250 Water Street LPC CofA Application: New Tower on Site

January 4, 2021

Sarah Carroll, Chair

NYC Landmarks Preservation Commission

1 Centre Street, 9th Floor

New York, NY 10007

Re: 250 Water Street, South Street Seaport Historic District

Dear Chair Carroll:

The Lower East Side Preservation Initiative – LESPI – has followed the proposal for the new building at 250 Water Street with great interest. As the Commission’s decision on this proposal will have significant impact beyond the South Street Seaport Historic District, LESPI is compelled to testify in opposition. 

The South Street Seaport Historic District’s northern boundary is nearly adjacent to the historic Lower East Side, which includes the East Village / Lower East Side Historic District and is also experiencing considerable development pressure. We ask the Commission to consider the proposal for 250 Water Street only on the merits of its appropriateness for this low-scale waterfront historic district.

The bulk and massing of the proposed development would reduce the now expansive pedestrian experience to the experience of looking through a tunnel. As the building will be the first structure many pedestrians see when visiting or passing by the district, it should reinforce South Street Seaport’s special sense of place, rather than detract from it.  

By its shear height and bulk, the building would visually overwhelm the neighboring buildings within the district. The applicant’s desire to defer the expense of shadow studies until after design approval leaves these to imagination: their suggestion that there will be no significant impact on the historic district defies all logic.  The phrases offered in the proposal: “edge of the

historic district” and “low contextual podium” diminish the very concept of the historic district, and should not serve to soften the intent to build an out-of scale high-rise. 

If the Commission can consider a building that looms over the surrounding historic district to be appropriate, what will stop other applicants from making similar arguments for their out-of-scale proposals in other historic districts? The value of an offer of financial assistance to one not-for-profit organization, no matter how cherished, should not affect the Commission’s ruling on the merits of this application within the South Street Seaport Historic District. If approved, this proposal would set a terrible precedent on both counts.

To those who have mislabeled the defense of a designated historic district as the intent to preserve a parking lot, LESPI would suggest that appropriate development of this site is most welcome, and does not need to be as restrictive as one might imagine. Neither would LESPI be disinclined to support a transfer of air rights to a development just outside the district, where other development opportunities may be found. 

LESPI sees no valid argument for appropriateness, given the building’s size, and believes that green-lighting this particular proposal would set a terrible precedent for historic districts throughout the city. We therefore respectfully urge the Commissioners to deny this proposal. 


Richard Moses


Cc: Laura Sewell, Lower East Side Preservation Initiative