Maxwell Street Historic Preservation Coalition
P.O. Box 6435
Evanston, IL 60204
July 21, 2000
Ms. Carol D. Shull
Keeper of the National Register of Historic Places
National Park Service
Department of the Interior
1849 C Street, NW
Washington, DC 20240
Attn: Ms. Beth Boland
Dear Ms. Boland:
I am writing in response to Mr. William Wheeler's letter to you, dated July 13, 2000, regarding our National Register nomination for the Maxwell Street Historic District. Obviously, we disagree with Mr. Wheeler's conclusions and maintain that the proposed district does retain sufficient integrity to be designated as a historic district.
In his letter, Mr. Wheeler makes much of a 1994 application that covered a similar geographic area. He states that he began his evaluation by reviewing his 1994 opinion and goes on to make numerous comparisons between the two applications. This is unfortunate, because the 1994 application is irrelevant to the nomination before you. We do not, for example, agree that the sole substantial difference between them is the addition of the blues music theme, but we will not argue this point or others because such comparisons serve no purpose. Mr. Wheeler's own staff ruled that the current nomination is sufficiently different to be considered. Therefore, it can stand on its own and should be evaluated solely on its own merits. I urge you to disregard all references to the 1994 application.
As Mr. Wheeler correctly notes, on June 9, 2000, the Illinois Historic Sites Advisory Council (IHSAC) unanimously disagreed with Illinois Historic Preservation Agency (IHPA) staff and endorsed our nomination (11-0, with 3 absent). All of the IHSAC members in attendance saw our slide presentation and an opposing presentation by the University of Illinois at Chicago (UIC). Several members visited the proposed district. Many spoke after the vote about why they endorsed the nomination despite the neighborhood's current dilapidated appearance. Their reasoning was that the tremendous historical significance of the neighborhood offsets any deficiencies reflected in its current condition.
As these historic preservation professionals understand, it is a rare historic district, especially within an urban area, that has not experienced some change since its period of significance. It is because of this fact that institutions like the National Register and laws like the Historic Preservation Act exist. Portions of what were once larger areas are frequently designated as historic districts to retain a "taste" of the former community, so a visitor can imagine what the larger area would have been like during the historic period. Chicago's Prairie Avenue Historic District is a prime example. It once consisted of dozens of homes, but only four remained when the historic district was established. In the case of the Maxwell Street neighborhood, more than forty buildings from the historic period remain and retain their historic appearance, so that a person from the historic period would still recognize them.
Mr. Wheeler is correct in stating that much of the land in the proposed district is vacant. From this fact, he concludes that too little from the historic period remains within the proposed district to convey its historic significance, but he offers no facts to support his conclusion. Here are the facts: If we measure the land in the proposed district by front feet, we find that 59 percent of the frontage is built and 41 percent is vacant. Of the 59 percent, 46 percent is occupied by contributing buildings and 13 percent is occupied by non-contributing buildings. If we confine our attention to the three core frontages (south side of Maxwell, Halsted to Union; west side of Halsted, Maxwell to Roosevelt; east side of Halsted, Liberty to Roosevelt), we find that 92 percent of this frontage is built, and 71 percent of those buildings are contributing. Thus there is within the proposed district a core of street frontage with a high degree of continuity and significance. These three core frontages provide the "curtain walls" that are such an important part of the setting and they are contiguous. In other words, within the boundaries of the proposed district, the "dense urban historic setting" of the area is still very much apparent.
Furthermore, the area that remains conveys the area's historic significance better than any other part of the old neighborhood would have. The part that remains is, arguably, the most important and the most ideally representative. The intersection of Maxwell and Halsted was the neighborhood's epicenter, and remains so today. The intersection of Halsted and Roosevelt is still the neighborhood's gateway. The area's three major building types (retail/residential on Maxwell, large retail on Halsted and wholesale on Roosevelt) are all represented within the proposed district.
Mr. Wheeler acknowledges that "some of the properties have been demolished by the University of Illinois at Chicago," but claims that "the cause of the demolition is not relevant for my review." Deliberate efforts by any entity, public or private, to sabotage a proposed historic district certainly should be the concern of any historic preservation official. For years, the University of Illinois at Chicago has engaged in a pattern of property acquisition and demolition clearly calculated to damage the neighborhood's historic district potential. The fact that this behavior does not concern Mr. Wheeler reflects poorly on him and his department.
Mr. Wheeler asserts that "the integrity of design has been compromised severely with various modern modifications to the many storefronts and upper floors, and the addition of modern materials." Our assessment, and an independent evaluation made in 1994 by the UIC-funded Phase I Archaeological and Historical Evaluation of the Maxwell Street Area, disagrees. Few of the forty-plus contributing buildings have any major post-1950 alterations, except for superficial ones that have actually preserved earlier facades underneath. Many of the buildings did receive modifications during the period of significance (i.e., prior to 1950), which changed their appearance from what it was originally, but rather than detracting from the neighborhood's historic significance these changes contribute to it, as they show that this was always a dynamic urban commercial district.
In reference to both the blues and the market, Mr. Wheeler notes that these activities took place in the street, not in the buildings. He portrays the buildings as a mere backdrop to these activities, a "visual background," the equivalent of a stage set. In fact, musicians who performed on the street also performed inside the neighborhood's residences, particularly at "rent parties." These events were an important part of the musical milieu. Many musicians also had their own residences in the neighborhood. As for the market, the permanent retail stores of the neighborhood were essential to the market's success and were part of a continuum, in which a successful street merchant would "move up" to a storefront on Maxwell and, if particularly successful, a much larger store on Halsted. Permanent stores used street stands to stop customers and pull them off the streets into the stores. Throughout the historic period, the neighborhood was a complete community in which people worked and lived. The district's buildings were an integral part of the activities that give the area its historic significance.
Finally, Mr. Wheeler raises the conflict of interest issue that we first
brought to your attention in our letter of March 23, 2000. He includes
a letter from the two individuals who sit on the Illinois Historic Preservation
Agency Board of Trustees denying that any such conflict exists. In our
March 23rd letter, we simply noted the following:
"Three highly placed individuals in the state’s historic preservation apparatus have potential conflicts of interest pertaining to our application. One is the spouse of a University of Illinois trustee and two others are spouses of principals in companies hired by UIC to redevelop the Maxwell Street neighborhood. The spouses of the developers are members of the IHPA’s Board of Trustees, a six-member body. One of them is its chairperson. The spouse of the University of Illinois trustee (UIC is part of the University of Illinois system) is the governor’s policy director."
Neither Mr. Wheeler, Ms. Cellini nor Ms. Stein has disputed any
of these facts. They have merely asserted that no conflict exists. While
IHPA trustees may have no formal procedural role in National Register matters,
they are certainly influential, both on agency staff and on those officials
to whom agency officials report. They would not have their positions otherwise.
Furthermore, Ms. Cellini and Ms. Stein in their letter state that:
"The work that our husbands have agreed to undertake for the University is not contingent in any way upon the National Register status of buildings. As the University determines the desired course of action for various components of its land use plan, Richard's and Bill's companies have been hired to help to carry out those plans."
In fact, Richard Stein's company is the master developer for the
project and created the land use plan. The project, two-thirds of which
is private, for-profit development, has often been described as a "partnership"
between the University and the private developers, all of whom are part
of the "South Campus Expansion Team." The University's portion of the project
is to be funded, not by the Illinois legislature, but by profits from the
for-profit portion of the development project. If federal funding restrictions
related to National Register status were to delay or disrupt any portion
of the project, the entire development could be jeopardized. It is disingenuous
to argue that Bill Cellini and Richard Stein have no interest in the success
of this project, as they have millions of dollars at stake.
The University and its partners are hardly neutral on the matter of National Register status. The University has vigorously opposed our nomination at every turn and has engaged in a pattern of property acquisition and demolition clearly calculated to damage the neighborhood's historic district potential.
Mr. Wheeler expresses the opinion that "those alleging a possible conflict of interest have had the burden to come forward with specific facts to support those allegations and they have not done so," but then he points out why such evidence is unnecessary. He writes, "any appearance of conflict of interest or even an unfounded allegation, however, has the potential to cloud the decision-making process." On this point, we agree. Actual conflicts of interest can seldom be proved. That is why most responsible persons and institutions seek to avoid even the appearance of a conflict, so that their decision-making process will be above suspicion.
In conclusion, we consider the completion of the National Register process to be urgent as some of the contributing buildings in the proposed district are threatened with imminent demolition by the University of Illinois at Chicago. We hope you will act swiftly and declare the proposed Maxwell Street Historic District eligible for inclusion in the National Register.
Thank you for your attention to this matter. Please contact me if we can provide any assistance. I can be reached at the above address, or by phone at 773-477-9691, or via email at cowdery@21stcentury.net.
Sincerely,
Charles K. Cowdery
President
Maxwell Street Historic Preservation Coalition
cc: William L. Wheeler, Associate Director and State Historic Preservation Officer, Illinois Historic Preservation Agency
Richard Friedman, University of Illinois at Chicago
David A. Bahlman, Executive Director, Landmarks Preservation Council of Illinois
James Peters, Commission on Chicago Landmarks
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Maxwell Street Historic Preservation Coalition
P.O. Box 6435
Evanston, IL 60204