Re: New Policy Regarding Submission of Public Comments for Commission Public Hearings and Meetings

April 4, 2017

Hon. Meenakshi Srinivasan, Chair
New York City Landmarks Preservation Commission One Centre Street, 9th Floor
New York, NY 10007

Re: New Policy Regarding Submission of Public Comments for Commission Public Hearings and Meetings

Dear Chair Srinivasan,

We write in response to an email sent by the agency on Friday, March 31, 2017 regarding the new policy for submission of testimony to the Landmarks Preservation Commission.

According to the email, from now on all testimony for public hearings and meetings should be submitted by 1:00pm on the Monday prior to the Commission’s Tuesday meeting in order that the testimony may be distributed to the members of the Commission.

While we understand the need for sufficient lead time to ensure the distribution of such materials to Commissioners, it must be noted that the presentation materials are usually not available on the LPC website until after business hours on the Friday prior to the hearing/meeting. This then leaves only four business hours between the time the materials become available and the deadline for submitting comments. This is entirely untenable for the general public, and certainly for organizations like ours.

If this policy remains in effect under these conditions, it would have the effect of making it nearly impossible for the public to submit comments in time for consideration, thus offering this possibility of public input in name only, but not in practice.

Case in point: the presentation materials for the April 4th public meeting directly following this announcement were not available during business hours until the morning of April 3rd. The deadline for submitting comments was 1pm that day – a mere four hours later. As we are sure you would agree, this is not a reasonable amount of time for a review of materials and to draft a response.

If this policy mandating a 1pm deadline the day before a public hearing or meeting for submitting public comments is to be maintained, we urge that the Commission make the presentation materials available electronically no later than 5pm the Thursday before. This

would allow a full business day and a half for the public to review materials and submit written comments to the Commission, which is hardly an unreasonable amount of time to expect.

We appreciate your attention to this very important matter.

April 4, 2017