March 1, 2011
PROPOSED RULES AMENDMENTS
In general, HDC finds the proposed changes to the rules for staff-level permits to be positive ones that will help ensure the integrity of landmarked buildings by setting forth clear standards of preservation practice that will allow applicants to receive permits more speedily when adhering to these standards. The standards enumerated in these amendments derive, in the main, from consistent Commissioner decisions and HDC commends the commission for proposing to institutionalize many of these standards as they have developed through practical application.
HDC is particularly pleased with the introduction of consideration of “cumulative change”, both in residential and commercial projects. In particular we are happy to see that properties with existing additions will no longer receive staff level permits for more additions and will instead go to a Public Hearing in front of the full Commission. This is an important step in controlling the incremental growth of historic structures. All too often, we have been hamstrung by the inability to comment on selective parts of the proposed work on a designated structure because of this discrepancy. The notion of “cumulative change” goes far to addressing that concern by treating a designated building as a whole, instead of in segments. This is a very welcome concept and we applaud LPC for introducing it into the agency rules.
HDC is also pleased to see that excavations are pointedly excluded from work eligible for expedited reviews. Even under ideal circumstances, excavation within an existing building is a tricky thing and taking the additional time to bring such a proposal to a public hearing can only be regarded as good safety practice. It is also good that rules are proposed to include wording to allow such sustainable technology as solar panels, when placed within certain parameters, at staff level.
With regard to the amendments to Section 2-15 regarding the insertion of windows on publicly visible side façades, HDC feels that they do not go far enough. Originally, the rule was established to ease the conversion and adaptive reuse of formerly-obsolete commercial and manufacturing buildings. This, of course, is a positive thing, but historically-residential structures, particularly rowhouses, should be held to a different standard and should not fall under this rule. Additional windows on these types of buildings can drastically change the nature of a façade or even the whole building if a side wall is transformed to resemble a primary façade. Often regularizing, as called for by the rules, with “a regular and consistent pattern” and windows matching the front façade if no historic windows are extant is not the answer. Alterations to a façade visible from the public way should go to a full public hearing so that the individual nature of the row is addressed. This would be consistent with the concept of “cumulative change” as proposed to be practiced in rear yards. Please note that our principal concern is with secondary façades that are visible from the public way. HDC finds the amended rules for new window openings in façades that are not publicly visible to be acceptable.
Rear yard additions to rowhouses are one of the most controversial issues in historic districts, and Section 2-16 addresses a number of residents’ worries. While the rule does not allow for anything taller or deeper than what is on the majority of other buildings in the block, there remains the concern of how to ensure that proper data is submitted to make that call. The modifier “legal” should also be included to ensure that the examples are grandfathered or commission-approved. The design and materials of the addition, not just its size and massing, should also be addressed. While Commissioners regularly approve and encourage what they call “creativity” on rear façades at Public Hearings and Meetings, staff-level approvals should be more conservative. Language should include references to keeping with the historic style and materials of the existing structure. Possibly a solid to void ratio, like what is proposed for new window openings, could be devised to prevent light boxes and loss of privacy that neighbors worry about. Finally, the phrase “minimally visible” remains a problematic one to many, both for rear yard and rooftop additions. Can a definition be devised? Is it the 18” that has been rumored? If so, this measurement should be included as a definition or in place of the phrase.
Section 2-20 on signage has some very good, clear rules like line 4 that specifies the projection allowable for sign panels and pin-mounted letters and line 9 that proscribes a maximum of one fixture per five linear feet of sign. Again, we are pleased with the notion of “cumulative change”, where the signage for the storefront is looked at in its entirety rather than segmented portions. This is how the building is experienced in reality and it should be considered in that view. HDC is a little concerned about line 5 which states “The height of a sign must be proportional to the storefront opening” and line 14 where the phrase “excessive” is used to determine the overall effect of existing and proposed signage. We ask that more detailed language be used in these lines so that they are less open to interpretation.
Finally, the new section 7-06 for the revocation of approvals is an important step in enforcing the decisions made by the Commission. HDC asks that in addition to “any incorrect or false statement or any misrepresentation in the documents submitted” the wording include “or material omission.” Sometimes the lack of information can be more misleading than anything incorrect or false.
While discussing this matter, it seems like a good time to reiterate the need for posting staff-level permits on line as is done with Certificates of Appropriateness. It is important for neighbors and others to know what has been approved so that they can either be comfortable in the fact that the work going on is legal or be able to report to the LPC any violations which might occur. In this way, the public can still play an important role in the preservation of our city’s landmarks.
LPC Docket Number: 116067
Manhattan, Block: 485, Lot: 12
80-82 Greene Street – SoHo-Cast Iron Historic District
A store and storehouse designed by Griffith Thomas and built in 1872-73. Application is to extend the fire escape.
While HDC does not object to this proposal as it appears to be necessary, we would ask that a softer color, perhaps a matching cream, be considered so that the extended fire escape does not stand out so much. We also would suggest repainting the sills on which the fire escapes will sit so that the cast iron is properly protected.
LPC Determination: Approved with modifications
LPC Docket Number: 111047
Manhattan, Block: 1416, Lot: 8
215 East 61st Street – Treadwell Farm Historic District
A rowhouse desinged by A. & S. Bussell and built in 1875 and later altered. Application is to construct a rear yard addition, replace windows and alter the façade.
The rowhouses of the Treadwell Farm Historic District were all altered in the early decades of the 20th century. These changes have created charming blocks of homes which are individually distinctive and yet still a cohesive group. With this in mind, unless a full restoration of 215 East 61st Street, including reconstruction of the stoop, is proposed, HDC asks that the various historic elements and design be retained here.
The divided light windows are a common feature in this district and were present at the time of the tax photo. Presumably these were added at the time that the stoop was removed as part of an overall redesign and renovation. Changing them back to one-over-one without doing other restorative work is a mix-and-match approach that does not accurately reflect the building’s history.
Shifting the parlor floor openings over seems like an awful lot of work for little return. While they would then align with the upper floor openings, those on the base would remain slightly off. Also this change would be a departure from the original configuration of the rowhouse.
HDC encourages the retention of the existing details, large and small, that add up to create a lovely, contextual rowhouse in the Treadwell Farm Historic District.
LPC Determination: Window replacements and facade alterations denied; rear yard addition approved