August 2017
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MAS Preservation Committee Write to LPC Chair Over St. Vincents

Dear Chairman Tierney:

We write to express the Municipal Art Society’s concern about the application to demolish historic buildings in the Greenwich Village Historic District for the redevelopment of St. Vincent’s Hospital. The overall redevelopment project was presented to the MAS preservation committee; in its analysis, the committee focused on the critical initial question – the validity of the proposed demolition.

As far as we know, the Landmarks Preservation Commission, in its 43 years of watching over our city’s heritage, has not permitted the demolition of a building that contributes to the historic district under a Certificate of Appropriateness and we see no reason for the Commission to do so now. We believe that, if the Commission were to approve such demolition, it would undoubtedly establish a dangerous precedent. Such an action would make it significantly more difficult for the Commission to deny future proposals to demolish designated buildings.

There is a two-step process by which the Commission ought to review St. Vincent’s application. The first step is to determine whether it is appropriate to the historic district to demolish each individual building. Only if the proposed demolition were found to be appropriate would the Commission then determine whether the design of the proposed replacement building is appropriate to the Greenwich Village Historic District.

Determining appropriateness to demolish will depend upon a determination of whether each building contributes to the “special character or special historical or aesthetic interest or value” of the district. The Greenwich Village Historic District Designation Report does not clearly attribute contributing or non-contributing status, but we believe that a significant number of the buildings do contribute to the district.

If the demolition were found to be inappropriate, then the applicant could proceed to the second step of applying for a hardship determination. The hardship proceeding would allow the Commission to examine whether St. Vincent’s is able to fulfill its charitable mission in these buildings. If they are unable to fulfill their mission, it is possible that the Commission could approve demolition under the hardship proceedings.

It is important that the consideration of mission only be considered in the hardship proceedings, and not as part of the appropriateness determination. That is challenging because, in this application, the Commission is being asked to weigh two public goods – the need for St. Vincent’s Hospital to expand and modernize its facilities and the legally recognized public benefit of safeguarding historic buildings. However, the Landmarks Law, which mandates the protection of New York City’s landmarks, does not allow the Commission to take into consideration any competing public benefit, like a hospital. Doing so is in fact a violation of the Landmarks Law.

We believe it is possible to provide a new hospital complex and to simultaneously respect the character of the historic district. Following the established sequential process outlined above is critical to maintaining the integrity of the Landmarks Law and avoids establishing a precedent for the demolition of buildings that contribute to a historic district. We look forward to testifying at a public hearing to the Commission on the MAS’s findings on the appropriateness of demolition of each building.

Sincerely,

Charles A. Platt and Judith Saltzman
Co-Chairs of MAS, Preservation Committee

cc: The Honorable Michael R. Bloomberg, Mayor, City of New York
The Honorable Christine C. Quinn, City Council Speaker
The Honorable Scott M. Stringer, Manhattan Borough President
The Honorable Thomas K. Duane, State Senator
The Honorable Jerrold L. Nadler, Congressmember
The Honorable Deborah J. Glick, Assemblymember
The Honorable Richard N. Gottfried, Assemblymember
Shelly Friedman, Friedman and Gotbaum
Andrew Berman, Greenwich Village Society for Historic Preservation
Brad Hoylman, Community Board 2
Simeon Bankoff, Historic Districts Council
Peg Breen, New York Landmarks Conservancy
Judy Stanton, Brooklyn Heights Association
Nina Rappaport, DOCOMOMO US/New York Tri-State
Seri Worden, Friends of the Upper East Side Historic Districts