Met with both strong support and staunch opposition, a Manhattan church’s hardship application would allow the landmarked building to be demolished. On June 14, 2022, the Landmark Preservation Commission held a public hearing to discuss the future of Individual Landmark West Park Presbyterian Church, located on 165 86th Street in the Upper West Side of Manhattan. The West Park Administrative Commission has applied for a Certificate of Appropriateness to demolish the church building on the grounds of hardship.
The church building, notable for its bright red sandstone and large square tower, was designed in the Romanesque-Revival style and completed in 1890. West Park has owned the building for its entire life and is solely responsible for its upkeep. In the 1970s and 1980s, West Park was known for supporting anti-war movements and fighting for the LGBTQ+ community during the AIDS crisis.
However, the church’s once-vibrant congregation has dwindled to just a dozen current members, and West Park now relies heavily on funding from the Presbytery of NYC. The building’s sandstone façade has deteriorated over time, and scaffolding has been in place to protect pedestrians since 2000. Despite outspoken concern from West Park representatives over the condition of the building, the church was landmarked on January 12, 2010. Currently, the Department of Buildings has over 60 open violations on the building, and recent violations would cost West Park tens of thousands in repairs.
The church claims to have exhausted all its financial resources in maintaining the building, and the Presbytery of NYC established the West Park Administrative Commission to assist with the sale of the building. West Park has now entered into a Purchase and Sale Agreement with developer Alchemy Properties, who intends to demolish the landmarked building. If Landmarks approves West Park’s application, Alchemy will replace the current building with a mixed-use development anchored by a 10,000 sq. ft. community space retained by the Church.
Following the contract with Alchemy, West Park applied for a hardship exception to their landmark status pursuant to the City’s Landmarks Law. To receive a hardship determination, applicants have to meet four statutory requirements. First, the property owner must enter into a legitimate sales agreement contingent on demolition approval from Landmarks. Second, the property cannot be capable of earning a reasonable return. Third, improvements alone must also be insufficient to make the building fulfill its intended purpose, such as church ministry here. Fourth, prospective purchasers must have a good-faith plan to construct new property immediately after the demolition.
At the public hearing, supporters of the hardship application argued that West Park satisfies all the statutory requirements. Alchemy president Kenneth Horn explained that the development company originally sought to repair the existing building, but determined after several months that it was impossible to salvage. Representatives from West Park further testified that because the Presbytery of NYC has limited resources, the church cannot earn a reasonable return. Members of the congregation and Presbytery, such Pastor Sadie Walters, also spoke in support of de-landmarking, citing the possibilities the Church could achieve with a new community space.
On the other hand, several opponents testified that Landmarks should deny West Park’s hardship application, namely the neighborhood’s Community Board and City Councilmember. Manhattan Community Board 7 voted 24-13 to deny the application, with seven members abstaining. The Board felt that despite the Alchemy sales contract, there were possible alternatives to demolition and the Church failed to meet the burden of proof required under the Landmarks Law. Councilmember Gale Brewer echoed the Community Board’s sentiment that demolition would be a tremendous loss not justified by the statute, arguing that the inside of the building is still used for its intended purpose. Detractors also strongly disagreed with the calculations in the hardship application, with several members of the public testifying that West Park could realistically make repairs or accept other counteroffers to buy the building. One of the offers was from The Center at West Park, a non-profit community performing arts center who is a current tenant of the church.
The Commissioners themselves did not discuss the hardship application as public testimony lasted over four hours. The application will be voted on at a later meeting.
By: Cassidy Strong (Cassidy is a CityLaw intern and a New York Law School student, Class of 2024.)
LPC: West Park Presbyterian Church, 165 West 86th Street, Manhattan (LP- 22-09135) (June 14, 2022).
Update: The title has been changed to correctly reflect the nature of the application.