Testimony of the Preservation League of New York State, Submitted by Katie Eggers Comeau, Vice President for Policy and Preservation Preservation League of New York State, to the Joint Legislative Budget Hearing of the Environmental Conservation Committees on Tuesday, February 14, 2023. Click here to download a PDF of this testimony.

Chairwoman Krueger, Chairwoman Weinstein, and distinguished members of the Senate and Assembly, thank you for the opportunity to provide testimony on the topic of historic preservation and the New York State FY 2024 Budget.

As New York State’s only statewide historic preservation nonprofit organization, the Preservation League of New York State invests in people and projects that champion the essential role of preservation in community revitalization, sustainable economic growth, and the protection of our historic buildings and landscapes. We lead advocacy, economic development, and education programs across the state and partner with local preservation organizations throughout New York.

Our testimony includes comments on the reuse of existing buildings as an essential tool in addressing both climate change and the housing shortage, support for the legislatively proposed extension and enhancement of the New York State Historic Tax Credit, and support for the Governor’s proposed budgets for the New York State Council on the Arts, New York State Office of Parks, Recreation and Historic Preservation, and the Environmental Protection Fund.

Existing Building Reuse: A Smart Approach to Housing and Climate Goals
We applaud Governor Hochul and the Legislature for setting ambitious goals to address both the climate crisis and the statewide housing shortage. Reusing existing buildings is a smart, sustainable strategy and an essential component of both efforts.

Building reuse is a climate-friendly practice with multiple environmental benefits: it keeps valuable, irreplaceable building materials out of landfills, reduces the expenditure of operational energy and waste of embodied energy associated with demolition and new construction, reuses existing infrastructure, enhances walkable communities, and reduces the need for greenfield development.

These benefits of building reuse are multiplied when existing buildings are repurposed to create housing, particularly affordable housing. Throughout New York State, particularly in Upstate cities and villages, historic buildings including rowhouses, schools, and warehouses have been rehabilitated to create affordable housing, often using a combination of historic rehabilitation tax credits and lowincome housing tax credits, among other incentives. These projects provide affordable housing options that are also unique, desirable living spaces, and prevent demolitions that can destabilize and devalue neighborhoods.

Extending and Enhancing the New York State Tax Credits
The most important tools available in New York State to promote the reuse of historic buildings are the state and federal rehabilitation tax credit programs. Since the New York State Commercial and Homeowner Historic Tax Credit (HTC) programs were put in place in 2007, they have developed a proven track record of revitalizing historic buildings and neighborhoods, particularly in upstate communities where their use leverages significant federal funding in economically challenged neighborhoods. The commercial and homeowner HTC programs are currently authorized until December 31, 2024. It is essential that these valuable programs be renewed in the current legislative session.

The commercial Historic Tax Credit program is an important tool for meeting the Governor’s housing goals, particularly when used in combination with Low Income Housing Tax Credits (LIHTC) and other incentives for the creation of affordable housing. Since 2010, rehabilitation projects utilizing State Historic Tax Credits have produced 27,500 housing units in New York State, of which 12,587 (45%) were classified as low-moderate income units. In light of the current housing shortage, we support several legislatively proposed changes to the commercial and residential credits, reflected in bills A. 2889 / S. 4174, that will encourage the creation and retention of affordable housing units in existing buildings:

• Extend both the commercial and residential HTC programs for 10 years rather than five. While in the past the programs have been renewed in five-year increments, now that they have been in existence in their current form for well over a decade, we support a 10-year extension. Rehabilitation projects, particularly those involving incentives for affordable housing production, can require several years’ lead time in the current construction climate; a longer extension will provide greater certainty to building owners wishing to make use of the credits.

• Improve the commercial tax credit’s ability to support the rehabilitation of a limited number of large, vacant buildings that are languishing due to the high cost of rehabilitation. Reactivating these “white elephant” buildings, like the Central Terminal in Buffalo, Victory Mills near Saratoga Springs, and Central Warehouse in Albany, would be transformational for their communities, but the projects are too costly to take full advantage of the state HTC in its current form. Two proposed improvements would address these limitations: first, raising the credit cap from $5 million to $15 million for large projects (over $50 million in rehab costs) involving long-vacant buildings; second, adding the ability to bifurcate and transfer the credits, as was done with the State Low-Income Housing Tax Credits. Bifurcation would allow different parties to invest in the state and federal credits, while transferability (proposed in the bill for “white elephant” projects that incorporate affordable housing) would allow the credits to be transferred to investors rather than used only within the development partnership. These two changes would bring more equity to these projects at no additional cost to the state. While all HTC projects would benefit from these adjustments, they would be particularly beneficial to projects that combine the HTC and the Low-Income Housing Tax Credits, since the inability to bifurcate and transfer the HTC is now limiting the pool of investors, thereby accidentally depressing the value of all tax credits in these projects including the LIHTC, and ultimately resulting in a need for more subsidies.

Last year saw the creation of a new HTC program for owners of historic barns; this program has already facilitated the rehabilitation of dozens of barns statewide since the program was rolled out in the spring of 2022. Some barn owners, including some small farmers, do not have sufficient taxable income to take advantage of the credit, however. We support the refund provision, reflected in bills A. 4030 / S. 3582, that will allow property owners with incomes under $60,000 to take the credit in the form of a rebate. This improvement, modeled on a provision in the Homeowner HTC program, would allow for more equitable use of the credit.

Preservation of Debar Pond Lodge
The Preservation League is partnering with colleagues at Adirondack Architectural Heritage and the Debar Pond Institute in support of a land exchange amendment that will safeguard the future of Debar Pond Lodge, a historic Adirondack lodge built around 1940 and set on the shore of Debar Pond in the town of Duane, Franklin County. Designed by notable Adirondack architect William Distin, Debar Pond Lodge is one of the largest log buildings in the Adirondacks, and is listed in the National Register of Historic Places in recognition of its architectural significance. The nonprofit Debar Pond Institute proposes to donate over 400 acres of wild forest land to the State, to be added to the Adirondack Forest Preserve, in exchange for the State transferring a six-acre parcel, encompassing the lodge and outbuildings, to the Institute. The Debar Pond Institute will use the property for a variety of public environmental and cultural programming. The public will retain access to the shoreline of Debar Pond, which will retain its wild character. We consider this a win-win that retains a magnificent piece of Adirondack architecture, enhances the Forest Preserve, and offers new recreational and cultural opportunities.

Capital Investment at OPRHP and DEC
We greatly appreciate the Governor’s proposal to continue significant investments in capital projects at both OPRHP and DEC. We support the proposed funding for infrastructure improvements and particularly look forward to seeing the results of additional investment in New York State Historic Sites, as well as historic buildings and structures located within our NYS Parks.

Environmental Protection Fund
The Preservation League strongly supports the Governor’s proposed continuation of funding for the Environmental Protection Fund at $400 million, matching last year’s funding. We particularly note the significance of the historic preservation grants, which in recent years have funded projects including municipal and nonprofit restoration of courthouses, town halls, libraries, historic houses of worship that frequently serve multiple functions, and nonprofit arts and cultural centers. These grants then leverage private fundraising to preserve community anchors and centers of cultural tourism, and often have a catalytic impact on their communities.

We thank the Legislature for including $500,000 in EPF funding in the FY 2023 budget to support the work of our colleagues at Adirondack Architectural Heritage (AARCH) maintaining, restoring, and interpreting Camp Santanoni, the only publicly owned Adirondack Great Camp and a National Historic Landmark. This funding has enabled AARCH to significantly expand its capacity to manage and maintain the site, investing in workforce development and safeguarding the future of this important site. We support AARCH’s request for an additional $500,000 in the FY 2024 budget, which will allow them to implement Phase 2 of their fire protection plan and maintain the enhanced level of service they are currently providing.

NYSCA Funding
The Preservation League enjoys a longstanding partnership with the New York State Council on the Arts, and knows the importance of their work to promote and sustain arts and cultural programming and facilities, particularly given the ongoing challenges arts institutions face due to COVID-19. We support the Governor’s proposal to provide $40 million to NYSCA for its core grantmaking programming as well as $100 million for capital grants to nonprofit arts facilities.

Thank you for the opportunity to provide comments as part of the state budget process. We are happy to provide additional information about the above testimony or any other historic preservation issue at the Committee’s request.

We are delighted that Governor Hochul’s Executive Budget Proposal for FY 2024, released on February 1, includes a five-year extension of the New York State Historic Tax Credit (HTC) programs. Securing an extension of the HTC programs is our top priority for the current legislative session, and its inclusion in the Governor’s budget is a key step toward achieving that goal.

The residential and commercial HTC programs are the strongest incentives available for the rehabilitation of historic properties in New York State. The credits are particularly valuable in retaining and creating affordable housing: since 2010, about 40% of the housing created through use of the commercial credit has been low to moderate-income housing. The residential credit, meanwhile, helps homeowners, particularly those in upstate communities, maintain and repair their houses. 

The Preservation League thanks Governor Hochul for her support of the Historic Tax Credit programs, and we look forward to working with our legislative partners to ensure that the extension is included in the final state budget. 

Along with the extension of the credits, we are working with our legislative sponsors, Assemblymember Carrie Woerner and Senator Timothy Kennedy, on proposals to enhance the commercial credit, with the goal of facilitating affordable housing production and the rehabilitation of large, long-vacant buildings. We thank Assemblymember Woerner and Senator Kennedy for their steadfast support of the HTC programs. 

The Executive Budget Proposal also includes $400 million for the Environmental Protection Fund and $140 million for NYSCA, both matching what was in last year’s budget. We appreciate the Governor’s continued support for these programs, which provide significant funding for historic preservation, the environment, and the arts in our state.

As we celebrate the good news about the credit extension, we are going through the rest of the Governor’s budget proposal to identify other items of interest to the preservation community and will be sharing more budget news soon. 

This advocacy alert is reposted from our colleagues at Preservation Action 

Urgent action is needed to advance the National Heritage Area Act of 2021 (S. 1942, H.R. 1316). This important bill would create a much-needed uniform system to reauthorize National Heritage Areas, allocate standard funding, and provide universal standards to how current and future National Heritage Areas (NHAs) are managed and designated. This bill would reauthorize and provide certainty for the 55 current NHAs, including reauthorizing 30 NHAs that are in immediate need and establish 5 new ones. NHAs produce nearly $13 billion in annual economic impact and every dollar in federal funding is matched by an average of $5.50 from other funding sources.

The National Heritage Area Act was advanced by the Senate Energy and Natural Resources Committee with strong, bipartisan support and was added to the Senate Calendar for the current legislative session. This does not mean the Senate will get to it and time is running out, as Congress needs to take action before the end of the year.

Take action! Urge your Representative and Senators to support the National Heritage Area Act and include it as part of any omnibus package. Check out the Alliance of National Heritage Areas to learn more about National Heritage Areas and this important bill. 

The Unmarked Burial Site Protection Act (S5701 / A6724) was passed by both the NYS Senate and Assembly earlier this year. This legislation is long overdue and the League strongly encourages the Governor to sign it into law. If she does not sign the bill before December 31, 2022, it will be effectively vetoed. For more about this issue, please also follow the Shinnecock Graves Protection Warrior Society, who have led much of the advocacy around this topic on Long Island.

December 1, 2022

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

Dear Governor Hochul,

On behalf of the Preservation League of New York State, I write to urge you to sign the Unmarked Burial Site Protection Act, which provides important protections for human remains in unmarked burial sites across the state that are in danger of damage from construction and other disruptions.

New York is one of only three states that lack statewide protection for unmarked burial sites. In recent years, graves associated with Native American Nations, African American communities, and Revolutionary War soldiers have been discovered during construction or development. In the absence of clear legal protocols, the human remains in these sites have lacked protection from desecration and destruction, as do those in other such sites yet to be discovered. The Unmarked Burial Site Protection Act will finally establish a clear legal process to protect human remains discovered during construction, by requiring that these sites and remains are treated with respect, the proper authorities are notified, and the remains are ultimately handled in an appropriate way. 

The League strongly encourages you to sign this important legislation.

Sincerely,

Katie Eggers Comeau
Vice President for Policy and Preservation

Click here for a PDF of this support letter.

November 17, 2022

Supervisor Peter Van Scoyoc and Members of the Town Board
Town of East Hampton
159 Pantigo Road
East Hampton, New York 11937

Dear Supervisor Van Scoyoc and Members of the East Hampton Town Board,

Preservation Long Island, the Preservation League of New York State, and the National Trust for Historic Preservation, the leading historic preservation advocacy organizations at the regional, state, and national levels, have all identified the James Brooks and Charlotte Park Studios and Residence as a top priority for preservation and rehabilitation due to the property’s exceptional significance in the history of mid-century modern art and design. The buildings used and occupied by Charlotte Park and James Brooks represent a unique opportunity to celebrate their legacy for the benefit of East Hampton residents and visitors, connecting their lives and careers to a broader culture of artistic achievement in this part of Long Island. In 2021, Preservation Long Island listed the site in its Endangered Historic Places List; the National Trust similarly included it on its the “Eleven Most Endangered Places” list in 2022; and the Preservation League named the site one of its “Seven to Save” properties in 2022.

We continue to express our concern for the buildings’ condition if they remain poorly maintained, and urge, in the strongest possible terms, the Town of East Hampton to take swift and significant steps to stabilize and protect the Brooks-Park Studios and Residence ahead of the 2022-23 winter season to prevent further damage, particularly due to water infiltration.

We know full well that their current unprotected status is not due to a funding constraint, but a deficit of political will. The Town has the authority – in fact, the obligation – as well as the funding necessary to stabilize the buildings, and to hire a consulting preservation architect qualified to conduct a thorough assessment of the buildings’ condition and the feasibility of rehabilitation. In § 112-1-50A[4], the East Hampton Town Code requires the Town to “manage and maintain historic properties consistent with accepted standards for historic preservation” (see also § 64-E.9[d] of the enabling New York Town Law). In regard to hiring a consulting preservation architect, please see § 64- E.13 of the enabling New York Town Law for the Peconic Bay Region Community Preservation Fund, which explicitly permits expenditure of fund monies for “cost of employees and independent contractors to implement the provisions of this section.”

Preservation Long Island, the Preservation League of New York State, and the National Trust for Historic Preservation encourage the Town of East Hampton to treat the Brooks-Park Historic Landmark as the treasure that it is, a place that tells the stories of James Brooks and Charlotte Park and their contributions to the development of Abstract Expressionism, as well as an opportunity to celebrate the extraordinary artistic heritage of the Springs. Given the property’s historic significance and cultural importance, we urge the Town of East Hampton to secure the site.

Our collective lenses are focused on preserving this unique, irreplaceable cultural and historic heritage site. Further neglect is the least attractive and most unpopular option. We will follow up in 30 days and eagerly await news of your action.

Sincerely,

Seri Worden
Senior Field Director, National Trust for Historic Preservation

Sarah Kautz
Preservation Director, Preservation Long Island

Katie Eggers Comeau
VP for Policy and Preservation, Preservation League of NYS

Local advocates in Schenectady, led by our colleagues at Schenectady Heritage Foundation, are currently lobbying for historic overlay zoning of the 1918 Masonic Temple. Located on the corner of State Street and Erie Blvd, the building occupies a prominent location in Schenectady’s Downtown district — a neighborhood included on the League’s Seven to Save list back in 2000. The League’s VP for Policy & Preservation Katie Comeau submitted the following letter to the Schenectady Planning Commission in support of the local historic designation of the former Masonic Temple.

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To: Planning Commission, City of Schenectady Department of Development
Schenectady City Hall, 105 Jay Street Schenectady, NY 12305

Dear Commissioners:

On behalf of the Preservation League of New York State, I am writing in support of the local historic designation of the former Masonic Temple at the intersection of State Street and Erie Boulevard. This building has been determined eligible for the State and National Registers of Historic Places “as an excellent local example of an early twentieth century Neoclassical commercial building,” and meets the criteria for local landmark designation as well.

Constructed in 1912 as retail and showroom space for a local furniture store, the building was remodeled several years later to serve as a Masonic temple. Its historic association with the local Masonic organization, as well as its architectural significance and visual prominence, all contribute to its significance and worthiness for landmark status.

At the League, we support efforts by local preservation advocates and municipal preservation boards to designate and protect historic buildings, districts, and landscapes that are important to their communities. Retention and reuse of historic buildings is beneficial to community character, economic revitalization, and environmental sustainability. We encourage the Planning Commission to recommend inclusion of this building in the OH Overlay Historic District.

Sincerely,

Katie Eggers Comeau
Vice President for Policy and Preservation, Preservation League of NYS

Cross-posted from our colleagues at the National Trust Community Investment Corporation, a subsidiary of the National Trust for Historic Preservation

Thank you to all the advocates who reached out to congressional offices, led local meetings, and hosted tours of HTC projects in August! At this critical time, we continue to gain support for the HTC-GO, with 97 House members and 14 Senators cosponsoring the bill. We are steadily approaching our goal of 100 cosponsors in the House and 20 cosponsors in the Senate!

As the 117th Congress winds down, members of Congress will head home in October ahead of the November elections. Depending on the outcome of the elections, Congress will determine whether it will be an active lame-duck session or if it will limit activity to organizing for the new Congress. Scores of federal tax incentives have expired or will expire in 2022, resulting in growing interest from Republicans and Democrats to extend these tax provisions.

Year-end legislation may be a vehicle for HTC improvements. Building support for the HTC-GO now will pave a path for success when year-end legislative vehicles begin to move, possibly during a lame-duck session of Congress.

With about seven remaining weeks until the election, advocates are encouraged to do the following:

1. Use the National Trust E-advocacy tool to contact offices to request cosponsorship of the Historic Tax Credit Growth and Opportunity Act (HTC-GO, HR 2294/S. 2266)

2. Look for opportunities to meet with legislators when they are back home in October. Please connect with Senators and Representatives back home to request cosponsorship of HTC-GO. We encourage you to safely attend upcoming political events and gatherings to discuss the HTC-GO bill. As many did in August, you can also proactively schedule a time to meet with legislators for a meeting or a tour of a local HTC project, especially projects that will become easier to undertake with the HTC if the proposed changes are enacted.

Take Action:

1. Request cosponsorship through the National Trust for Historic Preservation's E-Advocacy tool.

2. Review the HTC-GO fact sheets to stay informed:

   1. House HTC-GO (HR 2294) Fact Sheet

   2. Senate HTC-GO (S. 2266) Fact Sheet

3. Search local and political events or join a local political party's email list to learn about events your members of Congress might be attending.

4. Invite your members of Congress to tour successful historic preservation projects. Take a look at the National Trust's guide to arranging a site visit.

5. Email Michael Phillips (mphillips@ntcic.com) to receive the schedulers' email addresses for your members of Congress and for additional assistance in making your request.

6. Check to see if your members of Congress have already cosponsored:

   1. House HTC-GO Cosponsors

   2. Senate HTC-GO Cosponsors

Talking Points for Discussions with your Members of Congress:

• "Now is the time to strengthen this proven incentive to address the slowdown and challenges in rehabilitation projects across the country."

• "Would you please cosponsor House Bill H.R. 2294/Senate Bill S. 2266-The Historic Tax Credit Growth and Opportunity Act (HTC-GO) and work to include these provisions in year-end legislation?" If the legislator has already cosponsored the bill, thank them instead of asking them to cosponsor.

• Explain how enacting these provisions would benefit your community.

  • For HTC-GO provision talking points, click here.

• Please share the "State of the Historic Rehabilitation Industry" and either the House HTC-GO Fact Sheet or the Senate HTC-GO Fact Sheet as printed handouts or links/attachments as a follow-up.

Resources

• HTC State Maps and Project Lists

Thank you for your advocacy! For assistance in contacting the offices of your members of Congress, please contact us at the email addresses below.

Mike Phillips mphillips@ntcic.com
Shaw Sprague ssprague@savingplaces.org
Patrick Robertson probertson@confluencegr.com

Shared from our colleagues at Preservation Action:

Preservation Action is excited announce the launch of our 2022 Congressional Candidate Historic Preservation Survey. For the fourth time, Preservation Action is surveying U.S House and Senate candidates across the country to gauge support of key national preservation programs and policies. We plan to share the results of the survey widely before the Midterm elections in November. We conducted a candidate survey prior to the 2016, 2018, and 2020 elections and received hundreds of responses. We are excited to hear from even more candidates this year and will be working with our network of state and local preservation organizations to help spread the word.

The goal of the survey is multi-faceted; to educate congressional candidates on the federal historic preservation program, gauge their level of support for critically important preservation programs and policies, educate PA members and supporters on the candidates positions and gain useful insights into congressional candidates background with historic preservation. Using the results of our Grassroots Survey as a guide, the survey asks the following questions:

1. Do you support stable and robust funding for the Historic Preservation Fund?

2. Would you support efforts to permanently reauthorize and enhance the Historic Preservation Fund?

3. Would you support efforts to update the Federal Rehabilitation Tax Credit (HTC) program?

4. Would you support policies that assure the impact to historic and cultural resources continue to be considered in the federal project planning process?

5. Does historic preservation play an important role in your state/district? How so? Describe any personal connections to historic preservation or historic sites. Is there a specific historic place in your district that is important to you and your constituents?

Help support this important work by following up with congressional candidates in your state, urging them to complete Preservation Action’s 2022 Congressional Candidate Survey. A copy of the survey and letter are available here. A list of contact information for congressional candidates (divided by state) is available here. Candidates that have already responded are highlighted in yellow.

Penn Station needs to be improved, but the current Penn Area Plan is not the answer. Join us in speaking out against it!

What's at stake

The League included the Penn Area Neighborhood on our Seven to Save list because Empire State Development's (ESD) proposed Penn Area redevelopment plan would demolish multiple city blocks, including over 40 historic buildings and structures, displacing thousands of residents and businesses. The negative environmental impact of this needless demolition would be a catastrophe. The plan itself raises numerous, serious questions that have yet to be answered, especially regarding how the project will be paid for. The lack of transparency is an insult to locals, and this kind of top-down governmental overreach poses a threat to communities across the state — not just our largest city.

Click here to read an open letter to Governor Hochul from League President Jay DiLorenzo.

What can you do? 

From our colleagues at Human-Scale NYC and the Empire Station Coalition:

Write to the Public Authorities Control Board and tell them to reject the General Project Plan for Penn Station. It is fiscally irresponsible and puts taxpayers statewide on the hook for an unknowable amount of money. This is contrary to the public interest. The project speculates on a revenue stream that might never come to fruition after what Empire State Development says will be a 22-year build out of supertall office towers by Vornado. This project does nothing for transit efficiency. Instead of doing real economic development, this project merely turns our government into a real estate speculator.

Write or call the members of the Public Authorities Control Board today:

• Assemblywoman Amy Paulin: PaulinA@nyassembly.gov

• Senator Leroy Comrie: comrie@nysenate.gov

• Assemblyman Joseph M. Giglio: GiglioJ@nyassembly.gov 

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Empire Station Coalition is a group of concerned community organizations led by co-coordinators Sam Turvey of RethinkNYC and Lynn Ellsworth of Human-Scale NYC, who banded together in 2020 to fight the Penn Area Plan. ESC has worked tirelessly to push the Plan's many flaws to the forefront of public attention.

In this open letter to Governor Kathy Hochul, League President Jay DiLorenzo urges her to use her authority to halt Empire State Development’s planned approval of the Penn Station Area project on July 21. The League included the Penn Area Neighborhood on our Seven to Save list because that plan would demolish multiple city blocks, including over 40 historic buildings and structures, displacing thousands of residents and businesses. The negative environmental impact of this needless demolition would be a catastrophe. The plan itself raises numerous, serious questions that have yet to be answered. The lack of transparency is an insult to locals, and this kind of top-down governmental overreach poses a threat to communities across the state — not just our largest city.

Penn Station needs to be improved, but the current plan is not the answer. Join us in demanding that Governor Hochul put a stop to Empire State Development’s planned approval on July 21!

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July 15, 2022

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

Dear Governor Hochul,

The Preservation League of New York State respectfully asks that you use your authority as Governor to delay Empire State Development Corporation’s planned approval of the Penn Station area project, currently scheduled for July 21. 

The plan raises numerous, serious questions about its viability that have not been addressed, including how it will be financed, and what will happen if, especially given the weak demand for office space in a pandemic and post-pandemic world, the expected revenue does not materialize. Even if all those questions could be answered, the plan would still represent a colossal waste of resources, energy, irreplaceable architecture, and building materials.

The Empire State Development Corporation’s proposed Pennsylvania Station Civic and Land Use Project (the "Penn Area Plan") represents an unfortunate return to the Urban Renewal mindset of the mid-20th century, which promised that large-scale demolition would somehow lead to more viable and vibrant cities. Cities throughout the state and nation bear witness to the devastation caused by speculative demolition without a feasible rebuilding plan. Thousands of irreplaceable historic resources – of which the original Penn Station is an iconic example – were lost and wastefully discarded. Governor Hochul, we urge you to avoid repeating the mistakes of the past by halting this ill-conceived plan.

The current Penn Station is, without doubt, in need of improvement, and the League has no objection to upgrades that will improve the station’s functionality and aesthetics. What we strongly oppose is the plan to demolish multiple blocks of historic buildings in the vicinity of the station in the hope that private redevelopment will raise revenue for station improvements. We also oppose the opaque and top-down planning approach, which has utterly lacked the transparency and respect for local land-use procedures we thought the current administration championed.

All told, over 40 historic buildings and structures stand to be lost while displacing thousands of residents and businesses. The immediate impact on the people who live and work in this neighborhood would be devastating. The needless demolition is an environmental catastrophe. The negative environmental impact related to the embodied carbon that is wasted when buildings are demolished and put in a landfill, combined with the carbon output of major new construction projects, is in direct opposition to New York State’s proclaimed climate action goals. It is for these reasons that the Preservation League included the Penn Neighborhood on our current Seven to Save list of endangered historic places – underscoring the magnitude of the threat this community faces given the proposed Penn Area Plan. 

Penn Station needs to be improved, but the current Penn Area Plan is not the answer. The people of New York deserve better. Along with our New York City-based colleagues at the New York Landmarks Conservancy and the grassroots activists of the Empire Station Coalition, the League strongly urges Governor Hochul to put a stop to Empire State Development’s planned approval on July 21.

Sincerely,

Jay DiLorenzo
President, Preservation League of NYS

Click here for a PDF of this letter.