Tracking the Federal Reviews

Why federal reviews: The massive changes proposed for Jackson Park by the Obama Foundation, Chicago Department of Transportation, and the Park District would impact roads and Lake Michigan as well as the Park and thus potentially involve actions by the Federal Highway Administration, the US Army Corps of Engineers, and the National Park Service. As a result, federal reviews of the proposals are required before any work can begin.

What are the reviews:
The “Section 106” review is required under the National Historic Preservation Act of 1966. It began December 1 and is projected to last until at least December 2018. It requires federal agencies to consider the effects of their plans on historic properties; Jackson Park and the Midway Plaisance are listed on the National Register of Historic Places as are nearby communities. This reviews involves:

  • developing a thorough inventory of historic properties in the affected area(s);
  • identifying potential adverse impacts on the historic property involved (in this instance, Jackson Park, the Midway Plaisance, potentially others as well, to be determined);
  • developing alternatives to avoid, minimize, or mitigate adverse effects;
  • reviewing these with the consulting parties to attempt to reach agreement;
  • finalizing the process with a Memorandum of Agreement.

It is possible that the current Section 106 review could find that some or all of the OPC and CDOT road proposals for Jackson Park would have an significant adverse impact on the Park. In that event, the Federal Highway Administration, as the ultimate legally responsible party, would have to work to find an acceptable way to mitigate that impact.

A “NEPA” review is required under the National Environmental Policy Act of 1969 to assess the environmental impacts of proposed projects that entail the expenditure of federal funds. An unspecified number of public meetings will be held, culminating in a formal public hearing. It is also underway, concurrent with the Section 106 review, and will continue until fall. No public meeting has yet been scheduled. A NEPA review involves:

  • assessing a broad range of potential environmental impacts including wildlife/habitat, noise, traffic, air and water quality, and socio-economic factors;
  • identifying adverse impacts and their significance;
  • considering of alternative ways of mitigating them;
  • releasing a tentative decision for public comment and input by consulting parties, which may agree or disagree;
  • reaching final decision as to what alternative(s) to pursue and how to pursue it.

A UPARR review is needed under the Urban Parks And Recreation Recovery Act of 1978. Because Jackson Park received two grants under the UPARR act in the early1980s, various conditions must be met for the National Park Service to determine whether and how much Jackson Park land can be converted from recreational to non-recreational uses for the OPC. Replacement land must also be identified before conversion is allowed. This review, conducted by the National Park Service, is also underway.

Consulting parties: Interested groups and organizations may ask to become a “consulting party” for the Section 106 review, with the ability to raise questions, submit feedback, and otherwise have a seat at the table. Jackson Park Watch is one of the consulting parties along with numerous local, state, and national groups concerned with parks, natural areas and historic preservation. The consulting parties also have a role to play at the conclusion of the NEPA review, with the right to comment on and agree or disagree with the outcome of the NEPA process. If there is disagreement, an attempt to resolve the issue must be made.

What entities manage these reviews: With the exception of the UPARR review (being managed by the National Park Service), the Section 106 and NEPA reviews are being managed by the Chicago Department of Planning and Development and the Chicago Department of Transportation. The federal agency with the ultimate responsibility for the reviews is the Federal Highway Administration, reflecting the centrality of the proposed road changes to all of the changes under review. Note that Jackson Park Watch has written the Federal Highway Administration expressing concerns about the dual role of CDOT in the process, first as the entity that developed the road proposals under review, and then as co-manager of the review process.

The review process to date:
December 1: The kickoff meeting with an overflow crowd was held December 1 at the South Side Y, 63rd St. and Stony Island. A lengthy presentation included a list of historic resources (i.e., not only buildings) and maps of Area(s) of Potential Effect (APE) – one archaeological, one architectural. It culminated with opportunities for questions. Consulting parties were told that they would have until January 5 to submit suggestions concerning additional historic resources and the areas that should be included in the APE.    The link to the December 1 meeting presentation is here.

January 5: Jackson Park Watch and numerous organizations with which JPW works submitted comments, often raising concerns and questions beyond those related to historic resources and the proposed Areas of Potential Effect. The organizations and their statements include:

  • The Cultural Landscape Foundation
    • TCLF emphasized the Olmsted vision and design of the Park , with important great historical detail
  • The National Association for Olmsted Parks
    • NAOP emphasized comprehensive planning and maintaining the character-defining features of the Park
  • Landmarks Illinois
    • Landmarks Illinois urged expansion of the APE to include additional historic area and Woodlawn, and also consideration of the”GLFER” native habitat restoration project
  • Preservation Chicago
    • Preservation Chicago submitted a wide-range of important factors needed consideration
  • Friends of the Parks
    • FOTP labeled the presence of the OPC in the Park as itself an “adverse effect” on this historic resource
  • Openlands
    • Openlands proposed a useful set of principles that should guide changes in the Park
  • Jackson Park Watch
    • JPW urged that since the closure of Marquette Drive is included in the section 106 review, the proposed golf course merger/expansion should likewise be included
  • Blacks in Green
    • BIG questioned how these reviews could proceed in the absence of final, defined plans
  • Save the Midway
    • Save the Midway argued for inclusion of the full length of the Midway Plaisance and of Washington Park as well in the Area of Potential Effect
  • Midway Plaisance Park Advisory Council
    • MPAC asked that the entire length of the Midway be included in the review and that the existing Midway Framework Plan be included as well
  • 1Woodlawn
    • The 1Woodlawn letter raises concerns about inadequate recreational space, whether the Park will continue to accommodate family reunions and similar activities, potential new traffic and parking problems in Woodlawn, and the need to recognize Woodlawn’s historical heritage.
  • Hyde Park Historical Society
    • The Hyde Park Historical Society contributed concerns about key historical features of Jackson Park that would be adversely impacted by the current Obama Presidential Center design

March 29 section 106 meeting

The next meeting, much delayed, took place March 29. Lengthy Historic Properties Inventory and Archaeoloy Reports were released to consulting parties and others about 10 days in advance, and were briefly reviewed at the meeting (the documents are on line at – scroll down to the March 19, 2018 entry). A webinar of the 3/29 meeting is available on the same site at the March 29 entry. Consulting parties were then given until April 19 to submit comments.  A selection of important consulting party comments appears below. Also, note that, as summarized in a separate piece by The Cultural Landscape Foundation, there was significant push back to how the City facilitators of the section 106 process depicted important issues, as to what was emphasized and what excluded, and more.

Comment from Friends of the Parks:

Comment from Hyde Park Historical Society:

Comment from Jackson Park Watch:

Comment from Landmarks Illinois:

National Association of Olmsted Parks:

Comment from Openlands:

Comment from Preservation Chicago:

Comment from Save The Midway:

Comment from The Cultural Landscape Foundation:

Next Steps

In what appears to many consulting parties to be an unduly compressed and rushed schedule, the City facilitators of the section 106 process have scheduled a meeting in May to consider assessments of the impacts of the proposed changes to Jackson Park and to move on to discussing mitigations of those impacts, all in the same meeting.

Existing Park Framework plans:

Information about the review processes: