August 14, 2025
Ms. Julie Freeman
Associate Director
NYC Office of Management & Budget
255 Greenwich Street, 8th Floor
New York, NY 10007
Via email: freemanj[at] omb.nyc.gov
Re: LESPI Comments on Draft Second Amendment to the ESCR Programatic Agreement
Dear Ms. Freeman:
Lower East Side Preservation Initiative — LESPI — has reviewed the draft Second Amendment to Programmatic Agreement, which stipulates the demolition of the State and National Register eligible former Marine Engine Co. 66 Fireboat House and proposes mitigation measures.
As previously stated, LESPI has had serious questions about the structural engineering assessment that led up to this amendment. Based on the documentation we were provided, our team of professional architects and engineers did not find the demolition of the Fireboat House to be warranted due to structural deterioration. LESPI’s letters to your office dated December 23, 2024 and July 2, 2024 outlined these findings, recommended that our team of engineers be provided access to the site to review the conditions first hand, and questioned the City’s rejection of potential alternatives to demolition. Our position has not changed since.
However, given the City’s seemingly intransigent position on demolition, we recommend the following mitigation measures.
A. Photographic documentation: we did not find that the HABS photographs we received of the East River Park’s Tennis Center Comfort Station adequately documented that building. For the Fireboat House, we strongly recommend that documentation include rectified photography along with photos taken from vantage points showing oblique and detail views. Rectified photography will produce perspective-corrected images from which measurements can be taken; this would allow a much fuller understanding of this historic structure than standard photographs alone. It is also highly cost effective. Additionally, photographic views from the East River, where the building had once been accessed by fireboats, should be included in the documentation.
B. Measured drawings: the draft amendment calls for attempting to locate existing measured drawings of the building. We have serious doubts this will be successful. If not, the City should commission HABS measured drawings or laser scanning of the structure to accurately document the Fireboat House for posterity.
C. A historic narrative on the building’s history: we are pleased to see that this mitigation measure is included in the draft amendment. We request that, along with the SHPO, LESPI also be consulted on the content, design and placement of the display within the Park.
Please feel free to call me at 917-405-6224 or email me at richard@LESPI-nyc.org with any questions or to discuss further. Thank you.
Sincerely,
Richard Moses
President
Cc: NY City Councilmember Christopher Marte
Olivia Brazee, NY State Office of Parks, Recreation & Hist. Preservation
Andrea Gordillo, Manhattan Community Board 3
Susan Stetzer, Manhattan Community Board 3
