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NY DAILY NEWS READERS SOUND OFF ON DOWNTOWN DEVELOPMENT 

    MAS testified before the Landmarks Preservation Commission and the Department of City Planning on January 5 and 11, respectively, urging the agencies to reject the latest proposal for 250 Water Street. In addition to concerns about appropriateness within the historic district in terms of design and scale, MAS has fundamental problems with the proposed development from a policy perspective, particularly regarding the transfer of City-owned development rights upon which the project depends.  MAS recognizes the need to develop the project site, but the principles that have been embodied in the City's zoning policy action for more than 40 years must be respected. The current proposal at 250 Water Street has the potential to drastically change the unique historic and urban design character of the area.  

NY DAILY NEWS READERS SOUND OFF ON DOWNTOWN DEVELOPMENT 

Jeffrey A. Kroessler, president, The City Club of New York

    We were disappointed to read your knee-jerk editorial (“Keep building,” Dec. 26) supporting the inappropriate, out-of-scale, and quite likely illegal 470-foot towers proposed by the Howard Hughes Corporation for the South Street Seaport Historic District. The design has nothing to do with the area’s historic architecture; there is more to appropriateness than a brick facade.     The site at 250 Water St. was included within the boundaries of the historic district designated in 1977. It was vacant even then, which meant that the Landmarks Preservation Commission intended to regulate whatever new construction was proposed. Second, the lot was rezoned in 2003 specifically to prevent the out-of-scale development now proposed. Clearly, the city intended to limit height and bulk there. Howard Hughes is requesting approval from the LPC for a building that cannot be built without a zoning variance, which has not been granted.     Finally, this proposal calls for the unprecedented transfer of development rights from within the historic district to another site in the district. The legality of this maneuver is doubtful.As tempting as a $50 million donation to the South Street Seaport Museum may be, it is, alas, irrelevant to the question before the LPC. Would that the city had generously supported this worthy museum instead of starving it. And would that the city listened to its citizens rather than serving special interests.  Jeffrey A. Kroessler, president, The City Club of New YorkReaders sound off on downtown development, Dawn Wells and cop accountability - New York Daily News (nydailynews.com) 

 Thank you for the opportunity to testify regarding Howard Hughes Corporation (HHC)’s proposal at 250 Water Street and 89 South Street. As an elected representative of the South Street Seaport, I am writing to express my concern in awarding a Certificate of Appropriateness to this project that lies within the Historic District. 

    The South Street Seaport is foundational in the narrative of New York City and its historic district allows residents and visitors alike to experience this rich heritage. The South Street Seaport serves as a unique record of our collective history, from our nation’s earliest beginnings to the trade and commerce that grew our city and country into what they are today. To be clear, the current use of space at 250 Water Street as a parking lot does not advance the goals or narrative of this historic district and has not since its original designation in 1977. I welcome development plans that respect the historical appropriateness, scale and character surroundings of this important part of New York City’s evolution. 

    The proposed development for 250 Water Street would allow for two 470-ft towers, whose extensive size and scope would be more than triple the height limit permitted within the hard-fought existing zoning regulations, thereby rendering this proposal completely out of context for this unique district. I appreciate that as part of its proposal for these high-rise buildings, HHC would provide substantial funding to the South Street Seaport Museum at 89 South Street.

    I am a staunch supporters of the South Street Seaport Museum and am committed to securing the long-term health and prosperity of this vital institution that connects our modern city with its historical maritime beginnings, and that has played an instrumental role in preserving that history for future generations. I join with Community Board 1 and local residents in encouraging the City to explore all potential solutions that assist with funding the museum. However, Certificates of Appropriateness must be based on preservation of historic character and appropriateness, not for the financial benefit of individual organizations.

    I therefore urge the Landmarks Planning Commission to preserve the integrity of this Historic District by centering its decision on the appropriateness and historic merits of the project. I appreciate your consideration of my remarks.

 Assemblymember Niou represents the 65th Assembly District which includes Battery Park City, Chinatown, the Financial District, the Lower East Side, and the South Street Seaport. 

    My name is Yuh-Line Niou, the New York State Assemblymember representing Lower Manhattan, including the South Street Seaport Historic District. Thank you for the opportunity to testify before the Landmarks Preservation Commission regarding the proposed construction on the 250 Water Street parking lot. 

    The South Street Seaport Historic District is one of the most unique and distinct areas in my district. This roughly 11-block community is filled with small-scale brick buildings which date back to the 18th century and are typically no taller than 4-5 stories in height. The district includes some of the oldest architecture, and has the largest concentration of early 19th Century commercial buildings in New York City. As a designated historic district, the South Street Seaport offers a glimpse of the past and serves as a rare connection to the maritime history of New York and the United States. 

    In recognition of its rich history and unique nature of the South Street Seaport Historic District, Manhattan Community Board 1, elected officials, and a number of community groups and local developers united to rezone the area to C6-2A and preserve this precious gem of the city. This zoning type acknowledged the historic district’s distinctive character and implemented a variety of restrictions, including building heights no higher than 120 feet and floor area ratios. Yet the application proposes the construction of two towers, each standing at 470 feet high. This application blatantly disregards and disrespects the hard fought zoning guidelines that were secured to prevent situations of inappropriate and out-of-character construction. A number of developers have been able to build within the historic district while adhering to the restrictions set forth by our community. The developer, who previously presented four other building proposals with outrageous heights ranging from 570 to 990 feet, has made clear that they never intended to build within the scale of the Historic District. It is crucial that the LPC remains consistent with the disapproval of previous applications with similar inappropriate, out-of-scale aspects. 

    Approval of this application will be an out-of-character and a significant contrast to the existing infrastructure and aesthetics of the historic district. This application proposes a transfer of 445,000 zoning square foot (zsf) of unused development rights to the site, even though elected officials, Manhattan Community Board 1, community coalitions, and other stakeholders have repeatedly reiterated that development rights zoning transfer mechanism was intended to transfer unused development rights outside of the historic district in an effort to preserve the low-scale layout and character of the area. Allowing for such transfer of air rights renders the establishment of the area as a historic district worthless. The area has always remained as a low-rise brownstone district. The LPC should be making an effort to preserve the historic district which is on the National Trust for Historic Preservation’s List of America’s Most Endangered Places and approve applications that remain aligned with the historic district’s unique character and building heights. 

    I stand strong with our community and urge the Landmarks Preservation Commission to reject this application. I have been against this project from the very beginning and I echo the concerns and issues that have been highlighted by our local Manhattan Community Board 1 and other community stakeholders in its recent resolution as well as testimonies submitted by the Seaport Coalition, other community groups and our residents. It is the will of our community to preserve the historic district and, while the community is open to repurposing the parking lot, it is certainly not within the vision of our residents to have two megatowers soar over our neighborhood.
    Time and again, applications to build beyond the height limit of 120 feet have been rejected and I cannot stress enough that the same should hold true for the application before us. Thank you for your consideration. 

New York State Assemblymember Yuh-Line Niou