July 13, 2000
Ms Carol Shull
Keeper of the National Register of Historic Places
National Park Service
Department of the Interior
1849 C Street, NW
Washington, D.C. 20240
Attn: Ms. Beth Boland
Re: Proposed National Register of Historic Places Listing Maxwell Street Historic District
Dear Ms. Boland:
It is my opinion that this proposed historic district does not meet the National Register criteria and therefore I am not nominating it to the National Register of Historic Places. My action is based on the lack of integrity possessed by the proposed area, especially integrity of setting, design, materials, and feeling.
Background
Before discussing the reasons for my opinion it may be helpful to provide
a brief description of the background of this application. The application
under consideration was submitted for consideration by the Illinois Historic
Sites Advisory Council (IHSAC) at its June 9, 2000 meeting. A previous
application was considered favorably by IHSAC in 1994. My opinion and recommendation
at that time was that the proposed district not be listed due to its lack
of integrity. In a letter dated December 22, 1994, your office determined
that the district would not be designated due to its lack of integrity.
The current application is similar to that of 1994, with one substantial difference: the addition of the blues music theme as one of the bases for significance under Criterion A.
Recommendations: IHSAC and Agency National Register staff
with respect to the current application our National Register staff
is of the opinion that the proposed district lacks integrity and should
not be listed. After considering supporters' and opponents' presentations
and staff opinion at its meeting, IHSAC voted unanimously (11 yes, 0 no,
3 absent) to recommend its nomination.
Evaluation
I made a personal visit to the proposed district in 1994, and did so
again just a few weeks ago. Since 1994 at least 10 buildings have been
demolished, leaving additional vacant lots. As the applicants point out
some of these properties have been demolished by the University of Illinois
at Chicago. However, the cause of the demolition is not relevant for my
review. What is clear is that the integrity of the proposed district has
significantly deteriorated from what it was in 1994.
My concerns with regard to some of the particular aspects of integrity are outlined below:
Setting-The area under consideration is a small remnant of the building stock and streetscapes that originally comprised the Maxwell Street Market and Halsted Street retail area. Most critical to understanding the historic character of the market are the actual buildings that created curtain walls. Many blocks and hundreds of building of the market area and Halsted Street have been entirely demolished. The few remaining buildings are only an incomplete fragment of the historic streetscapes. Instead of the area being framed by contiguous rows of buildings, those few buildings that remain are often surrounded by empty space where historic buildings once stood, modern buildings, or badly altered older buildings. The dense urban historic setting of the area has been significantly lost through demolitions.
Design-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.
Materials-As mentioned above, there has been significant demolition of historic buildings in the market area. Most notable is the loss of nearly all the historic buildings on the north side of the only remaining block of Maxwell Street. Renovations on exteriors also have resulted in the loss of much historic fabric.
Feeling-I find it difficult to believe that most persons visiting
Maxwell Street today will find that Maxwell Street conveys feeling that
is similar to that which would have been conveyed during the period of
significance. The simple fact is that too many buildings are entirely missing
or severely modified.
In addition to visiting the proposed district, I reviewed the following
materials, copies of which are enclosed:
(1) The application form with attachments.
(2) The City of Chicago Landmark Commission's letter dated April 10,
2000, indicating that the Commission stands by its 1994 opinion that the
district not be nominated to the National Register, and noting that the
integrity found lacking in 1994 has only diminished since that time.
(3) Historic Preservation Agency's National Register staff opinion
that the proposed district lacks the integrity necessary for the National
Register, dated March 6, 2000; this opinion was repeated in a presentation
made by Tracey Sculle, and indicated that the same view is held by all
HPA's National Register staff.
(4) Correspondence in support of the application, much of which you
may have already received.
(5) A report presented at the IHSAC meeting by the University of Illinois
at Chicago, opposing the application.
The first step that I took was in essence to review my 1994 opinion that there was a lack of integrity. My conclusion is that my previous opinion was correct and is further verified by the loss of additional buildings since that time.
Another question I thought should be considered was whether the blues music theme as opposed to the commercial activity theme would somehow alter the requirements of what would be needed for the proposed district to have sufficient integrity. My conclusion is that the new theme does not alter the manner in which integrity should be evaluated because I understand that both types of activities were undertaken in the same setting.
It is clear from reading the application that there is considerable evidence, much of it in the form of oral history, that Maxwell Street was a place where musicians frequently played and that some of these musicians made important contributions to the development and popularizing of the blues. It is also clear that most of their activities took place on the street. Little information is provided to show an association with particular remaining buildings.
The commercial activities of street vendors and of building occupants took place with the back-drop of the multi-story curtain walls lining the streets. Similarly the blues music took place on the streets, with the same buildings providing the historic visual background. I have not found any reason to conclude that the important elements of integrity would be any different for the blues music theme than for the commercial activity theme.
The application is supported by a large number of enthusiastic persons and represents a substantial effort on their part intended not only to list the properties but to foster their preservation. Furthermore, this is one of those properties in Illinois where few if any would question its significance. Finally, it is rare that I disagree with IHSAC, a group of professionals and experienced preservationists whose opinions I value. Given these factors it is without any pleasure that I conclude that I must not nominate the proposed district and must recommend that your office not approve the proposed historic district. I find that I cannot do otherwise based on my understanding of the manner in which integrity is to be evaluated, as set forth in the National Register Bulletin Number 15.
I would note that a number of allegations have been made that there may be a possible conflict of interest involving two of our agency's trustees since their husbands' companies have a contract to develop the property being purchased by the University of Illinois at Chicago in and around the proposed historic district. A similar allegation has been made with regard to a member of our Governor's staff whose husband is a trustee of the University of Illinois, although neither has any financial involvement. Finally, similar unspecific allegations have been made that I have not acted independently in my review. It is important to note that my review of the first application for Maxwell Street occurred in 1994; our trustees' husbands' companies did not receive a contract with the University until 1997, a contract which was awarded after a competitive and well publicized public selection process conducted by the university. My review of these allegations indicates that there is no basis to support them.
Neither these individuals nor their husbands nor anyone acting on their behalf has had any role or made any suggestions as to my recommendation to your office. My recommendations to your office? both in 1994 and today? are based solely upon my review of the file, inspection of the proposed historic district, and my understanding of the National Register requirements for listing. In a letter dated May 1, 2000 these trustees informed their fellow trustees of the allegations and explained the role that their husbands' companies have in developing property. This letter, I believe, made it clear that these trustees have no role in the National Register process and that they wanted to make sure that their fellow board members were apprised of both the allegations and of their response to those allegations. A copy is enclosed for your information.
I believe 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. Any appearance of conflict of interest or even an unfounded allegation, however, has the potential to cloud the decision-making process. In this case my action is in the form of a recommendation and we welcome the independent review that will be made by your office before deciding whether or not to designate the proposed historic district. Certainly those making the allegations should understand that you are aware of their concerns and that your review will be based upon your evaluation of the application and materials submitted, and will by no means be only a formality.
Please let me know if you need additional information,
Sincerely,
William L. Wheeler
State Historic Preservation Officer
217 785-9045
cc.: Lori Grove
Michael C. Moran
William Lavicka
Steve Dalkin
Maxwell Street Historic Preservation Coalition, Charles Cowdery
University of Illinois at Chicago, Richard Friedman
Commission on Chicago Landmarks, James Peters
Landmarks Preservation Council, David Bahlman
Return to the Maxwell St. News Update page.
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Return to Chuck Cowdery's home page.
Go to the Maxwell Street Historic Preservation Coalition home page.
Contact Us
TO REACH US VIA EMAIL:
Chuck Cowdery, President (cowdery@21stcentury.net)TO REACH US VIA THE USPS:
Steve Balkin, Vice President (mar@openair.org)
Maxwell Street Historic Preservation Coalition
P.O. Box 6435
Evanston, IL 60204