8 February 2024

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

Chair Mazer and Members of the Planning Board,

We offer the following comments in addition to the letter submitted by our attorneys at Murray, Plumb & Murray.

Greater Portland Landmarks supports the expansion of the Portland Museum of Art but does not believe that the expansion necessitates the demolition of 142 Free Street, an action that would occur if the building was reclassified as non-contributing. Landmarks believes that the former Chamber of Commerce Building at 142 Free Street (more recently known as the Children’s Museum building), clearly meets the historic preservation ordinance’s criteria for designation as a contributing structure in a historic district. Landmarks strongly believes that the evidence that led to the building’s original designation as a contributing building in the historic district continues to exist and meets the minimum criteria set forth in the Ordinance.

EVALUATION BASED ON CRITERIA

During any district designation process, each structure or site is carefully evaluated and assigned a classification of Landmark, contributing, or non-contributing. This was done for the Congress Street Historic District and documentation on each building was included as part of the required designation materials that were reviewed and approved by the Historic Preservation Board, the Planning Board, and the City Council.

Section 17.5.9 of the Ordinance, “Amendment or Recission of a Designation” identifies the standards for recission or amendment. The standards for a decision by the Planning Board are limited to those provided in Subsections 17.4.1(A) and (B), and Subsection 17.4.2. Subsection 17.4.1(A), sets out the minimum criteria for determining a building’s significance, Subsection 17.4.1(B) sets out the criteria for determining if a historic district possesses a significant concentration, linkage, or continuity of structures, and Subsection 17.4.2, sets out the criteria for assessing the building’s integrity, meaning its ability to convey its historical associations or attributes. The status of 142 Free Street was carefully considered. As we demonstrate below, the building met all of the criteria when it was originally classified as contributing. No significant changes to the building since that date or new information regarding its structural instability have been presented by the applicant that justify a change in the original determination. We encourage the Planning Board to consider the following in your discussion of the owner’s request to reclassify the former Chamber of Commerce Building to noncontributing.

142 Free Street Still Meets the Minimum Criteria for Determining Significance

17.4.1.A. The ordinance limits consideration by the Board to the following criteria in making a determination on … an area, site, structure, or object for designation by ordinance as a landmark or district:
17.4.1.A.1. Its value as a significant example of the cultural, historic, architectural, archaeological, or related aspect of the heritage of the City of Portland, State of Maine, New England region, or the United States:

• The Chamber of Commerce Building is an example of the commercial significance of Congress Street within Portland in the first half of the 20th century. It is also an example of the significance and prominence of Portland’s business community within the state and northern New England in the first half of the 20th century. At the turn of the 20th century Congress Street from City Hall to Congress Square was noted for its fashionable shops and large department stores. Particularly between 1900 and 1930, the Congress Street business district replaced Exchange Street and the Old Port area as the business center of the city. At Congress Square this new commercial prominence is reflected in the construction of the Schwartz Building (1920), Eastland Hotel (1927), State Theater (1929), the third-story addition to the 1826 C.Q. Clapp Block/H.H. Hay Block (1922), and the alteration of the former Free Street Baptist Church for use by the Chamber of Commerce (1926).

17.4.1.A.4. Its exemplification of a significant architectural type, style, or design distinguished by innovation, rarity, uniqueness, or overall quality of design, detail, materials, or craftsmanship.

  • Redesigned in 1926 in the Colonial Revival Style, architects John Calvin Stevens and John Howard Stevens utilized the most popular style of the period. By the turn of the 20th century the Colonial Revival Style was one of the most predominant styles of architecture on the East Coast. It had quickly become the fashionable style in architecture following the Columbian Exposition of 1893 in Chicago. The style surged in prominence following World War I and again following World War II.

17.4.1.A.5. Its identification as the work of an architect, designer, engineer, or builder whose individual work is significant in the history or development of the City of Portland, the State of Maine, the New England region, or the United States.

  • John Calvin Stevens and his son John Howard Stevens are perhaps the most well-known and documented architects working in Portland at the turn of the 20th century. John Calvin Stevens’ significance to Portland and Maine’s architectural history is rivaled by his historic significance to Portland’s Art community and to the PMA itself:

    “He designed the museum’s L.D.M. Sweat Memorial Galleries. More importantly, he was a leader and president of the group that founded the museum. And it was he who secured the patronage that made the institution a reality and gave it staying power. But the Portland Society of Art not only founded the PMA, it created what is now the robust and thriving Maine College of Art, which many consider to be the most highly energized art institution in the art-oriented state of Maine.” Portland Press Herald, July 5, 2015.

    In addition to the Chamber of Commerce Building other significant examples of the Colonial Revival style by the firm include Biddeford City Hall (1896), South Portland’s Roosevelt School (1927), Fryeburg Academy’s Curtis and Cutter Halls (1930) and Portland’s US Post Office (1934) on Forest Avenue.

17.4.1.A.6. Its representation of a significant cultural, historic, architectural, archaeological, or related theme expressed through distinctive areas, sites, structures, or objects that may or may not be contiguous.

  • The Chamber of Commerce Building is a contributing building within the Congress Street Historic District, an area locally designated in 2009 to document Portland’s business district. The building’s use by the Portland Chamber of Commerce for its offices from 1926-1993 expresses the commercial theme of the district. The building and its use are integral to an understanding of the Congress Street business district’s development during the first half of the 20th century.

142 Free Street Still Possesses a Significant Linkage with Other Structures within the Historic District.

17.4.1.B. In the case of a nominated historic district, the Board shall also determine whether there is an interrelationship of resources within it which creates an identifiable entity, even if composed of a wide variety of resources. A district must convey a visual sense of the overall historic environment or be a grouping of historically or functionally related properties. A historic district can comprise both individually distinctive historic resources and historic resources that may lack individual distinction, but which contribute to the significance and visual character of the district as a whole.

The “eclecticism and layering of historical periods is the essence of the district’s character and what makes it unique among Portland’s historic districts.” Congress Street Historic District, Local Designation Narrative.

  • While this section applies to historic districts, as stated above, the former Chamber of Commerce Building is a contributing building within the Congress Street Historic District. The Congress Street Historic District’s commercial and civic buildings form a cohesive corridor that are physically related. They are also thematically related by their significant role in the commercial, social, and architectural development of the city. The former Chamber of Commerce Building expresses the commercial theme of the district and contributes to the district’s visual character through its relationship to other historic buildings at Congress Square.

    • Although adjacent to a large parking lot, the Chamber of Commerce Building is visually related to its neighbors across Free Street, 133-135 Free Street (c1810-1820) and the Landmark-designated Charles Q Clapp Block/HH Hay Block at 588 Congress Street (built 1826 and altered 1922 by John Calvin Stevens). The Chamber of Commerce Building is also thematically related to 133-135 Free Street and the HH Hay Block. All three are early buildings altered to meet the changing needs of the evolving business district in the early 20th century.

    • The former Chamber of Commerce Building is also visually related to its neighbor, the Payson Wing of the Portland Museum of Art. The Payson Building, although built less than 50 years ago, is considered part of the Landmark-designated Museum campus. Together the two buildings’ monumental facades help to define the eastern boundary of Congress Square, a significant node within the historic district.

142 Free Street Still Meets the Criteria of Building Integrity

The National Parks Service standards upon which Portland’s ordinance is based, do not require the materials, features, and spaces of buildings to be original to be considered “historic” and “character-defining.” A structure can be significant not only for the way it was originally constructed or crafted, but also for the way it was adapted at a later period to illustrate changing tastes, attitudes, and uses over a period of time. The Congress Street Historic District is largely significant as a commercial corridor, and the 1926 alterations of the 142 Free Street building reflect the evolving commercial character of Congress Square in the early 20th century. The period of its history from 1926 onward is the time-period from which its integrity is considered.

17.4.2. Integrity of Landmarks and Historic Districts. Any area, structure, or object that meets the criteria in Section 17.4.1 must also have sufficient integrity of location, design, condition, materials, and workmanship to make it worthy of preservation or restoration.

  • The former Chamber of Commerce Building possesses integrity of location as it remains in its historic Free Street location.

  • The building retains its integrity of design, although altered by replacement windows and doors, and additions necessary for code requirements and its use as a museum, the major Colonial Revival design features of the Chamber of Commerce building as designed by the Stevens firm (in particular at the Free Street elevation) have not been irretrievably destroyed. The building 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. In the technical language of the historic preservation ordinance, the building retains its design integrity, its ability to convey the historical association and the physical attributes that were present during the nearly 60 years the building served as the Chamber’s headquarters.

  • The building retains its integrity of condition, as it is structurally sound according to the applicant’s statements before the Historic Preservation Board, although like any building that has not been updated for a period of time, it would need to have some alterations for code requirements for any potential new use.

  • The building retains its integrity of materials, although some historic materials have been lost through the replacement of windows and doors, the structure still retains significant amounts of historic materials including the masonry walls and extensive decorative trim and details of the temple front. In fact, the building’s exterior condition is like many of its neighbors within the Congress Street Historic District. Most of the buildings within the district have undergone updates and alterations such as window or storefront replacements since their period of construction. However, the district’s contributing buildings typically retain their original (mainly brick) facades, storefront use, and character-defining architectural details.

  • The building retains its integrity of workmanship, although some historic workmanship was lost through the replacement of windows and doors, the structure still retains significant evidence of historic workmanship in the masonry walls and in the extensive decorative trim and details of the front façade. The loss of original window, door, and storefront materials is typical in the historic district.

The Chamber of Commerce Building was first identified as historically significant when it was included within the boundary of the Spring Street Historic District when that district was added to the National Register of Historic Places in 1970. After that listing, the building’s exterior was minimally altered for its use by the Children’s Museum in the early 1990s. Alterations to accommodate new uses are not necessarily evidence of lack of integrity, in fact the review standards are intentionally flexible to accommodate changes that facilitate a building’s reuse (see attached images). When the building was documented for the Congress Street Historic District’s designation report, the code required additions and rooftop alterations by the Children’s Museum were noted and the alterations did not affect its contributing status. The alterations are reversible and therefore the altered features are not “irretrievably lost”. The alterations have not significantly altered the character defining features of the building’s Colonial Revival style, form, and primary facade, and do not detract from the overall appearance of the building.

A comparison using the 1958 Portland Press Herald photograph presented in the applicant’s report and a more recent image of the buildings makes it clear that although alterations have occurred, the building retains its temple-form, major fenestration patterns, and the architectural details of its primary facade that are character defining elements of its Colonial Revival design and reflect its appearance during the building’s nearly 60 year use by the Portland Chamber of Commerce.

CONCLUSION
For a building to be designated as a contributing structure, it needs to meet just one of the criteria laid out in Subsection 17.4.1.A of Portland’s Historic Preservation Ordinance. The former Chamber of Commerce Building meets 4 out of the 6 criteria. 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. In the technical language of the historic preservation ordinance, the building retains its integrity, its ability to convey its historical association and the physical attributes that were present during the nearly 60 years the building served as the headquarters of Portland’s Chamber of Commerce.

The former Chamber of Commerce building continues to warrant its designation as a contributing building within the historic district. There is no basis for rescinding its designation. We hope that through your careful deliberations, you will agree that the evidence supports its current designation.

We urge the applicant to work with their consultants to incorporate142 Free Street into their proposal, and to return to the Historic Preservation Board to obtain a Certificate of Appropriateness so that they may move forward with their expansion plans to create a more welcoming and inclusive museum.

Thank you for considering our views,

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

Attachment:
Images of altered buildings which retain their historic character and significance in Portland’s historic districts