To the Editor:
A few thoughts on the proposed Memorandum of Agreement for the proposed Obama Presidential Center in Jackson Park/
1. The proposed Memorandum of Agreement makes no provision for the avoidance or minimization of any of the adverse effects of the construction of the Obama Presidential Center (OPC) and the projects that the City of Chicago has chosen to link to the construction of the OPC, including (a) the closure of portions of the South Midway Plaisance, (b) the shutdown of Cornell Drive and related changes to Lake Shore Drive, and (c) the designation of the eastern end of the Midway as an Urban Park and Recreation Recovery Act (UPARR) replacement site. This contravenes Section 106 and related provisions in the Code of Federal Regulations, at 36 C.F.R. §§800.1, et seq.
2. The mitigation provisions of the proposed Memorandum of Agreement are a sham, consisting of a memorialization of the destruction caused by the adverse effects of these projects.
3. The proposed shutdown of Cornell Drive and related changes to Lake Shore Drive and Stony Island Avenue, at a cost of $175 million (based on current estimates which likely will be exceeded), will destroy the Olmsted traffic circulation design for Jackson Park.
The Olmsted traffic circulation design is used by thousands every day. The proposed changes will cause unnecessary inconvenience and congestion. The safety improvements touted to justify these changes can be obtained without destroying the Olmsted design, at a fraction of the proposed cost.
Earlier this year, Mayor Lightfoot and Senator Durbin called on FEMA to declare a lakefront emergency for Chicago and Cook County. In light of the threat posed by rising lake levels, the decision to divert traffic from Cornell Drive to Lake Shore Drive makes no sense.
Also, the State of Illinois and the City of Chicago are burdened with debt and rising taxes, and this situation has been exacerbated by the economic impact of the COVID-19 pandemic. Maintaining the Olmsted traffic circulation design would help maintain the aesthetic integrity of Jackson Park, while minimizing inconvenience to the public and reducing proposed public expenditures.
4. The City’s proposed use of the Midway as a UPARR replacement site would not add parkland, when the opportunities to add parkland to underserved areas in the vicinity abound. In light of the myriad vacant lots owned by the City in, for instance, Woodlawn, it is amazing that only two other UPARR replacement sites supposedly were considered within 1 mile from Jackson Park.
5. The City claims that it resolved the adverse effects identified in the Assessment of Effects. However, this claim is baseless, because the City’s purported resolution of adverse effects took place before the Assessment of Effects was developed.
6. The City’s claim also violates 36 C.F.R. §800.1(c), which authorizes “nondestructive project planning activities before completing compliance with section 106, provided that such actions do not restrict the subsequent consideration of alternatives to avoid, minimize or mitigate the undertaking’s adverse effects on historic properties.” (Emphasis supplied.)
7. No federal funds or approvals should be provided for these projects, based on the City’s failure to make any effort to avoid or minimize adverse effects.
8. The proposed Memorandum of Agreement should be withdrawn by the Federal Highway Administration (FHWA), and the FHWA should seek ways to “avoid, minimize or mitigate” the adverse effects that have been identified.
9. The proposed Memorandum of Agreement should not be signed by the any of the consulting parties, including but not limited to the Illinois State Preservation Officer and the Advisory Council on Historic Preservation.