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After public testimony, LPC presents revisions to proposed rule changes

June 27, 2018

The NYC Landmarks Preservation Commission held a public hearing on March 27 to gather public comments on the wide-ranging changes it is proposing to the rules governing the regulatory process for approving work on designated properties. The hearing drew an overflow crowd of individuals, professional organizations, preservation and environmental advocacy groups, and community board representatives. DOCOMOMO NY/Tri-State president John Arbuckle provided testimony on behalf of the chapter in an effort to highlight the potential negative impact of the proposed rules changes to buildings and sites from the Modern movement.

In particular, the draft rules use of “contributing,” “non-contributing,” and “no style” language for structures of the Modern period in historic district designation reports puts Modern-era buildings at a disadvantage in terms of regulation compared with those of the documented and prevalent style in the district. In some cases, Modern buildings were categorized as “non-contributing” simply because they were new and not “historic” at the time a district designation report was prepared. Research undertaken by Historic Districts Council prior to the hearing identified 717 buildings within existing historic districts that are listed as “no-style” or “non-contributing” and would no longer be subject to the public input and transparency of the current approvals process when changes are proposed.  
 
A number of speakers addressed concerns about the “no style” and “non-contributing” terminology used in the draft and how the proposed changes would give less consideration to buildings in styles outside a district’s predominant style. However, the most common concern of those opposed was that the proposed rules will reduce the opportunity for public input and transparency on alterations such as rooftop additions, window and door replacements, and replacement with non-historic materials. 

Representatives from several community boards spoke in opposition to the proposed rules because the changes would result in fewer landmark CofA projects coming before the local boards for review and comment. In addition to the AIANY and REBNY, some property owners, including the Catholic Archdiocese, some business improvement districts and a handful of preservation architects supported the rules changes.

The large number of attendees meant that not everyone had time to testify during the official public hearing. At the request of Borough President Gale Brewer the comment period on the rules changes was extended to May 8, 2018. No timeframe has been given for the Commission’s next steps. The April 19 announcement of commission chair Meenakshi Srinivasan’s resignation effective June 1 could potentially affect the rules change process going forward.

We urge those concerned about Modern buildings in the city to read DOCOMOMO’s testimony and those of other preservation organizations and submit comments to the public record. Background on the proposed rules changes and instructions for commenting by mail, email or online can be found here.

UPDATE: At its regularly scheduled meeting on May 29, LPC presented modifications based on the public’s feedback, both from the hearing and a public comment period that was extended through May 8. Most of the revisions appear to scale back or remove completely some of the originally proposed changes. One of DOCOMOMO’s main contentions, presented by Board President John Arbuckle, was the use of “contributing,” “non-contributing,” and “no style” language for structures of the Modern period in historic district designation reports, which put Modern-era buildings at a disadvantage in terms of regulation compared with those of the documented and prevalent style in the district. According to the May 29 presentation, the revised rules would remove references to the categories of “non-contributing” and “no style” buildings in the revised rules. LPC staff intends meet with preservation groups, community stakeholders, and community boards for further discussion before finalizing the rules and bringing them before the Commissioners for a final vote.

“LPC rolls back elements of proposed changes to landmarking process,” curbed.com, May 31, 2018. 

LPC explainer on rules changes 

LPC Presentation from May 29, 2018