28 September 2023

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

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

In response to the Portland Museum of Art’s request to revise the classification of the former Chamber of Commerce building at 142 Free Street (more recently known as the Children’s Museum building), Greater Portland Landmarks has considered the historic preservation ordinance’s criteria for designation of a contributing structure within a local historic district in order to determine whether the Chamber of Commerce Building is more appropriately classified as non-contributing, as PMA suggests. Based on this analysis, Greater Portland Landmarks believes that the building clearly meets the criteria for designation as a contributing structure, both in terms of its architectural and historic significance within the Congress Street Historic District and its retention of the required level of integrity. Greater Portland Landmarks finds no basis for reclassification as a non-contributing structure.

As HP Board members are aware, the historic preservation ordinance clearly identifies criteria which must be met in order to be classified as a contributing structure within a district. During the district designation process, each structure or site is carefully evaluated in order to assign a classification of contributing, non-contributing or Landmark. This was done for the Congress Street Historic District and documentation on each building was included as part of the required designation materials.

Within the boundaries of any given district, inevitably there will be a number of structures which fail to meet the criteria for designation as a contributing structure either because they lack significance under any of the categories identified in the ordinance or because they do not exhibit sufficient integrity to be designated. For example, a building that is structurally unsound or has been altered on the exterior to such a degree it no longer retains its historic character will not meet the integrity standard and be classified noncontributing structure even if it is historically or architecturally significant.

The historic preservation ordinance requires that this same rigorous analysis be conducted when a request is made to change the classification of a structure or site within a district. The same criteria must guide the Board’s final determination and recommendation to the Council. In order to change the classification of a building from contributing to non-contributing, the Board must find that the original classification was erroneous (perhaps based on incomplete information) or that circumstances have changed such that the building no longer meets the required criteria (if a building becomes structurally unsound, for example). Since the ordinance was adopted in 1990, about a dozen buildings have been reclassified following the process outlined in the ordinance. Greater Portland Landmarks followed these requests and, in each case, supported the reclassification based on the ordinance criteria. In this case, however, Landmarks strongly believes that the evidence that led to the building’s original designation as a contributing building continues to exist and meets the minimum criteria set forth in the Ordinance.

EVALUATION BASED ON CRITERIA

We encourage the Board to consider the following in your discussion of the owner’s request to reclassify the former Chamber of Commerce Building to noncontributing.

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.

17.4.1 Minimum Criteria for Designation 17.4.1.A. The ordinance limits consideration by the HPB 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 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.

17.4.1.B. In the case of a nominated historic district, the Historic Preservation 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.

  •  As stated above, the former Chamber of Commerce Building is a contributing building within the Congress Street Historic District. It expresses the commercial theme of the district and contributes to the district’s visual character. The Congress Street Historic District is a cohesive corridor of commercial and civic buildings that are significant for their role in the commercial, social, and architectural development of the city. Although flanked by a parking lot to the north, the Chamber of Commerce Building is visually related to its neighbors across Free Street, 133-135 Free Street (c1810-1820) and the Landmark-designated CQ Clapp Block/HH Hay Block at 588 Congress Street (built 1826 and altered 1922), and to the Payson Wing of the Portland Museum of Art next door. Like 133-135 Free Street and the HH Hay Block, the Chamber of Commerce Building is an early building 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 and like the Payson Wing, its monumental facade helps to define the eastern boundary of Congress Square, a significant node within the boundary of the district.

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 retains integrity of location, design, condition, materials, and workmanship. Although the building’s exterior has been altered since it was redesigned for use by the Chamber of Commerce, these alterations are reversible, have not significantly altered the character defining features of the building’s style, and do not detract from the overall appearance of the building.

    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.

    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 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.

The former Chamber of Commerce building continues to warrant its designation as a contributing building within the historic district. We hope that through your careful deliberations, you will agree that the evidence supports its current designation.

Thank you for considering our views,

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