25 October 2023

RE: CONGRESS STREET HISTORIC DISTRICT - RECLASSIFICATION OF 142 FREE STREET AS NONCONTRIBUTING

Chair O’Brien and Members of the Historic Preservation Board,

Greater Portland Landmarks does not oppose the expansion of the Portland Museum of Art’s campus and we are enthusiastic about the prospect of another landmark building being added to the museum's collection. We do not believe preservation of the former Chamber of Commerce Building and the introduction of a contemporary landmark are mutually exclusive.

As we addressed in our statement for the October workshop, Landmarks strongly believes that the former Chamber of Commerce Building clearly meets the criteria for designation as a contributing structure, both in terms of its architectural, historic, and thematic significance within the Congress Street Historic District and its retention of the required level of integrity to its 1926 appearance. The PMA’s reclassification request includes a consultant report that focuses largely on interior alterations, which are not under the purview of the Historic Preservation Board, and the early history of the building, rather than the integrity of the building’s exterior appearance since its 1926 alteration. The building’s exterior is largely unchanged from its appearance in 1926 or from its appearance when it was evaluated for inclusion in the Congress Street Historic District. Greater Portland Landmarks finds no basis in the consultant’s report for reclassification of the building as a non-contributing structure.

While not designated as an individual landmark, the former Chamber of Commerce building, like all contributing buildings, in combination with its neighbors forms the cohesive fabric essential to the establishment of a historic district. In addition, the former Chamber of Commerce Building meets 4 out of the 6 criteria laid out in Subsection 17.4.1.A of Portland’s Historic Preservation Ordinance. It also meets the criteria laid out in Subsection 17.4.1.B. and Subsection 17.4.2 of the ordinance.

  • It is significant to the cultural, historic, architectural heritage of the city.

  • It exemplifies a significant architectural style.

  • It is the work of an architect whose individual work is significant in the history or development of the City of Portland and the State of Maine.

  • As the former home for nearly 60 years of the city’s Chamber of Commerce, it expresses and contributes to the theme of the Congress Street Historic District, a cohesive corridor of commercial and civic buildings that are significant for their role in the commercial, social, and architectural development of the city from 1780-1958.

  • Although minor alterations have been made to the exterior, it retains its temple-form, major fenestration patterns, and the architectural details of its primary facade that are character defining elements of its design and reflect its appearance during its use by the Portland Chamber of Commerce.

The Portland Museum of Art’s collection is significant to the art history and culture of Maine. The largest pieces in the PMA’s collection are its five historic buildings. This expansion project is an opportunity to further unify all the varied historic buildings on the museum’s campus. Greater Portland Landmarks believes that there are options to meet the Museum’s worthy goals and to preserve the former Chamber of Commerce Building on Free Street.

Portland has examples of the beneficial results that can occur when demolition plans are reconsidered. One such example occurred in the 1990s when plans to demolish the interior of Portland’s Merrill Auditorium were touted as the only means to achieve state-of-the-art acoustics. The demolition plans were resisted by a vocal group of citizens who advocated for a second opinion. Experts capable of improving the concert hall’s acoustics while preserving the historic interior were then hired. The result is a beautiful venue that serves as a cultural hub supporting a diverse variety of programming.

Landmarks does not believe the best way forward is the demolition of one of the PMA’s largest assets. Instead, we encourage the PMA to work creatively with their architects and with the Historic Preservation Board to seek a Certificate of Appropriateness that incorporates the former Chamber of Commerce building into its campus expansion project.

The vote to reconsider the designation of the former Chamber of Commerce Building is significant not only for this application, but also significant to maintaining the integrity of the ordinance itself and to the preservation of other contributing structures throughout the City’s historic districts. We hope that you will apply the criteria of the ordinance in this case as you do in all development projects, large and small, that you consider. In your careful deliberation we urge you to agree that the evidence supports the former Chamber of Commerce building’s continued designation as a contributing building within the historic district.

Thank you for considering our views,

Carol De Tine
Vice President of the Board of Trustees
Greater Portland Landmarks