24 November 2023

RE: CONGRESS STREET H.D. - RECLASSIFICATION OF 142 FREE STREET AS NONCONTRIBUTING

Chair Mazer and Members of the Planning Board,

Greater Portland Landmarks urges you to concur with the Historic Preservation Board’s unanimous finding to maintain the designation of the former Chamber of Commerce Building, more recently known as the Children’s Museum, as a contributing building within the Congress Street Historic District.

• It more than meets the criteria for contributing status.

• There is strong public support for preserving the building.

• It meets the Portland Plan 2030 goals.

• The Portland Museum of Art’s expansion and preservation goals are not mutually exclusive.

• It is important to maintain the fair application and integrity of the historic preservation ordinance.

 Clearly Meets Criteria For Contributing Status
Although minor reversible alterations have been made to the exterior, it retains its integrity through 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.

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. 

· 17.4.1.A.1 It is significant to the cultural, historic, and architectural heritage of the city as an example of Congress Street’s commercial significance in the first half of the 20th century.

 · 17.4.1.A.4 It exemplifies a significant architectural style from its 1926 redesign by architects John Calvin Stevens and John Howard Stevens in the Colonial Revival Style, the most popular style of the period.

 · 17.4.1.A.5 It is the work of architect John Calvin Stevens and his son John Howard Stevens, whose individual work is significant in the history and development of the City. John Calvin Steven’s 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

 · 17.4.1.A.6. 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.

Public Comment on the Importance of Retaining the Chamber of Commerce Building
During the Historic Preservation Board deliberations, the retention of the former Chamber of Commerce building received significant support from the public, with 59 of the 68 public comments submitted to the city opposed to its demolition. The reclassification and demolition of a contributing historic building within one of Portland’s historic districts would set a dangerous precedent. One of the public comments regarding the proposed demolition:

“I write to urge you to save 142 Free St and not establish a dangerous precedent that could endanger many more of our treasured historic buildings. The historic character of our downtowns enriches our communities and provides a unique sense of place. This is a very important decision that cities and towns around the State of Maine will be closely watching.” Bryan Kaenrath, Waterville City Manager

In place for more than thirty years, the ordinance has set out expectations for all applicants to follow. Its fair and equitable application has helped to enhance the city’s economic and cultural success. The recently released “Trends in Portland’s Historic Districts” report states “Portland’s historic character is a…fundamental part of the city’s identity, as expressed throughout the City’s vision statement and comprehensive City goals.”

The Camiros report offers the City recommendations based on comparing Portland’s Plan 2030 goals to current land use regulations in order to better align the Land Use Code with the Comp Plan. It recommends that the Recode project “…involve considerations for ensuring that new development respects the city’s rich history and that, in the face of new development, essential elements of the city’s history are preserved.”

Preservation of 142 Free Street Meets Portland’s Plan 2030 Goals
“Portland has been built and rebuilt to endure; we will balance our historic fabric, sound infrastructure, and the best of new technology and design for the future.” From the Vision Statement, Portland’s Plan 2030.

The City and the community have invested significant time and funds into improvements to Congress Square, a significant node within the Arts District and the Congress Street Historic District. The PMA’s plan, which would necessitate the removal of the former Chamber of Commerce Building, would also remove the existing main entrance to the museum from Congress Square and locate a new entrance on High Street. In our opinion this is counter to the Comprehensive Plan’s goals to enhance the downtown, the Arts District, and undermines the ongoing planning and implementation to revitalize Congress Square.

Museum Expansion and Preservation Goals Are Not Mutually Exclusive
Although the applicant has a design proposal that necessitates the former Chamber of Commerce Building’s removal, the PMA purchased the building knowing its historic designation and solicited design proposals without acknowledging the building’s historic designation to design teams. In fact, the map included with the museum’s RFP had no building shown in the location of the Chamber of Commerce Building. Greater Portland Landmarks supports the PMA’s desire to expand, but strongly believes there remains opportunity in the design process to reconsider the demolition of a contributing historic resource and the potential impact of the new addition on Congress Square. The architect’s job is to take complex program elements and creatively synthesize those with the existing site. We strongly encourage the PMA to reconsider its proposal and we urge you to agree.

Reconsideration of the current design path is not unprecedented. In New York State, the Buffalo AKG museum’s initial expansion plans by OMA were fundamentally changed based on public reaction to the initial plans. The new building addition, which opened recently, honors the museum’s 1905 original building, its 1962 modern addition, and improves the dialogue between the museum and the Frederick Law Olmsted designed park in which the museum sits. The transformed AKG Museum meets all of the museum’s goals while preserving and respecting the museum’s architectural history.

 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 historic venue that with its state of the art acoustics, has continued to serve as a cultural hub supporting a diverse variety of programming.

 Fair Application of the Ordinance
17.5.9 Amendment or Rescission of a Designation
Amendment or rescission of any designation shall ... follow the procedure set forth in Section 17.5 for designation...The standards for rescission or amendment applied by the Historic Preservation Board, Planning Board, and City Council shall be limited to those provided in Subsections 17.4.1(A) and (B) and Subsection 17.4.2

The Historic Preservation Ordinance clearly limits the Planning Board’s consideration to those Standards found in Section 17.4.1 (A) and (B). The Historic Preservation Board, although sympathetic to the desire of the PMA to expand, unanimously determined that the former Chamber of Commerce Building meets the standards laid out in Subsections 17.4.1(A) and (B) and Subsection 17.4.2. The former Chamber of Commerce building continues to warrant its designation as a contributing building within the historic district. Moreover, its retention helps meet key goals of Portland’s Plan 2030. We hope that through your careful deliberations, you will agree that the evidence supports its current designation.

Conclusion
The PMA must reconsider its options for expansion. The city block occupied by the PMA includes several surface parking lots, including one owned by the PMA. The reclassification and demolition of a historic building which contributes to the character of the Congress Street corridor and Congress Square, a significant urban gathering space, cannot be allowed when other options exist to meet the museum’s space needs while further enhancing the city’s streetscapes. We hope that you will reject the PMA’s proposal and encourage them to return with a project that retains the integrity of the Congress Street Historic District and creates a world class museum.

Thank you for considering our views,

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