November 19, 2020
Statement from Landmarks Illinois regarding the final Section 106 Memorandum of Agreement for the Obama Presidential Center
CHICAGO – On November 17, 2020, the Landmarks Illinois Board of Directors approved signing the Obama Presidential Center (OPC) Section 106 Memorandum of Agreement (MOA). In recognition of the significant public participation and local input in the process unlike we have seen before, Landmarks Illinois concurs with the MOA. Our signature, however, is accompanied by significant dissatisfaction with how regulators managed the Section 106 process and deep concerns about the precedent their actions may set.
One purpose of Section 106 of the National Historic Preservation Act is to ensure the public informs federal agencies on how the latter’s actions will affect historic places. Public participation in the OPC consultation process was extensive, comprised of residents living near Jackson Park, local organizations and institutions, citywide, statewide and national nonprofits and local, state and federal agencies. We saw public consultation meetings attended by an unprecedented number of people demonstrating interest in the OPC project and its impacts.
Through consultation, we heard from many people living in the Jackson Park area who see the OPC as a future park amenity and asset. At consultation meetings, we decided to do less speaking and more listening. It led us to deeply reflect on who should decide what is built in a community. This is a fundamental question facing the preservation field and a matter of equity, justice and self-determination. While some see the OPC’s use of 19.3 acres as a loss of public parkland, others see it as a long-overdue improvement and public benefit for Chicago’s South Side. Some speakers at public meetings said Jackson Park was not a place where they felt welcome, represented or safe and they see the OPC as an opportunity to make the park welcoming to the entire community. The OPC is also seen as a once-in-a-lifetime opportunity with economic development benefits for a community that has experienced few investments. We heard the compelling claim that 19.3 acres of a 552-acre park seems little to give for such an opportunity. To many, the OPC stands as a beacon of hope, aspiration and achievement and represents an evolution of this historic public park.
One might ask us what this has to do with the evaluation of the OPC’s effects on Jackson Park as a National Register-listed resource. While we recognize the national significance of the park and its landscape, we fundamentally believe that considering the OPC MOA goes beyond a regulatory issue – it is a matter of equity. We asked ourselves, “Who should decide the future of Jackson Park?” We believe the voices of nearby residents and organizations should have the greatest influence. Local residents see this as a living park and not a landscape frozen in amber. It can both adapt to the needs of people living there today and reference its historic significance. We heard the compelling point that adapting a small part of the park, which as a whole honors people of the past, should neither diminish this past nor jeopardize the opportunity to honor our nation’s first Black president. This doesn’t need to be all or nothing, it can be both/and. The preservation field should participate in the decision-making process in a way that supports accommodation and flexibility.
We believe signing the MOA is true to our organizational values for innovation, empowering people and improving lives. The preservation field needs to be more open in its perspectives and practices, including embracing other people’s definitions of cultural and historic resources. If we are to practice our values, we will align our organization with the local community.
We also recognize that our participation as a consulting party resulted in project improvement. Several of our requests for mitigation measures were addressed through the consultation process. We consistently requested that a supportive and affordable housing plan, and funding for it, be developed to prevent displacement that might result from the OPC’s construction. This concern was echoed by Woodlawn residents and their alderwoman and, while not included in the MOA, a neighborhood affordable housing ordinance was passed by the Chicago City Council in September 2020. While the east end of the Midway will have new recreational elements added, the Illinois State Historic Preservation Office (SHPO) and the public will have design input, which was one of our requests. The Statue of the Republic and the English Stone Comfort Station are also to be rehabilitated, and we had called for such investment in the park’s historic structures.
Our decision to sign the MOA is accompanied by grave concerns about precedent and a profound dissatisfaction with the consultation process as a whole. If it were not for our focus on equity, we would not concur with this MOA. This was a flawed regulatory process. Section 106 of the National Historic Preservation Act calls for exploring avoidance first, then minimization and finally mitigation after an “adverse effect” is determined upon the historic resource (Jackson Park). The city and federal agencies failed to explore avoidance or minimization whatsoever and moved right into mitigation, indicating that they had no real willingness to consider design alternatives raised by many through Section 106 consultation.
Several of our avoidance, minimization and mitigation requests were ignored. Requests made in our August 10, 2020, draft MOA comment letter called for more retention of Jackson Park’s Olmsted design and a greater commitment to preserve the park’s historic buildings and structures. The city failed to justify why the OPC could not be moved slightly to the south to retain the historic Women’s Garden and the symmetrical roadway system framing the east end of the Midway. Furthermore, the city did not provide a reasonable answer to why replacement parkland as part of the UPARR requirements could not be located in areas of Woodlawn that need park space, rather than activating the Midway’s passive east end, designed by Olmsted to be an open vista. We are unnecessarily losing all three of these historic features for which retention would have had minimal effect on the OPC.
We are concerned that the disingenuousness shown to the examination of avoidance and minimization, as well as the lack of consideration for reasonable solutions that would have prevented demolition of historic features, will set a precedent. We lodge here a significant complaint with the Responsible Governmental Units (RGUs) that failed to comply with Section 106 process. We expect better from federal agencies and understand why most of our partners are not signing the MOA on principle.
This was a difficult decision, but the right decision for Landmarks Illinois as we navigate our exploration of the future of preservation in Chicago, Illinois and beyond.