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Landmarks
CB5 Comment on LPC Rules Changes
May 12, 2023
Sarah Carroll
Chair
Landmarks Preservation Commission
One Centre Street, 9th Floor North
New York, NY 10007
Members of Landmarks Preservation Commission
One Centre Street, 9th Floor North
New York, NY 10007
Dear Chair Carroll, and Members of the Landmarks Preservation Commission:
We are writing to express our concern and strong objection to the recent rules’ changes proposed by the Landmarks Preservation Commission. The Landmarks Committee of Manhattan Community Board Five is deeply concerned about the impact that these changes will have on the public’s ability to participate in the preservation process.
First and foremost, the new rules if adopted as introduced, would deprive the public of an opportunity to be informed and to comment on certain projects. The Commission’s proposed changes would significantly reduce the amount of notice given to the public and eliminate the opportunity to comment. This is particularly troubling because public input is crucial to ensuring that preservation decisions reflect the needs and interests of communities. Transparency is also a tenet of good governance. Giving more awareness is key to good government.
We are particularly concerned that Community Boards would be deprived of an opportunity to be informed, let alone comment on applications.
Secondly, the proposed rules may be too lenient or too loosely defined. Under the new guidelines, there will be a relaxed standard for historic buildings that may result in unseemly alterations. The Commission’s responsibility is to protect our city’s historic architecture, and these new guidelines could set a dangerous precedent for the future of our built environment. For example, allowing the staff to review and approve banners may result in an undesirable proliferation of banners on buildings, especially in historic districts. Canopies are mostly non-contextual in our historic districts. Allowing their approval at staff level would result in a proliferation of these structures that tend to be large, obtrusive of the primary facades and often of poor design.
Lastly, the proposed rules will subject the commission’s staff to too much pressure in making their determinations. As the staff has no discretion, any project that has been deemed acceptable for review at staff level would eventually be approved. It is essential that projects that alter buildings and their physical envelope and relationship to streetscape be reviewed by the commission. For example, solar panels are a new technology. They should be reviewed by the Commissioners until a clear set of rules can be put in place. Solar panels are a new technology that is bound to evolve and may impact buildings permanently. Before we task the LPC staff with their approval, we need robust public input.
In conclusion, CB5 urges the Landmarks Preservation Commission to reconsider these proposed changes. We ask that all applications continue to be referred to community boards and give community boards the power to refer applications to the commission. We also urge LPC to reconsider rules changes on banners, flagpoles, illuminated signage, canopies, awnings, marquis, minimally visible rooftop additions (including mechanical elements), gray vinyl, and murals.
The public deserves the opportunity to be informed and to participate in the preservation process, and the commission’s responsibility to protect our city’s historic architecture must be upheld.
Sincerely,
Vikki Barbero Layla Law-Gisiko
Chair Chair, Landmarks Committee
Cc: Council Member Erik Bottcher
Council Member Carlina Rivera
Council Member Keith Powers
Manhattan Borough President Mark Levine