The "Black Hole" Landmarks Commission - 500 Ignored Requests

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As part of the Citizens Emergency Committee to Preserve Preservation's work to bring transparency to the Landmark Preservation Commission, we recently issued a Freedom of Information Act request, seeking to determine whether Request for Evaluation (RFE's) were being considered in a fair, timely, open manner.

After reviewing hundreds of RFE files in LPC's possession, we determined that approximately 500 RFE's were either a) received but never acted on or b) reviewed by LPC staff and rejected on grounds that have not been shared with the public. The map, above, graphically depicts the location of each "ignored" RFE that was found in LPC's files. When possible, we have added a photo of the site and any information that was available.

This information became the basis of a recent New York Times editorial, in which LPC was called "a bureaucratic black hole, the place where requests for evaluation — the formal nominations of buildings or districts to be landmarked — go to get filed and forgotten." The full editorial is available here.

If you know of any RFE sites which have not been included in this map, or if you have photos or information that has not been included, please leave a comment, below, or email us at citizens@savelpc.org. You can click on the map above to enlarge it and make it searchable.

So, how did we obtain this information? Read the details below:
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A Lesson in Civics

This is how CECPP volunteers put together the comprehensive list of over-age RFEs (Request for Evaluation) for proposed landmark sites that have never been reviewed or acted on by the full Landmarks Preservation Commission.

1. CECPP sent a Freedom of Information Act request letter to the Landmarks Preservation Commission for inspection and copying of all RFEs more than five years old not submitted for full Commission review.

2. After approximately three months we were told by the LPC's legal counsel that the files were ready for inspection at the Municipal Building.

A group of five volunteers went to a conference room at the LPC, where boxes of RFE files were made available. The boxes were assigned to individual volunteers who made handwritten lists of every RFE, noting the address, date of RFE submission, and name of proposer.

3. Where there was information of importance on papers in the file, the volunteers marked them with post-it notes for copying -- these usually included the RFE, detailed letters from the proposer (especially if a public official), and any rejection of the RFE at the staff level.

4. After review was completed, volunteers requested (and paid for) copies of the marked documents. From these we selected the representative group of RFEs for our first mandamus action seeking a court order to compel presentation to the full LPC for decision at a public meeting.

5. After reviewing the initial group of RFE files, a second FOIA request was submitted covering RFEs from two to five years old. The inspection and copying process was repeated.

6. All of this information was then entered on a spreadsheet by two very capable student interns. This resulted in a solid database of all RFEs more than two years old never acted on by the full Commission -- a total of several hundred.

Historic Districts Council Executive Director Simeon Bankoff helped refine the list by identifying some RFE’s that were missing from the LPC files, had been acted on, or had been demolished while in limbo. HDC is working on creating a citywide database of submitted RFE’s.

This volunteer work so far has produced: one lawsuit; one NYTimes editorial; contacts with various public officials who submitted RFEs; preparation of a digital map; initiation of a public education program; and preparation for additional court litigation, if required. Our goal is to make the designation process at the Landmarks Preservation Commission "transparent," and have the Commission and its staff act responsibly and in timely fashion to carry out their responsibilities to the citizens of New York.