking communities had come to call this neighborhood home.

Our Lady of Guadalupe Church continued to serve Spanish-speaking parishioners until as recently as the early 2000s, when the significant influx of Mexican immigrants to New York City, which had occurred starting in the 1990s, began to overextend the capacity of the small chapel that the combining of the two brownstones had facilitated. In 2002, the parish relocated just a few hundred feet west to St. Bernard’s Church, located on 14th Street between 8th and 9th Avenues. Prior to the move, neighbors and eyewitnesses recall the overflow of crowds that used to participate in services at the original location. Demand was so high that Mass was sometimes broadcast over loudspeakers to reach a broader audience spilling onto the sidewalk.

LPC further indicated that “the [church] building has since been altered with the removal of historic window and door details, facade resurfacing, and changes to window openings, roofs, and parapets.” Indeed it has, but such minor alterations are typically not considered barriers to designation. Many features of the two original upscale brownstone row houses remain, as does the 1921 facade designed by a famed architect, which reflects the development of the building into its longstanding use as a religious institution.

The first religious home that a community creates is often not the grandest. Like so many other congregations that used methods of adaptive reuse in order to create houses of worship, Our Lady of Guadalupe Church was not purpose-built, but rather crafted by altering existing infrastructure, and the present building tells that story. Places of worship are often among the first dedicated, shared spaces established in a neighborhood, and the physical form is borne of necessity. That is exactly what is memorialized here: a church building that evolved in tandem with a developing community, which was then made more “grand” with its Spanish Colonial Baroque facade when resources permitted.

Historically, many synagogues on the Lower East Side followed a similar model, as have more recently mosques and Hindu and Buddhist temples; likewise, churches of less well-established groups in earlier days typically took over existing houses of worship or created ones out of structures already built for different purposes. These were communities that either a) did not have sufficient resources at the time and needed to work with what was available to them, and/or b) were transient insomuch as they were made up of immigrants or refugees whose permanence was not guaranteed. They would therefore create spaces of safe worship within existing infrastructure. As these communities established more of a permanent presence in their neighborhoods, they took the time, energy, and monetary investment to add grandeur and ornamentation to their sacred spaces.

Finally, LPC asserted that “while [Our Lady of Guadalupe Church] has served a Spanish-speaking community through its history, it has also served other communities, as so many churches across the city do, with services in various languages,” and that “as a result, it does not appear to possess a strong enough association with a specific community to merit consideration for its cultural significance alone.” As an inclusive and welcoming place of worship in one of the most diverse cities in the world, Our Lady of Guadalupe Church certainly may have opened its doors to broader populations throughout its lifetime. However, that does not minimize the continuous value that it had for the core Spanish-speaking community it consistently served for 100 years. The parish never wavered from its original purpose, which was to provide a religious home for its Spanish-speaking congregation — for over a decade, the only place that offered such services in the entire city.

While constituting approximately 30% of NYC’s population, sites designated for their connection to Latino/a, Latinx, and Hispanic peoples and their history and culture account for at most a handful of the 1,456 individual landmarks citywide, or well under 1% of designated individual landmarks. And a comparatively negligible number of the nearly 40,000 interior landmark, scenic landmark, and historic district designations throughout the five boroughs cite such connections as their reason for designation. It would appear the LPC does not have the luxury of dismissing Our Lady of Guadalupe Church as lacking in requisite significance to Latino/a, Latinx, and Hispanic history and heritage when there is such a deficit of other sites that have been recognized, and when so many experts in the field strongly disagree. Our Lady of Guadalupe Church tells the specific story of “Little Spain” and its Spanish and Latin American immigration history, a critical piece of our heritage that may soon be lost to time if the Landmarks Preservation Commission does not act.

Thank you for your reconsideration of this request.

Sincerely,

Andrew Berman
Executive Director, Village Preservation

Deborah J. Glick
NYS Assemblymember 66th Assembly District

Eric Bottcher
NYC Council Member District 3

Jessica Chait
First Vice Chair, Manhattan Community Board 4

Jay DiLorenzo
President, Preservation League of New York State

Frampton Tolbert
Executive Director, Historic Districts Council

Robert Sanfiz
Executive Director La Nacional - Spanish Benevolent Society

Anthony M. Stevens-Arroyo, Ph.D.
Professor Emeritus of Puerto Rican and Latino Studies, Brooklyn College, CUNY

Elena Martinez
Folklorist, City Lore

Brad Hoylman-Sigal
NYS Senator 27th Senate District

Tony Simone
NYS Assemblymember 75th Assembly District

Jeffrey LeFrancois
Chair, Manhattan Community Board 4

Kerry Keenan
Co-Chair, Chelsea Land Use Committee, Manhattan Community Board 4

Peg Breen
President, The New York Landmarks Conservancy

Kitt Garrett
President, Save Chelsea

Mark Wallem
Executive Director, Abraham Lincoln Brigade Archives (ALBA)

Ana María Díaz-Stevens, Ph.D.
Chair of Church and Society and Professor Emerita, Union Theological Seminary, New York City

Orlando José Hernández
Independent writer and Professor Emeritus, Hostos Community College-CUNY

Click here for a PDF of this letter.

September 7, 2023

Supervisor Peter Van Scoyoc and Members of the Town Council
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 Preservation League of New York State and the National Trust for Historic Preservation are writing to voice our support for the local advocates behind the Brooks-Park Arts and Nature Center (BPANC) and their management plan for the Brooks-Park Home and Studios in Springs.

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. The National Trust for Historic Preservation works to save America's historic sites; tell the full American story; build stronger communities; and invest in preservation's future. Both of our organizations have identified the James Brooks and Charlotte Park Home and Studios as an incredibly important site worth saving. The Trust listed the Brooks-Park site as one of their 11 Most Endangered Historic Places in 2022, with the League including the site among its Seven to Save shortly after. Since those listings, we have worked closely with the BPANC volunteers and have been continuously impressed by their dedication to creating a vital community asset at the Brooks-Park site.

With the Building Conditions Report from Michael Devonshire of Jan Hird Pokorny Associates recently completed in March of this year, the Town is poised to stabilize, and eventually restore, these buildings. BPANC is ready to work with the Town to find a future for Brooks-Park. Both James Brooks and Charlotte Park were seminal figures in the 20th Century Abstract Expressionist art movement. Their home and studios are a physical testament to their work and this important moment in American history. But the Brooks-Park site is also a place to experience nature, just as James and Charlotte did as they made art there. BPANC seeks to create inclusive educational programming and arts-related activities alongside “the discovery, research, and experience of its eleven undisturbed acres of natural habitat, bringing focus to these two acclaimed artists, the unique community in which they lived and worked, and the trail system that runs through parts of the property.”

We strongly encourage the approval of their management plan and a path forward for the Brooks-Park site.

Sincerely,

Jay DiLorenzo                                                           
President, Preservation League of NYS                    

Seri Worden
Senior Director of Preservation Programs, National Trust for Historic Preservation

This Advocacy Update has been reposted from our colleagues at Preservation Action.

Last month, Rep. Mike Kelly (R-PA) and Rep. Brian Higgins (D-NY) introduced the Neighborhood Homes Investment Act (H.R. 3940, S. 657) in the House. Companion legislation was introduced in the Senate earlier this year. This bill would create a federal tax credit to encourage revitalization of distressed homes. In many parts of the country, the cost of purchasing and renovating a home is greater than the value of the home's sale price. The bill would create a tax credit to cover the cost between building or rehabilitating a home in these areas and the price at which they can be sold, up to 35% of the total development cost. Similar legislation was introduced during the last Congress and garnered significant bipartisan support.

The bill focuses on communities with the greatest need, by targeting distressed areas. This includes neighborhoods with high poverty rates, incomes below the area median income; and home values that are below the metro or state median value. The Neighborhood Homes Coalition put together an interactive map where you can see what neighborhoods could qualify for funding. The Coalition estimates that the bill could lead to 500,000 homes over 10 years being rehabilitated or constructed.

This legislation has the potential to significantly assist owners of historic and older homes. Preservation Action will continue to monitor this important legislation.

June 6, 2023

Hon. Eric Adams, Mayor
New York City Hall, New York, NY 10007

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

Dear Mayor Adams and Chair Carroll:

On behalf of the Preservation League of New York State, I write to support Village Preservation’s request for an evaluation of 78-80 St. Mark’s Place, most recently home of Theatre 80.

As is well documented in Village Preservation’s Request for Evaluation, the building is linked to the early development of New York City, having been built in the 1840s when St. Mark’s Place was lined by spacious townhouses for prosperous New Yorkers. Later nineteenth- and early twentieth-century residents were associated with the waves of immigration that characterized the East Village in that period.

The building later housed a performance venue with roots in the Prohibition era. In 1959, the Jazz Gallery was opened in the building; in 1964 this was transformed into Theatre 80. As a jazz club and later Off-Off-Broadway theatre, it was associated with notable jazz musicians and actors who performed there, and notably with the premiere of You’re a Good Man, Charlie Brown. More recently, the space has served as a revival movie house, then again as a venue for live theater.

I encourage the Landmarks Preservation Commission to carefully consider the notable history and cultural significance of the building at 78-80 St. Mark’s Place. The architecture of this building reflects not architectural purity, but rather the singular quirks of its own history and the multiple, overlapping aspects of its significance; but it is primarily the contributions of this building and its occupants to the culture of the East Village that warrant its consideration for landmark status.

Sincerely,

Katie Eggers Comeau
Vice President for Policy and Preservation

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.