July 19, 2012
Office of the Deputy Mayor for Economic Development
Robert R. Kulikowski, PhD.
Assisitant to the Mayor
253 Broadway, 14th Floor
New York, NY 10007
Re: Seward Park Mixed-Use Redevelopment Project: Section 106 Review
Dear Dr. Kulikowski:
The Lower East Side Preservation Initiative – LESPI – has reviewed the Draft Environment Impact Statement for the Seward Park Mixed-Use Redevelopment Project.
As you know, there are several properties in and around the redevelopment site that have been identified as having architectural / historic significance that would be directly or indirectly impacted by the construction. Among these are the Essex Street Market, Fire Engine Company 17 at 185 Broome Street, St. Mary’s Roman Catholic Church, and The Dispensary Building. Additionally, the State and National Register Lower East Side Historic District and the potential (State and National Register Eligible) Clinton, Rivington, Stanton Street Historic District are within close proximity to the site.
We do not believe it is appropriate for state and federal funds to be used to demolish or significantly damage an historic site that is either listed or deemed eligible for listing in the State or National Register of Historic Places.
The Lower East Side is an area of immense historic significance to our city and country. This community has and continues to lose large numbers of historically and architecturally significant buildings at an alarmingly fast rate. Demolishing more of these buildings will further diminish this fragile historic neighborhood already pockmarked with insensitive development.
Several types of mitigation have been proposed. We strongly assert that mitigation for demolition typically does not come close to balancing the loss of the cultural / historical resource. Mitigations such as creating museum exhibits on a demolished building’s history within the new structure, and preserving a section of the building’s façade and building the new structure behind it (i.e. facadism) do not address historic preservation concerns or values.
The best way to minimize impacts on the area’s historic districts – either listed or considered eligible – is for the scale and materials of the new buildings to be sensitive to the surrounding historic sites. This does not mean that the new buildings should slavishly imitate the style of the historic buildings, or resort to apologetically bland generic designs. Conversely, it is most appropriate for the new design to be robustly modern, and to develop a dialogue with the historic buildings in the spirit of the robust architecture of the neighborhood’s historic structures.
Creative urban and architectural design can ensure that a new development takes its place comfortably on the Lower East Side, contributing to the area’s vital historic character and respectful of its rich architectural and historic resources.
LESPI is a not-for-profit organization dedicated to preserving the architectural, historical and cultural heritage of Manhattan’s East Village / Lower East Side. With historic resources falling prey to demolition and defacement on an almost daily basis, it is imperative that the city act now to save the historically intact areas of these locally and nationally important neighborhoods for current and future generations.
Please feel free to email me at Richard@LESPI-nyc.org or call at 347-827-1846. Thank you.
Richard D. Moses
Margaret Chin, NY City Council
Gigi Li, Manhattan Community Board 3