Public comments for: LPC Rules Amendment 2018

Comments

Comment:
I am opposed to these rule changes, because they will result in decreased transparency and reduce oversight by Community Boards. These boards need More oversight of real estate development in their neighborhoods, not less.
Agency: LPC
Comment:
I object to the rules changes because of the reasons cited by the Historic Districts Council: "The overall diminution of public review of projects; procedural incentives for the use of substitute and faux materials in restorative work; a broader allowance of more visible and larger additions to buildings; the characterization of some landmarked properties in historic districts as “building(s) for which the district was designated”; and a reorganization of work types that would not be appropriate given the variety of characters amid the nearly 150 historic districts."
Agency: LPC
Comment:
Please find attached a photo testimony for replacement in kind and the adverse effects alternative materials have on our landmark structures. I kindly request the Landmark Preservation Commission to consider this first hand account and ultimately revising the amended rules so that staff level employees can only approve replacement in kind. Additionally I implore the LPC to consider this testimony when faced with an applicant who is applying to replace with alternative materials or in the case where an applicant is applying "with no effect". These materials do adversely effect our prized landmark buildings.
Agency: LPC
Comment:
I would just like to quickly say that while I certainly believe in and support the mission of the LPC to maintain historic buildings in NYC, I also believe this mission must be balanced with the extreme need for new housing of all kinds. I therefore support any change to the rules that would reduce the difficulty and time required to navigate the LPC approval process, especially for smaller projects. This will have a big impact on the number of housing units built/renovated and that will, in the long term, be good for all residents of the city, especially those who are less well-off financially.
Agency: LPC
Comment:
New York Passive House Inc. (NYPH) is an organization of design, construction and associated professionals for the promotion and advocacy of a healthy, comfortable and energy efficient built environment through implementation of the international Passive House Standard. NYPH strongly urges the Landmarks Preservation Commission to implement the proposed revisions to the LPC Rules. Simplifying the approval process will preserve our historic landmarks, while contributing to New York City committed goal to reducing greenhouse gas reduction of 80% by 2050. Historic buildings and historic districts represent a long term carbon challenge and require increased attention to building enclosure construction and the installation of insulation, airtightness, thermal bridge free construction and high performance windows. NYPH strongly supports the proposed changes to improve energy efficiency and clean energy upgrades to historic landmarks, especially: 1. Increased staff-level authority for window replacements. NYC has already many high quality and high performance window options and executed landmark retrofits to demonstrate compliance. 2. We strongly support the proposed change to allow Staff-level approval for the highly efficient simulated double-hung windows used in passive house construction. 3. We endorse to adjustments to the visibility requirements for mechanical equipment which will facilitate high-performance HVAC equipment such as heat pump systems and fresh air energy recovery ventilation units. NYPH strongly urges the Landmarks Preservation Commission to implement the proposed Rules immediately. Improved energy efficiency is the most important measure to preserve our historic landmarks and make our historic buildings resilient and for the future. Sincerely, Andreas Benzing President, New York Passive House
Supporting Document:
Agency: LPC
Comment:
New York Passive House Inc. (NYPH) is an organization of design, construction and associated professionals for the promotion and advocacy of a healthy, comfortable and energy efficient built environment through implementation of the international Passive House Standard. NYPH strongly urges the Landmarks Preservation Commission to implement the proposed revisions to the LPC Rules. Simplifying the approval process will preserve our historic landmarks, while contributing to New York City committed goal to reducing greenhouse gas reduction of 80% by 2050. Historic buildings and historic districts represent a long term carbon challenge and require increased attention to building enclosure construction and the installation of insulation, airtightness, thermal bridge free construction and high performance windows. NYPH strongly supports the proposed changes to improve energy efficiency and clean energy upgrades to historic landmarks, especially: 1. Increased staff-level authority for window replacements. NYC has already many high quality and high performance window options and executed landmark retrofits to demonstrate compliance. 2. We strongly support the proposed change to allow Staff-level approval for the highly efficient simulated double-hung windows used in passive house construction. 3. We endorse to adjustments to the visibility requirements for mechanical equipment which will facilitate high-performance HVAC equipment such as heat pump systems and fresh air energy recovery ventilation units. NYPH strongly urges the Landmarks Preservation Commission to implement the proposed Rules immediately. Improved energy efficiency is the most important measure to preserve our historic landmarks and make our historic buildings resilient and for the future. Sincerely, Andreas Benzing President, New York Passive House
Supporting Document:
Agency: LPC
Comment:
COMMENTS FROM THE BUILDING OWNERS AND MANAGERS ASSOCIATION OF GREATER NEW YORK ON THE LANDMARKS PRESERVATION COMMISSION’S PROPOSED RULE’S AMENDMENTS The Building Owners and Managers Association of Greater New York (“BOMA/NY”) represents more than 750 owners, property managers, and building professionals who either own or manage 400 million square feet of commercial space in NYC, and it is an association within BOMA International, a federation of 90 US associations and 19 international affiliates that own and operate approximately 10.5 billion square feet of office space in the United States. BOMA/NY strongly supports the proposed rules amendments, as they make common sense changes to procedures that will simplify and speed up decision making on routine matters that are already accepted current practices. As such, these changes will reduce the burden on the Commission’s limited staff and resources, thereby allowing them to focus on more pressing matters. Given the Commission’s own predictions that its case load of applicants will only increase as more properties are designated, these practical and important amendments need to be finalized and put into place. We commend the Chair and the Commission for moving these proposals forward.
Supporting Document:
Agency: LPC
Comment:
Please see attached pdf for my comments on the Landmarks Commission Title 63 Rules proposal.
Supporting Document:
Agency: LPC
Comment:
The amended regulations allow a streamlined approvals process, relying on other agency approvals and pre-approved siting criteria to be an effective means to validate the appropriateness of PCS installation without the LPC review and approvals process. This helps to bring modern, free, and accessible communications to the general public in a timely manner. - GoldmanHarris LLC
Agency: LPC