Advisory Council on Historic Preservation says ‘adverse effects’ report lacks sufficient detail

Rendering of Obama Presidential Center (Courtesy of Obama Foundation)

Staff writer

The draft report finding “adverse effects” on the historic integrity of Jackson Park and the Midway Plaisance under existing plans for the Obama Presidential Center’s (OPC) establishment went into insufficient detail to consider amelioration options, said the Advisory Council on Historic Preservation (ACHP), which oversees federal historic preservation review processes.

“The ACHP is concerned that not enough detail is provided to properly characterize the nature and intensity of the adverse effects to the cultural landscapes of Jackson Park and Midway Plaisance in a way that will enable informed consideration of avoidance, minimization or mitigation measures,” wrote Jaime Loichinger, assistant director of the ACHP Office of Federal Agency Programs, to Federal Highway Administration (FHWA) division administrator Arlene K. Kocher.

The Aug.22 letter outlines several issues that the FHWA and National Park Service, which are conducting the reviews in consultation with the city, ought to address in the final report.

The draft report “does not articulate how the overall undertaking is altering or diminishing the integrity of the character-defining landscape characteristics” like spatial organization, land use, circulation, vegetation and structures, Loichinger wrote. The ACHP urges that the effects analysis “summarize how the landscape characteristics and the overall cultural landscapes will be altered based on the types of effects (physical, visual, traffic and noise).”

The ACHP also noted that the effects analysis is unclear as to whether the OPC-related constructions will result in Jackson Park and the Midway no longer being eligible for listing on the National Register of Historic Places (NRHP) — though it noted that the Jackson Park archaeological sites are not eligible for the NRHP, a fact the ACHP wants included.

The ACHP recommends that the reviewers “include information and data explaining if the surrounding historic residential neighborhoods will experience traffic changes due to the road closures and changes” as well as “if these changes will affect historic properties” and neighborhoods around Jackson Park. They noted consulting parties requested “viewshed analysis from a higher perspective to ensure all visual elements could be thoroughly assessed” and requested its inclusion.

As Washington Park is connected to Jackson Park by the Midway, the ACHP found it would be “beneficial to understand if the undertaking could indirectly or cumulatively affect” it, especially in the form of the number of visitors and pedestrian and bicycle circulation.

The ACHP also questioned how the city designated the eastern end of the Midway Plaisance as the site of federal investment under terms of the Urban Park and Recreation Recovery (UPARR) Act, which gave a federal grant to Jackson Park in 1980; the city has been in discussions with the Midway Plaisance Advisory Council about the designation for the past year.

Effects on nearby historic properties should be considered “and what avoidance measures were considered as part of the selection process.” The Section 106 agreement should include a design review process including consulting parties and design criteria for the UPARR investment once the final design is chosen.

“The ACHP urges FHWA to clarify the next steps it intends to carry out in this Section 106 review and provide sufficient notice and time for consulting parties to review reports prior to consultation meetings,” Loichinger wrote, adding that the effects report should be completed “shortly after Aug. 30.”