Testimony of the Real Estate Board of New York, Inc. on the Proposed Sullivan-Thompson Historic District

The Real Estate Board of New York (REBNY) is a trade association with over 17,000 members including owners, builders, residential and commercial brokers and managers, and other professionals active in the real estate industry in New York. We would like to submit our comments on the proposed Sullivan-Thompson Historic District.

The absence of a draft designation report before the public hearing makes it difficult to determine what criteria the Commission will consider when determining which buildings to include in the proposed historic district. However, using the surrounding SoHo Cast Iron and Charlton-King-Vandam Historic Districts as a basis, it is our judgment that the proposed Sullivan-Thompson Historic District lacks the obvious distinctiveness, both architecturally and historically, as a unique section of the city. While the vast majority of the buildings are old, the proposed Sullivan-Thompson Historic District is a collection of unremarkable tenement buildings, row houses, and retail store fronts that vary in size, style, and retention of historic/architectural features. This district simply does not merit designation. 

The Landmarks Preservation Commission (LPC) has preserved — somewhat questionably — tenement buildings in numerous districts.  The Upper West Side/Central Park West Historic District is one district where the inclusion of tenements on Amsterdam and Columbus Avenues is entirely out of character and diminishes the value of the district.  The East Village/Lower East and the South Village Historic Districts are two recent designations where tenement buildings are the dominant building type in the district and presumably one of the key elements in its designation. However, it should be noted that tenement buildings are a type of housing stock that has been deemed substandard for decades, and from a housing policy perspective, we question the preservation of so many tenement buildings.  More importantly, from a historic preservation perspective, the Commission has already designated this building type in a number of historic districts.  It appears to us that Sullivan-Thompson is less a distinct section but rather simply another section where tenement buildings remain.

The proposed district does contain a handful of unique and historic storefronts.  Since the storefront features are visible and presumably contributing to the character of the district, it is imperative that these property owners are given clear guidance about what features must remain unchanged and what can be changed to accommodate the needs of the business.  Furthermore, storefronts that do not contribute should be explicitly called out in the designation report as non-contributing and exempt from complying with onerous guidelines.  The clear description of significant features is particularly important for small stores that are frequently attracting small start-up business who lack the capital to embark on a lengthy design review process.

Finally, there are numerous buildings in the proposed Sullivan-Thompson Historic District whose inclusion in the district does not contribute to the suggested architectural and historical features of the proposed district and therefore should be excluded (see attached map).  We believe these buildings should be excluded because some are more modern buildings that do not reflect the period of architecture or development; some are significantly altered and retain little architectural and historic value; and all are non-contributing buildings located on the periphery of the district where the boundaries can easily be drawn to exclude them.

The attached map highlights thirty-five properties (shaded in grey) in five sections that we believe should be excluded, they are:

1. The northern portion of the district facing West Houston which contain vacant lots and non-contributing buildings (155 & 152 Thompson St, 129 & 109 West Houston St and 64 MacDougal St)

2. MacDougal St between Prince and West Houston which contain significantly altered buildings (64-34 MacDougal Street, and 202 & 208 Avenue of the Americas)

3. Portions on South Spring St between Avenue of the Americas and Sullivan St which lack cohesion (208-204 South Spring Street, and 84 Sullivan St)

4. Southern most portion contains several large billboards and feels more like SoHo or Tribeca than neighboring Charlton-King-Vandam, MacDougal-Sullivan Gardens and SoHo Cast-Iron Historic Districts (55 Sullivan St, 116-110 Avenue of the Americas, and 527-519 Broome St)

5. The east side of Thompson Street between Prince and Spring St which includes buildings with inconsistent building styles and materials (114-106, 98 & 90 Thomson St)

It is important to note that twenty-five of these properties are overbuilt so there is little risk of demolition, and of the remaining ten that are not overbuilt, four are vacant lots, and one was built in the mid-1980’s. The current Commission has wisely drawn boundaries around intrusions that do not belong in other historic districts. We ask that the Commission exercise that same judgement for the proposed Sullivan-Thompson Historic District. We urge the Commission to exclude the aforementioned buildings, but should the Commission designate them anyway, we ask that the designation report explicitly list these buildings as non-contributing, at minimum.

Again, we renew our call asking that the LPC prepare a draft designation report well before a public hearing so that property owners and the public can better understand the rationale for including particular buildings in a historic district.

Thank you for the opportunity to share our thoughts and concerns about this proposed designation.