Letter to the Governor: Advocating for HTC Enhancements
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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.
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.
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.
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.
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