LESPI's Letter re landmarking 138 Second Avenue

October 28, 2015

Meenakshi Srinivasan, Chair
NYC Landmarks Preservation Commission
1 Centre Street, 9th Floor North
New York, NY 10007

re: Landmark Designation of 138 Second Avenue

Dear Chair Srinivasan:

I am writing to strongly support the designation of 138 Second Avenue in Manhattan's East Village / Lower East Side as an Individual Landmark.

In 1832, when this grand residential building was constructed, 138 Second Avenue was one of many such homes that once lined this part of Second Avenue. The building retains most of its Federal characteristics. The simple yet elegant design - including Flemish bond brickwork, and most notably its Gibbsian entrance surround - clearly show the building’s origins in this early period of the East Village’s development.

The 4th story addition, built in the late 19th century over the original 3-1/2 story design, physically embodies the neighborhood's transition from exclusive, wealthy enclave to German immigrant community. Significant to the history of both the building and the neighborhood, in 1874 the building was converted to The Association for Befriending Children and Young Girls, and then in 1916 became the headquarters for the League of Foreign-Born Citizens. During this period the entire Lower East Side - including Kleindeutschland - became the most important center for immigration in the country.

We respectfully ask that the Landmarks Preservation Commission vote to designate 138 Second Avenue as soon as possible. Without landmark protection this important building will almost certainly fall prey to the neighborhood’s intense development pressures. Thank you.


Richard D. Moses

cc: Hon. Rosie Mendez, NY City Council
Community Board 3 Manhattan


LESPI's Letter re Jarmulowsky CofA application

May 23, 2014

Robert B. Tierney, Chair
New York City Landmarks Preservation Commission
Municipal Building
1 Centre Street, 9th Floor, North
New York, NY 10007

Re: Jarmulowsky Bank Building Certificate of Appropriateness Application

Dear Mr. Tierney:

I would like to convey Lower East Side Preservation Initiative’s enthusiastic support for the proposed reconstruction of the corner cupola at the Jarmulowsky Bank Building at 54 Canal Street in Manhattan.

The cupola, with its temple-like colonnaded perimeter and ornate dome, was one of the most important original architectural features of the building. The cupola's placement at the corner of the building overlooking Canal and Allen Streets made the building a highly-visible and distinguished landmark and gave it an unmistakable presence which the cupola's removal greatly reduced, to the detriment of the building itself and to the important Lower East Side streetscape of which the building is a part.

We also ask the LPC to work with the applicant to relocate / reduce the size of rooftop additions as much as practicable to ensure that they do not detract from the building’s architecture.


Britton A. Baine
Chair, Architectural Design Review Committee

cc: Richard Moses, Lower East Side Preservation Initiative


LESPI's Letter re Proposed Rooftop Addition at 104 E 10th St

April 7, 2017

Meenakshi Srinivasan, Chair
New York City Landmarks Preservation Commission
1 Centre Street, 9th Floor
New York, NY 10007

re: Proposed Rooftop Addition at 104 East 10th Street

Dear Chair Srinivasan:

The Lower East Side Preservation Initiative is writing to oppose the proposed rooftop addition to 104 East 10th Street. This addition to the mostly-unaltered mid-19th-century Italianate house at 104 East 10th Street would be in the form of a three-level rooftop penthouse and mechanical equipment platform which would increase the height of the house by over 30% and would increase the above-ground bulk by fully one quarter.

The 1984 designation report for the St. Marks Historic District Extension, which is made up of just two buildings – No. 104 and its neighbor and oldest house on the block, No. 102 – emphasizes again and again that the buildings’ low heights are a defining feature of their historic significance. The report makes the specific point that the low height of No. 104 “creates an effective bridge between the small vernacular structure on its right and the taller, more recent Italianate buildings on its left,” and that “while distinct from their taller neighbors, [Nos. 104 and 102] offer a happy contrast.”

When Nos. 104 and 102 were designated in 1984, they were the last two houses at that end of the row, and thus created a well-defined “bookend” to the original St. Mark’s Historic District. Two years later, the very large Postmodern building at 31 Third Avenue went up, cheek-by-jowl with No. 102. Though the contemporary building is a structure of completely different architectural character and scale, No. 104 and its neighbor still mark an admirably-defined starting point to the St. Mark’s District by their resolutely different scale and architectural style: three stories compared with a high-rise, rectangular multi-paned windows compared with punched squares, and intricately-detailed ornament compared with pared-down Postmodernism.

The proposed addition seems to take a chunk of 31 Third Avenue and plop it right atop the roof of No. 104. With this gesture, the clearly-defined beginning to the historic district is permanently blurred, and the coherence of the St. Mark’s Extension – a district of just two buildings – becomes lost. “These buildings...set, and in subsequent modifications followed, the architectural and aesthetic standards for East 10th Street,” in the words of the 1984 designation report. “A harmonious uniformity was achieved in building types, materials, [and] scale....the relation of these buildings to each other and to the streetscape furthers the architectural coherence of St. Mark’s Historic District and adds to its significance.” If No. 104 begins to relate to buildings outside the district, the coherence born of scale which was found to be so important in the original designation will be lost. And with precedent set, the question is when, not whether, the rest of the houses along this street with its “compelling sense of unity” will acquire rooftop additions, and the scale and distinctive character of this district will be diluted and chipped away.

In light of the above, the Lower East Side Preservation Initiative respectfully urges the NYC Landmarks Preservation Commission to disapprove this out-of-scale addition which will significantly detract from the characteristics which give No. 104, and the St. Mark’s Historic District, their distinctive character and historic significance.


Britton A. Baine
Chair, Architectural Design Review Committee


LESPI's Letter re NYC Small Business Rent Tax

February 25, 2017

Hon. Melissa Mark-Viverito, Speaker
New York City Council
105 East 116th St
New York, NY 10029

By mail and email: This e-mail address is being protected from spambots. You need JavaScript enabled to view it

re: NY City Council Proposed Commercial Rent Tax Legislation

Dear Councilmember Mark-Viverito:

I am writing to express the Lower East Side Preservation Initiative’s support for new legislation being considered by the NYC Council to reduce taxes paid by “mom and pop” small retail establishments by exempting them from paying the Commercial Rent Tax.

Small independent businesses have traditionally comprised the very heart of Lower East Side neighborhoods, as well as other neighborhoods around the city. With ever increasing rents and the demolition of the city’s older, smaller buildings for replacement by much larger buildings with larger retail space, “mom and pops” are increasingly being displaced by large corporate chains and franchises. This affects the very character of our city, and undoubtedly affects democratic governing as national corporations and franchises are likely to be less rooted and involved in community affairs. Although we cannot comment on the specifics of the proposed legislation, we strongly believe that small independent businesses should be nurtured and protected.

As a preservation organization, we know that “mom and pops” typically fit well within the smaller commercial spaces available in historic buildings, such as those found in Manhattan’s Lower East Side. The human scale of historic buildings and small retail provide an excellent urban environment for those who live, work and visit historic neighborhoods.

We respectfully ask that City Council moves to pass this legislation at the earliest opportunity. Thank you for your consideration.


Richard D. Moses

cc: Hon. Margaret Chin, NY City Council This e-mail address is being protected from spambots. You need JavaScript enabled to view it
Hon. Rosie Mendez, NY City Council This e-mail address is being protected from spambots. You need JavaScript enabled to view it


LESPI's Letter re NYC Council Legislation Intro 775

September 3, 2015

The Honorable Rosie Mendez
NY City Council
237 1st Avenue, # 504
New York, NY 10003

Dear Councilmember Mendez:

I am writing on behalf of the Lower East Side Preservation Initiative to express our strong opposition to NY City Council Intro 775, which establishes strict time limits on NYC Landmarks Preservation Commission landmarking procedures.

Landmark designation requires formidable amounts of historical research and political and community outreach. Our city’s political environment is increasingly complicated, and corporate real estate interests are pushing back harder than ever against historic preservation using their immense wealth and influence. New Yorkers looking to save their historic buildings and streetscapes face greater challenges than ever, and the LPC must navigate these shoals with the limited resources of a small government agency.

As shown in the August 25 letter prepared by the Historic Districts Council et al (of which LESPI is a signator), many of the city’s most cherished historic districts would likely not have been designated under this legislation’s deadlines, including the St. Mark’s Historic District and Extension within the historic East Village / Lower East Side, as well as such “superstars” as Soho-Cast Iron and Greenwich Village Historic Districts. Going forward, this legislation will certainly deprive our communities with the new landmark buildings and districts residents want and deserve.

We support providing LPC with additional funding to expedite the process of historical research. And we are not opposed to establishing target time frames for designation, but any targets must be generous and flexible, to allow for districts with particularly challenging circumstances to move forward. Furthermore, there should not be any moratorium on reintroducing districts that do not pass, to allow for changing circumstances and political climates. Finally, any new legislation addressing the landmarking process should not only respond to the LPC’s input, but to the input of preservation and community advocacy groups, who understand the process of landmarking in NYC and the need for policies to facilitate rather than obstruct the process of protecting our future landmarks.

We respectfully urge the Council not to enact this legislation. Thank you,


Richard D. Moses

cc: The Hon. Melissa Mark-Viverito, NY City Council

[NOTE: identical letter sent to
Councilmember Margaret Chin]


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The Lower East Side Preservation Initiative is dedicated to preserving the historic streetscapes of the Lower East Side, including the East Village, Lower East Side below Houston Street, Bowery, Chinatown and Little Italy