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On May 26, 2020, the SHPO raised expectations for several of the official consulting parties participating in the Section 106 process when it called for “additional design review” of the OPC, including raising the possibility of relocating the facility. This was an important follow up to the SHPO’s February 18, 2020, letter concurring with the assessment of the severity of the OPC’s impact on Jackson Park as detailed in the . Coming late in the Section 106 review process, the May 26 letter forced a one-month postponement of the next Section 106 meeting during which a would be discussed. The draft MOA spells out the mitigation measures that would be implemented to compensate for the loss of 19.3 acres of parkland for the OPC.

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The SHPO’s move was all the more important because the Federal Highway Administration (FHWA) had declared itself powerless to affect the location of the OPC. Moreover, efforts to “avoid” and/or “minimize” the adverse effects of the OPC on Jackson Park (stated goals of the Section 106 review process), were essentially off the table. However, at the July 16, 2020, Section 106 meeting, the SHPO’s Cultural Resources Coordinator, CJ Wallace, in a stunning reversal, announced that they were “satisfied” with responses to their “design review” concerns from the FHWA and the City. Wallace did not elaborate on the agency’s about face reasoning except to add that the SHPO looked “forward to executing the MOA.”

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What will be the result of the Section 106 process, which began in December 2017? Mitigation, the least impactful measure to address the loss of 19.3 acres. According to the , the mitigation measures include: [1] update the National Register of Historic Places designation; [2] photographs and drawings documenting existing conditions; [3] a Cultural Landscape Report for Jackson Park; [4] “a plan for interpretive materials”, i.e. signage; [5] rehabilitation and restoration of a comfort station and a statue; and, [6] design review of a playground in the neighboring Midway Plaisance.

That’s it. Separate out the reports and documentation, and the addressing of some deferred maintenance, what we’re left with is signage.

The recompense for the taking of 19.3 acres of historic parkland thrice designed by Frederick Law Olmsted, Sr. and listed in the National Register of Historic Places is signage.