Click here for a PDF of this support letter submitted to the NYS Department of Environmental Conservation on August 15, 2025.

---

August 15, 2025

Steve Guglielmi
NYSDEC
PO Box 296, 1115 State Route 86
Ray Brook, NY 12977

RE: Debar Pond Lodge 2025 DEIS Draft Scope Comment

Dear Mr. Guglielmi:

The Preservation League of New York State submits the following comments in response to the NYS Department of Environmental Conservation’s (DEC) Draft Scope for its Draft Environmental Impact Statement (DEIS) for the Debar Mountain Complex. The League is New York’s statewide nonprofit historic preservation organization. We frequently partner with our regional colleagues at Adirondack Architectural Heritage (AARCH) to support preservation efforts throughout the Adirondack region.

In recent years, we have worked with AARCH and the Debar Pond Institute to support preservation and reuse of Debar Pond Lodge, advocating for passage of a constitutional amendment to remove the remaining historic buildings from the Adirondack Forest Preserve. Today, we continue to support AARCH’s call for a collaborative approach that would reclassify the lodge complex as Historic.

AARCH has extensive experience working collaboratively with the DEC and Town of Newcomb on the stabilization, restoration, and interpretation of Great Camp Santanoni, part of the Adirondack Forest Preserve, in Essex County. The League stands ready to support any efforts to explore similar collaborative reuse options.

We respectfully offer the following specific comments in response to the Draft DEIS Scope:

Non-Conforming Structure: New York State has an option to keep Debar Pond Lodge and manage the surrounding land as Wild Forest through the Historic land use classification available in the State Land Master Plan. Places such as Hurricane and St. Regis Mountain fire towers and Great Camp Santanoni remain as conforming structures under this classification. Again, AARCH’s collaborative stewardship of Great Camp Santanoni provides a template for this model.

Significance: As an example of Adirondack camp design, an important work of noted regional architect, William Distin, and due to its direct association with Adirondack tourism in the first half of the twentieth century, Debar Pond Lodge is indeed significant to the history, architecture, and culture of the Adirondack Park. All of these areas of significance are enumerated in the National Register of Historic Places nomination. As such, the Debar Pond Lodge meets the APSLMP definition for Historic areas.

Initial List of Potential Mitigation Measures: The potential mitigation measures listed in the Draft Scope, such as public educational materials and interpretive elements, would do little to mitigate the loss of a significant historic structure that helps tell the unique history of the Adirondack Park and that could serve as an accessible site from which to enjoy Debar Pond’s natural environment.

Potential challenges and benefits of rehabilitation: While the reuse and programming of the lodge would require a significant investment, the demolition and removal of Debar Pond Lodge will cost time and money in DEC resources, with no benefit to the public. Resources could be more economically put towards building repairs. In addition, AARCH—a respected and professional regional preservation organization, with a 35-year history of partnership with the DEC—has expressed readiness to commit to a public/private partnership that could bring significant resources to the table.

The potential benefit to the public of such a partnership would be greater than that of demolition. With proximity to a parking area, the lodge could provide accessible restrooms and public recreation facilities (a stated DEC goal for the site). The lodge would allow the public to explore the intersection of nature and culture in the Adirondacks and would serve as a draw for visitors.

There are few places in the forest preserve where one can experience wilderness in concert with historic architecture on public land. The harmony of historic architecture with an incredibly beautiful natural surrounding serves as a net asset to the people of New York State. Creating beautiful accessible spaces for all people who would like to experience the peacefulness of Debar Pond and incorporating a historic structure built in concert with its surroundings democratizes the space and contributes to creating an Adirondacks for all to enjoy.

Thank you for the opportunity to comment and for your consideration. Please do not hesitate to contact me or my staff if the Preservation League can be of assistance.

Sincerely,

Jay DiLorenzo
President, Preservation League of NYS

Click here for a PDF of this support letter submitted to the Rochester Planning Commission on August 15, 2025.

---

August 15, 2025

Rochester Planning Commission c/o City of Rochester Department of Planning and Zoning
30 Church Street, Room 125B
Rochester, NY 14614

RE: L-001-25-26, Landmark Designation 76 Anderson Avenue, Cutler Mail Chute Company Building

Dear Members of the Planning Commission:

On behalf of the Preservation League of New York State, I write in strong support of landmark designation of the Cutler Mail Chute Company Building at 76 Anderson Avenue. This designation not only aligns with the City's longstanding preservation goals but also directly advances the objectives and policies outlined in the 2034 Comprehensive Plan (2034 CP) and City Code § 120-193A(3)(b), which guide your Commission’s review.

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. As New York’s statewide nonprofit preservation advocacy organization, we support the efforts of Rochester’s citizens to recognize and protect this highly significant building.

The property meets each of the Planning Commission standards for designation, outlined below.

§ 120-193A(3)(b)-1 – The proposed designation will be in harmony with the City's Comprehensive Plan and overall planning program of the City.

The 2034 Plan identifies historic preservation as a key strategy for Reinforcing Strong Neighborhoods and emphasizes “capitalizing on the unique existing assets within the city,” including historic buildings like this one. The Cutler Mail Chute Company Building is a visual and cultural anchor within the Neighborhood of the Arts (NOTA), whose very identity has been shaped by the reuse of historic industrial and commercial buildings.

Designating this building will reinforce the city’s historic character, as encouraged by the 2034 CP, while continuing the pattern of strategic reinvestment along Anderson Avenue. Furthermore, the designation poses no barriers to adaptive reuse—in fact, the property has been determined eligible for listing in the National Register of Historic Places as part of the proposed Anderson Avenue Historic District, which would make the property eligible for state and federal historic tax credits, supporting economic development and job creation. The property’s M-1 zoning district remains fully intact, allowing redevelopment in line with current land use goals.

§ 120-193A(3)(b)-2 – The proposed designation will not adversely impact the growth and development of the City.

Preserving this structure will not hinder the city’s growth or development goals. Similar industrial-era buildings have been successfully adapted across Rochester—many with landmark status and historic tax credits—such as the Sibley Building, Gannett Building, and Bevier Memorial Building. The existing footprint and exterior configuration, which would not be replicable under current NYS Building Code, make this building a particularly valuable candidate for preservation. The leniency offered to designated historic buildings by code provisions enhances feasibility for future investment and redevelopment. Importantly, the proposed designation applies only to the exterior, allowing full flexibility for interior adaptation to meet contemporary uses.

§ 120-193A(3)(b)-3 – The proposed designation will not adversely impact any scheduled public improvement or renewal project.

The proposed designation affects only a single privately owned parcel, with no implications for the public right-of-way or known easements. Therefore, there is no conflict with public improvement or renewal projects scheduled or envisioned for the area.

In summary, the Cutler Mail Chute Company Building satisfies all relevant Planning Commission criteria for landmark designation. It upholds the intent of the City’s preservation ordinance, aligns with the 2034 Comprehensive Plan’s neighborhood and economic development goals, and promotes orderly, character-driven reinvestment in one of Rochester’s most iconic urban districts.

We respectfully urge the Planning Commission to support this landmark designation and help safeguard one of Rochester’s irreplaceable historic assets.

Sincerely,

Caitlin Meives
Director of Preservation, Preservation League of NYS

Click here for a PDF of this sign-on letter in support of the Tony Dapolito Recreation Center, sent to NTC Mayor Adams on July 22, 2025.

July 22, 2025

Mayor Eric Adams
City Hall
New York, NY 10007
First Deputy Mayor Randy Mastro
City Hall
New York, NY 10007

Re: Restoration and Reopening of the Tony Dapolito Recreation Center, 1 Clarkson Street, Manhattan

Dear Mayor Adams and First Deputy Mayor Mastro:

As community and preservation organizations representing thousands of residents of Lower Manhattan and New Yorkers from across the five boroughs, we write to strongly urge you to ensure that the landmarked and much beloved Tony Dapolito Recreation Center, now closed for more than five years, is restored, modernized, and reopened. We have been deeply dismayed by the Parks Department’s ongoing effort to demolish the building.

Community support for restoring and reopening the existing Tony Dapolito Recreation Center has been overwhelming and consistent. While this community supports creating new supplemental indoor public recreation facilities in 388 Hudson Street, there is and always has been a clearly stated desire to see the existing Center repaired and reopened. That has manifested in overwhelming sentiment expressed at Community Board meetings, a community board resolution overwhelmingly opposing demolition and calling for restoration, nearly 40,000 letters sent by nearly 5,000 people to various public officials calling for the Center to be restored and reopened, and multiple letters from more than 20 downtown community groups and preservation organizations from across New York City and State calling for the same. Additionally, more than 200 people attended a rally on June 1 of this year calling for restoration and reopening of the Center, and Councilmember Bottcher has called for moving ahead with a process for designing a reimagined Tony Dapolito Center which would “retain, at minimum, the existing facades of the building, while also exploring new uses that allow for the preservation of as much of the building’s historic interior as feasible,” and that “preservation should be a foundational component of any future proposal.”

The Center’s deteriorated condition is a direct result of deferred maintenance and a failure to undertake needed repairs, upgrades, and restorations. We urge you to call upon the Landmarks Preservation Commission (LPC) to pursue a failure to maintain violation against the Parks Department to compel it to begin the process of repairing the building, as the LPC has already been called upon to do. Disturbingly, they have thus far refused to do so.

We urge you to commit to repairing, modernizing, and reopening the facility, and to putting forward a plan to do so as soon as possible. None of the issues with the building are beyond the scope of repair, and none of the updates needed are incompatible with continued use of the building for recreational purposes, even if some spaces may no longer be used for the same purposes that they have in the building’s most recent incarnation. A building is needed on this site to serve the adjacent outdoor swimming pool, and even with a new recreational facility at 388 Hudson Street, the need for a public recreation center here remains. Aside from the deep connections the Lower Manhattan community and a wide array of New Yorkers feel to this building and the need for public recreational facilities which it could serve, this structure was quite intentionally landmarked in 2010 as part of the Greenwich Village Historic District Extension II, recognizing its importance to the history of our city. To allow it to be destroyed rather than repaired and reopened would be incredibly damaging to the regulations which exist to preserve and protect all our city’s recognized historic properties.

We look forward to your response.

Sincerely,

Andrew Berman
Executive Director, Village Preservation

Jay DiLorenzo
President, Preservation League of NYS

Keri Butler
Interim President, Municipal Art Society (MAS)

Peg Breen
President, NY Landmarks Conservancy

Frampton Tolbert
Executive Director, Historic Districts Council

Sean Khorsandi
Executive Director, Landmark West!

Nuha Ansari
Executive Director, Friends of the Upper East Side Historic Districts

Lo van der Valk
President, Carnegie Hill Neighbors

Claudette Brady
Executive Director, Save Harlem Now!

Sommer Omar
Founder, The Coalition to Save the Public Recreation Center Downtown

Richard Corman
President, Downtown Independent Democrats

Raymond Cline
President, Village Reform Democratic Club

Sean Sweeney
Director, SoHo Alliance

Mark Fielder
President, Bleecker Area Merchants Residents Association (BAMRA)

David Mulkins
President, Bowery Alliance of Neighbors

Micki McGee
Founding Member, South Village Neighbors

Patricia Aakre
Board Member, Friends of Finn Square

Pat Bates
Founding Member, Team Min

Kenny Wind
President, Grand Street Democrats

Ellen Breslow Newhouse
Founder, The Wednesday Group

Kim Beck
Co-Founder, Downtown Nasty Women Social Group

Irene Kaufman
Co-President, Village Independent Democrats

Erin Quinn Purcell
President, Westbeth Artists Residents Council

Augustine Hope
President, West Village Residents Association

Kathryn Arntzen
President, Central Village Block Association

Steve Gould
Founding Member, Christopher Street Merchants Block Association

Marguerite Martin
President and Co-Chair, West 12th St. Block Association

Maria Leao
Executive Director, Village Kids NYC

Executive Committee
Chelsea Reform
Democratic Club

The Preservation League of NYS sent this letter to the entire New York State Congressional Delegation on Monday, June 2. Along with our Preservation Colleagues , the League is determined that our elected representatives in Congress understand the importance of the Historic Preservation Fund and related programs in communities across New York State. Click here for a PDF copy of this letter.

Preservation Colleagues Sign-on Letter to the New York State Congressional Delegation

June 2, 2025

Re: Historic Preservation Fund

Dear Senators Schumer and Gillibrand, and Representatives Clarke, Espaillat, Garbarino, Gillen, Goldman, Jeffries, Kennedy, LaLota, Langworthy, Latimer, Lawler, Malliotakis, Mannion, Meeks, Meng, Morelle, Nadler, Ocasio-Cortez, Riley, Ryan, Stefanik, Suozzi, Tenney, Tonko, Torres, and Velazquez,

Historic preservation in New York State, and throughout the nation, is under threat. The Preservation League of New York State, along with the undersigned New York preservation nonprofit organizations, call on Congress to save the programs that support critical preservation projects across our state. 

Of urgent concern: The President’s proposed FY 2026 budget guts the Historic Preservation Fund (HPF). 

The budget proposes a $197 million cut to the HPF, essentially destroying it. This will devastate historic preservation efforts statewide, with immediate and long-lasting consequences. Communities large and small rely on HPF funding to provide affordable housing, promote heritage tourism, celebrate their history, and support economic development.

Without HPF funds, the New York State Historic Preservation Office (NY SHPO) may face significant staffing cuts and elimination of grants to local municipalities. The agency will be hindered as it carries out duties mandated under the National Historic Preservation Act (NHPA). Those include survey and inventory of historic resources, preparing National Register nominations, review and compliance under Section 106, and administration of the Historic Tax Credit program.

Millions of dollars’ worth of public and private investment in New York’s infrastructure, affordable housing, and other redevelopment projects will be jeopardized. 

➤ We call on Congress to demonstrate continued, bipartisan commitment to our nation’s history, ahead of the 2026 Semiquincentennial – by proposing FY26 appropriations necessary for SHPOs to carry out the requirements of the NHPA, emphasizing their role as stewards of our nation’s history; and by investing in preservation projects that recognize the past, with an eye toward the future.

In addition to the threat to FY 2026 HPF funds, already-appropriated FY 2025 HPF funds have not been released. 

Congress appropriated FY 2025 HPF funds in March 2025, but they have not been released to State and Tribal Historic Preservation Offices (SHPOs and THPOs). The Federal appropriation to NY SHPO is around $1.7 million, the third-highest operational grant in the nation. With those funds, the NY SHPO leads the nation in multiple categories: consultation reviews (11,000+ annually), historic tax credits ($7.17 billion in total rehabilitation investment 2018-2024), and National Register of Historic Places listings (nearly 130,000).

➤ We call on Congress to facilitate the immediate approval of the FY2025 Notice of Funding Opportunity (NOFO) so that NY SHPO and NY’s eight THPOs can continue to aid in the preservation of our state’s heritage.

Further jeopardizing our ability to carry out preservation programs in New York State are significant staffing cuts imposed on the National Park Service.

The NY SHPO works with numerous federal agency counterparts. NPS layoffs and retirements continue at a rapid pace with a second Reduction in Force (RIF) expected in early June 2025, following the conclusion of a forced retirement cycle by May 31, 2025. New York will experience a significant slowdown or potential halt of infrastructure and historic tax credit rehabilitation project reviews once projects are passed to NPS for final review – discouraging private investment and hampering community and economic growth.

➤ We call for the reinstatement of NPS staff.

As New Yorkers living and working in rural, suburban, and urban communities throughout the state, we call on the federal government to fulfill its obligations under the National Historic Preservation Act of 1966 so that New York State’s rich cultural heritage may continue to sustain our future.

Sincerely,

Adirondack Architectural Heritage, Erin Tobin Executive Director
Docomomo US, Liz Waytkus, Executive Director
Docomomo US New York/Tri-State, John Shreve Arbuckle, President
Friends of Historic Kingston, Dean Engle, Assistant Director
Friends of the Upper East Side Historic Districts, Nuha Ansari, Executive Director
Historic Albany Foundation, Pamela Howard, Executive Director
Historic Districts Council, Frampton Tolbert, Executive Director
Historic Ithaca, Zachary Lifton, Executive Director
Historic Saranac Lake, Amy Catania, Executive Director
Landmark Society of Western New York, Wayne Goodman, Executive Director
Landmark West!, Sean Khorsandi, Executive Director
New York Landmarks Conservancy, Peg Breen, President
NYC LGBT Historic Sites Project, Ken Lustbader, Project Director
Otsego 2000, Ellen Pope, Executive Director
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, Jackie Powers, Executive Director
Saratoga Springs Preservation Foundation, Samantha Bosshart, Executive Director
Save Harlem Now!, Claudette Brady, Executive Director
Schenectady Heritage Foundation, Gloria Kishton, Chair
TAP Inc., Barb Nelson, AIA, Executive Director
Thousand Island Park Landmark Society, Trude Fitelson, President
Village Preservation, Andrew Berman, Executive Director

View fullsize

Historic Preservation Fund Gutted

These funds are vital to the preservation that happens every day in New York State. Unfortunately, FY 2025 funds have not been released to SHPOs, THPOs, and competitive grant programs under the HPF, leaving offices short of funds and preservation projects stalled, despite being appropriated by Congress. In addition, the President’s proposed budget seeks to eliminate the HPF almost entirely. This is a complete abandonment of states who are tasked with implementing important parts of the National Historic Preservation Act. This is in addition to cuts and staff reductions at the National Park Service itself.

Please reach out directly to your members of Congress and tell them that we need to release FY 2025 funds for SHPOs, THPOs and competitive grants, and ensure a strong appropriation for the Historic Preservation Fund in the FY 2026 budget.

Specific calls to action and how-to’s from Preservation Action:

1.Reach out to your members of Congress and ask them to help facilitate the immediate approval of the FY25 Notice of Funding Opportunity (NOFO) for the Historic Preservation Fund and subsequent review and approval of applications.

• These funds are urgently needed to ensure the work of SHPOs and THPOs continues to aid in the preservation of our nation’s heritage

• Without prompt funding State and Tribes will be forced to eliminate federally-required staff – jeopardizing billions in investment

• Share the Historic Preservation Under Threat one-pagers with your members of Congress and let them know how these funding delays are impacting your state and community! This is especially important if your members are on the House or Senate Appropriations Committee.

• If you have personal contact in your Representative or Senator’s office, reach out to them directly. If you need any help finding staff contacts, feel free to reach out to Rob Naylor at Preservation Action (rnaylor@preservationaction.org). 

2.Ask your Representatives to sign onto the FY26 House Historic Preservation Fund Dear Colleague Letter. This bipartisan letter is being circulated by Rep. Mike Turner (R-OH) and Rep. Teresa Leger Ferrnandez (D-NM), and requests $225 million for the HPF – the same amount advocated for during Advocacy Week. The deadline for signatures is COB Thursday, May 15.

• Offices can sign-on by using the internal Quill link (this is for internal House use only) or by reaching out to Clare Pavell at Clare.Pavell@mail.house.gov in Rep. Turner’s office or Mark Zientek at Mark.Zientek@mail.house.gov in Rep. Leger Fernandez’s office. 

• Review the FY26 House HPF Dear Colleague Letter and learn more here. Stay tuned for more details coming soon on a Senate letter.

• Check out our action campaign to easily personalize and send a letter to your Representative today!

The Historic Preservation Fund (HPF), funded by Outer Continental Shelf oil and gas lease revenues, provides financial assistance to states, tribes, territories, local governments, and nonprofits. HPF grants are awarded annually to State Historic Preservation Offices based on an apportionment formula for their work in fulfilling their responsibilities under the National Historic Preservation Act of 1966 and includes a 10% pass-through of HPF grant funds to directly support local preservation projects and provide preservation training and guidance. This includes the administration of the Certified Local Governments Program (CLG), survey and inventory of historic resources, preparing National Register nominations, review and compliance under Section 106, and administering the preservation tax credit program. In New York, this Federal appropriation is around $1.7 million, the third-highest operational grant in the nation.

In addition to annual formula grants given to states, the HPF has also funded competitive grant programs including, African American Civil Rights Grants, Save Americas Treasures Grants, Paul Bruhn Historic Revitalization Grants, Underrepresented Communities Grants, and others.  

Important Changes to the NYS Historic Tax Credit Program

We want to thank Governor Kathy Hochul and the NYS Legislature for their leadership in making important improvements to the NYS Rehabilitation Tax Credit Program during the creation of the FY2026 budget. Sentor Brian Kavanagh and Assemblymember Carrie Woerner championed the legislation in their respective houses. These changes make the historic tax credit an even more powerful tool for the creation of affordable housing and community revitalization in New York State.

Specifically, the new legislation makes two important changes to the program.

1.       Allows for transfer of the NYS Historic Tax Credit. This will increase the pool of eligible tax credit investors and thereby increase the value of the credits, meaning more money for projects.

2.       Removes the current requirement that tax credit projects must be in a census tract at or below the state median family income if the project creates affordable housing. This further strengthens the indispensable role that preservation plays in providing housing.

Special thanks to our colleagues and to the NYS Association for Affordable Housing for their partnership in advocating for this program!

Co-Sponsors Needed for HTC-GO

The updated language for the Historic Tax Credit Growth and Opportunity Act [HTC-GO (H.R. 2941/S. 1459)] has been introduced in Congress and the proposed changes would be a tremendous improvement over the current program. Co-sponsored by Representative Tom Suozzi (D-NY 3) in the House, the legislation would add more muscle to the program in smaller, rural communities, make rehab credits available to more projects, incentivize housing development and increase the value of the credit to investors overall.

Our national partners at Preservation Action are asking all of us to encourage our representatives in Congress to sign on as co-sponsors of this important legislation. This is all happening very quickly, so your outreach is important now.

Here is an HTC-GO Fact Sheet put together by Preservation Action with more information on the bill that you can share with offices as well as their Action Alert.

This Advocacy Alert is reposted from our colleagues at Preservation Action. Click here for Preservation Action’s HTC-GO one-pager .

---

Advocacy Alert: Urge Your Members of Congress to Cosponsor the Historic Tax Credit Growth and Opportunity Act and Include Provisions in Emerging Tax Legislation

Senate and House champions have introduced the Historic Tax Credit Growth and Opportunity Act (H.R. 2941, S.1459). Led by Sen. Bill Cassidy (R-LA) and Sen. Mark Warner (D-VA) in the Senate and Rep. Darin LaHood (R-IL) and Rep. Tom Suozzi (D-NY) in the House, these bills include several provisions that will restore value to the Historic Tax Credit (HTC), improve access to the credit, make more projects eligible to use the credit, and boost the credit for smaller and rural rehabilitation projects. The bill includes the following provisions:

HTC-GO Provisions

• Returns to a 1-year delivery of Historic Tax Credits for all projects

• Eliminates the HTC Basis Adjustment, bringing more value to HTCs and making it easier to pair with the Low-Income Housing Tax Credit

• Reduces the substantial rehabilitation threshold from 100% to 50%, making more buildings eligible to use the HTC

• Modifies Tax Exempt Use Rules, making the credit easier to use by non-profits

• Increases the credit from 20% to 30% for small projects below $3.75 million

• Increases the credit from 20% to 30% for projects below $5 million in rural areas

• All small/rural projects are eligible for direct transfer

The federal HTC is the largest federal investment in historic preservation and a critical economic development tool used to revitalize our communities, create jobs, and preserve our heritage. Unfortunately, the HTC has not kept pace with other federal incentives and needs to be modernized. Additionally, over the past decade, HTCs have lost 25% of their investment value due to unfavorable IRS rulings, administrative burdens, and changes in the credit structure. The provisions in the HTC-GO Act would help restore the credit’s lost value and make the credit easier to use.

With a series of tax provisions expiring at the end of the year, one of the top priorities of Congress and the White House will be passing a large tax package. This provides a huge opportunity to ensure HTC provisions are included in the emerging tax bill. The House and Senate passed budget resolutions that clear the way to pass budget reconciliation bills, which could move early this summer. Advocates will also be paying close attention to any attempts to weaken the HTC as lawmakers seek cost-saving measures.

The voice of preservation advocates will be absolutely essential to make the case for enhancing the HTC, ensuring it is included as part of emerging tax legislation, and fending off any potential threats to diminish the credit.

We need your help!

Urge your Members of Congress to co-sponsor the bipartisan Historic Tax Credit Growth and Opportunity Act (H.R. 2941, S. 1459) and include HTC provisions in emerging tax legislation

If you have a personal contact in your Representative or Senators’ office, contact that person directly, especially if you just met with their office during Advocacy Week. Urge them to co-sponsor the Historic Tax Credit Growth and Opportunity Act (H.R. 2941, S. 1459). If they do not handle tax issues please ask that they pass the message along to the appropriate staff person. Preservation Action has also made it easy for you take action. Check out our action campaign to easily personalize and send a letter to your members of Congress and share this alert with your networks!

On February 13, the National Park Service removed all instances of the words Transgender and Queer from the Stonewall National Monument website, as well as other sites and resources referencing LGBTQ+ history. In 1999, Stonewall was the first site in the country listed on the National Register of Historic Places for its significance to LGBTQ+ history. We are proud that it is in New York State and was listed through the efforts of preservationists and the state historic preservation office.

The Stonewall National Monument, designated in 2016, is based on the boundaries established in this earlier nomination and is the first and only national park dedicated to LGBTQ+ history. The history of the Stonewall uprising is intertwined with the civil rights of the United States and all citizens. It demonstrates the power of activism by the full range of LGBTQ+ activists who rose up in June 1969, changing the trajectory of the LGBTQ+ rights movement. 

“Transgender and Queer participation cannot be erased and written out of the historical record like it never happened.”

As a preservation movement, we say in no uncertain terms that LGBTQ+ history is our history, and it needs to be amplified and celebrated. We choose not to remain silent while attempts are made to deny the existence of Trans people, both past and present. Revising the historical record for political purposes is dangerous and unacceptable.

The Preservation League of NYS stands for a preservation movement that is for everyone – a core tenet is promoting diversity, equity, and inclusion in all that we do. Denying or inventing history may make some feel more comfortable, but it is neither accurate nor constructive. Preserving and celebrating diverse histories is essential – whether that means preserving sites related to disability history or places that represent the immigrant experience, telling the stories of women’s history, honoring Asian American histories, amplifying the work of Transgender activists, supporting Latinx communities, or celebrating Black culture – all of it matters and we stand with our allies who continue to do this important work.

In New York State, we continue to preserve our past to work toward a more just and sustainable future. We count among our partners in this work the organizations listed below and many others. You have our word that together we will always seek to tell the full story of our shared history.

Click here for a PDF of this statement. We are happy to continue adding co-signers to this statement. Please reach out if your organization would like to be added.

On February 14, the League joined colleagues at the New York Landmarks Conservancy, Village Preservation, Save Harlem Now!, and Landmark West! in a joint letter to NYC Mayor Eric Adams, NYC Department of Parks and Recreation Commissioner Sue Donoghue, NYC Landmarks Preservation Commission Chair Sarah Carroll, Manhattan Borough President Mark Levine, City Councilmember Erik Bottcher, and Manhattan Community Board 2 Chair Susan Kent, to express our strong opposition to the proposed demolition of the Tony Dapolito Recreation Center. The body of the letter is below. Click here for a PDF of the signed letter.

---

Re: Potential demolition of the historic Tony Dapolito Recreation Center (1 Clarkson Street, Manhattan), as presented to Manhattan Community Board 2 on February 5, 2025

Dear Mayor Adams, Commissioner Donoghue, Chair Carroll, Borough President Levine, Councilmember Bottcher, and Chair Kent:

We write in strong opposition to the proposed demolition of the Tony Dapolito Recreation Center, as presented by the New York City Department of Parks and Recreation at the February 5, 2025, joint meeting of the Community Board 2 Parks & Waterfront and Landmarks Committees. The proposal to demolish this historic, city-owned, landmarked building is unnecessary, harmful to the neighborhood, environmentally unsound, and would set a dangerous precedent.

The New York City Department of Parks and Recreation has not provided any information that would justify or necessitate the complete demolition of this historic building. Their primary argument, that the building was constructed in three phases and thus cannot be adequately repaired, is spurious and runs counter to evidence and experience with buildings that have been restored under similar circumstances throughout our city.

As historic preservation advocates, each of our organizations reviews numerous proposals undergoing review at the Landmarks Preservation Commission every month. The vast majority of these projects involve buildings at least as old as the Tony Dapolito Recreation Center, many of which were also constructed in phases initially, or have had new additions introduced over time. These buildings are often coming forward for new structural work, such as the introduction of rear yard and rooftop additions, and sometimes for extensive gut renovations of their interiors. None of them are beyond repair or adaptation. Our historic buildings can be renovated, restored, and preserved.

The Tony Dapolito Recreation Center should likewise be repaired, restored, and modified as needed to suit a modern purpose. Its three street-facing facades, where most original materials and Colonial Revival-style architectural features remain, including the red brick and limestone details at the exterior (and the original Guastavino tile-arch system throughout the interior), should be retained during future renovations to the extent feasible. With this in mind, the building can be repurposed to fit a whole range of potential new uses. Many creative solutions are plausible here.

However, the Parks Department’s claim that they will “honor history and preserve historic elements where possible” is vague and entirely insufficient for a contributing building to a historic district. It offers no commitment, and implies perhaps embedding disembodied fragments of the existing building into a new one. This is an unacceptable solution.

Our city contains a great many buildings that are older than the Tony Dapolito Recreation Center, built in as many or more sections over time, and subsequently altered and used for different purposes while their historic materiality has been retained, and often even substantially restored. Just a few prominent examples located near the Center include the Jefferson Market Library (built in 1874-77 as a courthouse, significantly altered in 1967), Westbeth (built c. 1860 as the Bell Telephone Laboratories Complex, altered in 1896-1903, 1924-26, 1929, 1931-34, and 1968-70), and the Astor Library (built in three phases between 1849-53, 1856-59, and 1879-81, and saved from demolition and adapted for use as an immigrant processing center and then as a theater), among many other cases. The city has an opportunity to now similarly preserve this original turn-of-the-century bath house, which was transformed into a recreational center in 1938, and further adapt it to serve as a modern community facility.

The Parks Department has also indicated that the wall of the recreation center’s cellar vault is approximately five feet away from a subway tunnel, citing this as a barrier to preservation of the building. But countless extant 19th and early 20th century buildings throughout New York City are impacted by subway tunnels in this way, including in historic districts such as the SoHo-Cast Iron Historic District, where many of the sizable commercial buildings feature underground vaults adjacent to subway routes.

Regarding Parks’ argument that the Guastavino tile system at the recreation center’s interior is too fragile, it should be noted that Grand Central Station, the Queensboro Bridge, and Manhattan’s Municipal Building (which for most of its 110 year lifetime has had heavily trafficked Chambers Street running directly underneath the building), are just three examples of high-traffic historic structures that also utilize a Guastavino tile system, and have experienced significantly greater structural stress than the Tony Dapolito Recreation Center, yet remain intact and fully functional.

To allow for the demolition of the landmarked Tony Dapolito Recreation Center would set a troubling and deeply problematic example. The Tony Dapolito Recreation Center has been under the ownership of the City of New York since it opened as a bath house in 1908. The onus has always been on the city to keep the building in good repair, but instead, the city has let it decay and continue to deteriorate for the past five years since its initial closure, not to mention in the decades prior. These years of neglect, deferred maintenance, and delayed action by the city should not be rewarded with permission to demolish the building. The Tony Dapolito Recreation Center must be preserved and reopened to serve the community, as it always has.

We also strongly urge that the Parks Department’s spoken commitment to retain this space for only parks and recreation use be made in writing and binding so that this commitment does not change as others like it have. And we urge the Community Board and elected officials to remain vigilant about the maintenance of this commitment, as we will, since its fulfillment is far from guaranteed.

Sincerely,

Jay DiLorenzo, President, Preservation League of NYS

Peg Breen, President, The New York Landmarks Conservancy

Andrew Berman, Exec. Dir., Village Preservation

Claudette Brady, Exec. Dir., Save Harlem Now!

Sean Khorsandi, Exec. Dir., Landmark West!

This sign-on letter follows an earlier public comment from the League and our Preservation Colleagues, which you can find here. For a PDF of the December 13 letter, click here.

December 13, 2024
Advisory Council on Historic Preservation
Sarah Bronin, Chair
401 F Street NW, Suite 308
Washington, DC 20001

Dear Chair Bronin:

Thank you for the opportunity to comment on the revised Program Comment on Certain Housing, Building, and Transportation Activities. On behalf of the undersigned New York-based preservation nonprofit organizations, the Preservation Colleagues network, the Preservation League of New York State respectfully submits the following comments.

We appreciate that many of our concerns were addressed and that the document is easier to follow. We have no major concerns with the processes and activities covered under Appendix A of the revised Program Comment.

However, we remain concerned that State Historic Preservation Offices (SHPOs) are essentially cut out of the Section 106 process for any activities covered under Appendix B. We appreciate the gesture of adding the option for federal agencies to consult with the relevant SHPO (Appendix B, Section 1) but this is unlikely to occur in practice. By not consulting with SHPO, federal agencies and/or their consultants are left with little accountability and are left to make their own determinations regarding National Register eligibility.

The lack of notification requirements remains a concern as well. With respect to Dispute Resolution (Section VI), how and when would a member of the public, local government, SHPO, or other entity become aware of an undertaking? Without consultation requirements, how will there be any consulting parties?

Finally, the lack of notification requirements and the lack of SHPO input could result in the intentional or unintentional loss of historic resources and/or character defining features that have not yet been identified in surveys or listed in the National Register. This could disproportionately impact historically marginalized communities, which are generally less well documented.

Thank you for your consideration.

Sincerely,

Adirondack Architectural Heritage, Erin Tobin, Executive Director
Friends of the Upper East Side Historic Districts, Nuha Ansari, Executive Director
Historic Albany Foundation, Pamela Howard, Executive Director
Historic Districts Council, Frampton Tolbert, Executive Director
Historic Ithaca, Susan Holland, Executive Director
Landmark Society of Western New York, Wayne Goodman, Executive Director
New York Landmarks Conservancy, Peg Breen, President
Preservation Association of Central New York, Nicole M. 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
Saratoga Springs Preservation Foundation, Samantha Bosshart, Executive Director
TAP Inc., Barb Nelson, AIA, Executive Director
Village Preservation, Andrew Berman, Executive Director

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