Statement of the Historic Districts Council
Before the Landmarks Preservation Commission
January 20, 2004
Re: Proposed Rule Relating to Regulation of Public Pay Telephones
The Historic Districts Council is the advocate
for New York City’s designated historic districts and neighborhoods
meriting preservation. The Council is dedicated to upholding the
New York City Landmarks Law, and to furthering the preservation
ethic. HDC’s Public Review Committee has reviewed the proposed
rule now before the Commission.
The Historic Districts Council is pleased that
the Commission is addressing the problem of public pay telephones
and attempting to set standards for their appropriateness in historic
districts. However, in general, we believe that the rules before
the Commission today do not go far enough to protect New York’s
historic districts from the dominating presence of modern public
pay phones. Moreover, we fear that by allowing the telephones
to be easily approved at staff level, more and more pay phones
will appear in our historic districts, not because they are needed,
but to increase advertising revenue for the phone companies.
In the past five to ten years, New York City’s
sidewalks have been bombarded with a proliferation of public pay
telephones. Usage of these public pay phones is down, as cellular
phones become more common. However, ironically the number of public
pay phones has multiplied. While these phones do “provide
an important communication link for business, pleasure and public
health and safety,” their abundance is more closely linked
to the advertising they display. The statement that “These
public pay telephones have traditionally had a quiet presence
on the streetscape that allowed for their identification without
calling undue attention to themselves” is no longer true.
We therefore ask that the introduction to these proposed rules
acknowledge that today public pay telephones are a jarring presence
in our historic streetscapes and that their purpose, more often
than not, is as billboards, not as a public service.
Specific to the proposed rule before us today,
HDC has the following comments:
Section 2-21 (c)1-ii. If the
Commission hopes to have PPT Enclosures that are inconspicuous
and do not call undue attention to themselves, then a height allowance
of up to 90” (7’ 6”) seems excessive. A height
limit of 6’ to 6’ 6”for the enclosures would
adequately address the needs of privacy while reducing the telephone’s
impact on the streetscape.
Section 2-21 (c)1-iv. HDC assumes
that the term “landmark” refers to individual landmarks
and hopes that this is clarified in the revised rules. We commend
the Commission for forbidding public pay telephones in front of
individual landmarks. However we ask that this prohibition be
extended to scenic landmarks. As scenic landmarks are designated
for their landscape features, the presence of a public pay telephone
in front of these designated features is particularly damaging
to their integrity.
Section 2-21 (c)1-v. HDC asks that the language
of this section prohibit any and all cables, wires and lines from
being visible, not just power and telephone lines. In this era
of rapidly changing in technology, we fear that a telephone company
will argue that a newly-developed wire type can be visible because
it is not specifically forbidden under these rules.
Section 2-21 (c)1-vi. The permitted
colors outlined in this section brings to light the question as
to how this rule relates to the Commission’s other rules
and guidelines, particularly design guidelines. For instance,
in Jackson Heights, storefronts are not permitted to be dark brown.
Therefore, telephones in Jackson Heights must also not be brown.
HDC asks that this rule’s relationship to other Commission
policies be clarified in the document to ensure that this rule
does not supercede any previously approved rules.
Section 2-21 (c)1-vii. If the
Commission is to ensure that these phones do not have a dominant
presence in our historic districts’ streetscapes, internal
illumination of advertising must be limited. Moreover, we believe
that illuminating the name or logo of the telephone company is
unnecessary and only serves as additional advertising for the
company to the detriment of our historic neighborhoods.
Section 2-21 (c) 2. HDC understands
that some public pay telephones, such as those installed on the
interior of a building, may be eligible for a permit for minor
work or a certificate of no effect. However, we would like this
section clarified to guarantee that all public pay telephones
visible from a public thoroughfare that do not meet the standards
in these guidelines go before the Commission for a certificate
of appropriateness.
Lastly, HDC believes that there are several sections
not included in these rules that should be included. One such
section should address the issue of a minimum sidewalk width for
the placement of telephones. Commercial streets in historic districts
often have narrow sidewalks, which can be easily overwhelmed by
a public pay telephone intrusion. Examples are portions of Lexington
Avenue and the entire length of Madison Avenue in the Upper East
Side Historic District. Cluttered sidewalks throughout New York
City create a disservice to pedestrians. Moreover, in commercial
areas, they interfere with commercial activity, obstructing from
a person’s broad view storefronts and other establishments.
In our historic districts, public pay telephones produce the additional
problem of detracting from the neighborhood architecture. We ask
that the Commission develop standards in addition to those set
forth by the Department of Transportation and DOITT to ensure
that public pay telephones are not placed on narrow sidewalks.
A section addressing public pay telephone design
should also be included in these rules. We regret that the telephones
that these rules permit will be in essence no better than those
that have horribly encroached on New York’s non-designated
neighborhoods. In addition, the rules do not reflect the different
“special characters” New York City’s historic
districts exhibit. Telephones in the Madison Square North Historic
District should not look like those in Brooklyn Heights. The LPC
has the right to regulate design, and we hope that these regulations
will be revised to give the agency more purview over the telephone
design.
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