Alderman Scott Waguespack Lathrop Letter to CHA 012714

8/13/2019 Alderman Scott Waguespack Lathrop Letter to CHA 012714

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January 27,

2014

Mr. Michael Merchant

CEO

Chicago Housing Authority

60 E Van Buren

Chicago, IL 60605

In November 2012 I wrote a letter (enclosed) to your predecessor Mr. Woodyard expressing serious

concerns regarding the planning process and initial development scenarios proposed by Lathrop

Community Partners

(LCP).

Thirteen

organizations

in

the

surrounding

neighborhood

signed

on

as

supporters of this letter. Subsequently, the CHA and LCP made some substantive changes relative to the

initial development scenarios, most notably decreasing the residential density from 1,600 to just fewer

than 1,200 units. Despite this progress toward addressing community concerns, there remains key

issues that must be addressed before the process can advance toward the submission of a planned

development application.

The current plan, presented in August 2013 as a, “final draft plan,” calls for an, “iconic tower,” of an

unspecified height. The model presented at the open house suggested a high‐rise of approximately 28

stories. The proposal to revert back to the days of high‐rise public housing by building a tower on the

Lathrop

Homes

site

is

completely

unacceptable

to

both

me

and

the

overwhelming

majority

of

surrounding neighbors. A building of such height and density would be completely out of context and

character relative to the surrounding neighborhoods and materially detract from the historic character

of the existing buildings slated to be preserved on the Lathrop Homes site. The higher construction costs

associated with high rise buildings only serves to intensify the need for taxpayer subsidy. Further, high

rise towers have demonstrated a tendency to isolate their residents and increase criminal activity rather

than promoting healthy integration with their surrounding communities.

The following points detail my objections to this unfortunate, yet persistent, element of the LCP plan for

Lathrop Homes:

Excessive Height is Inappropriate Relative to the Surrounding Community—High‐rise

residential

buildings are typically built in areas with high levels of residential density in locations with close access

to high capacity mass transit and significant resident and visitor amenities within walking distance. The

proposed location of this Lathrop Homes high‐rise features none of these attributes. The City’s own

Department of Planning and Development would certainly oppose a proposal for a similar high rise in

this neighborhood on private property on the grounds that the height and density were excessive and

would detract from the viability of surrounding residential units. The only relatively recent proposal for a



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residential high rise in this area was rejected after strenuous opposition from neighboring residents and

the former 1st Ward Alderman.

High Rise Construction Costs are Significantly Greater—LCP’s plan to build a high‐rise tower is

contributing to the purported need for public subsidies. Recent construction cost data from RS Means

places the

cost

of

constructing

8‐24

story

high

rise

apartment

units

38

percent

higher

than

1‐4‐story

units. LCP has stated a need for $30 million or more in subsidies from the City. A high rise is not

necessary to accomplish the level of density the CHA is proposing for the site. Why then is LCP insistent

on building a high rise? The only plausible explanation is that LCP believes that vertically isolating market

rate units in a high rise apart from the balance of the mixed‐income development is necessary to attract

renters. The Gautreaux decision prohibits the CHA from placing public housing units with children above

the third floor of any building. The court has granted previous waivers to this restriction, but only for low

and mid‐rise buildings. A proposal to place public housing units in a high rise would be unprecedented

since the Gautreaux decision and the resulting court supervision and undoubtedly attract both national

and international scorn given Chicago’s infamously poor track record with such housing.

Implications for Ultimate Potential Density—The overall Lathrop Homes redevelopment project may

fail to meet developer and CHA expectations, a circumstance that has been the rule rather than the

exception in recent years. If the planned market rate units fall short, the overall site density may need to

be adjusted downward in order to maintain the desired ratio of market versus affordable and public

housing units. In this highly likely chain of events, the site would feature an unnecessary high‐rise

residential tower and the timing of the renovation of the existing buildings will be delayed, perhaps

indefinitely, due to the inability to absorb the planned market rate residential units on the overall site.

Detriment to Historic Character of the Overall Site— In the unfortunate scenario where a public

housing high rise is approved and constructed, it will be the dominant permanent feature of the site,

overshadowing the

two

and

three

‐story

walkup

character

of

the

historic

development

and

the

Great

Lawn. Comments by City of Chicago staff and historic preservation professionals involved in the Section

106 process stressed significant concerns over the detrimental effects of proposed building heights on

the historic character of the site. The City’s Historic Preservation Division referred to the adverse effects

proposed high‐rise towers would have on the historic character of the site,

“The addition of high‐rise towers also intrudes upon the low ‐rise character of Lathrop Homes and

its surrounding neighborhood.”

These comments from City of Chicago staff recognize the detrimental intrusion a high‐rise would have,

not

only

on

the

historic

character

of

the

site

itself,

but

also

on

the

surrounding

residential

neighborhoods. This detriment to the historic character of the site places in peril the ability to qualify for

the historic tax credits that the CHA and LCP have repeatedly said are essential to the financial feasibility

of the entire development.



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Effects of Design on Safety, Security, and Sense of Community There exists a significant volume of empirical research and data identifying high‐rise residential towers

in the context of public housing as a contributing factor in breakdowns in societal norms, high rates of

vandalism and lawlessness, and various other negative effects. Jane Jacobs, in her 1961 book, The Death

and Life

of

Great

American

Cities

detailed

the

various

ways

in

which

high

‐rise

public

housing

created

unhealthy environments for residents. More recently, the US Department of Housing and Economic

Development (HUD) published a 1996 paper entitled, “Creating Defensible Space,” which details the

shortcomings of high‐rise development relative to crime prevention and public safety. Building upon the

theory of crime prevention through environmental design, the paper describes the ways that high‐rise

development inhibits the understanding among families concerning acceptable behavior and their

ability to enforce adherence to such standards,

“A family’s claim to a territory diminishes proportionally as the number of families who share

that claim increases. The larger the number of people who share a territory, the less each

individual feels rights to it. Therefore, with only a few families sharing an area, whether it be the

interior circulation areas of a building or the grounds outside, it is relatively easy for an informal

understanding to be reached among the families as to what constitutes acceptable usage. When

the numbers increase, the opportunity for reaching such an implicit understanding diminishes to

the point that no usage other than walking through the area is really possible, but any use is

permissible. The larger the number of people who share a communal space, the more difficult it

is for people to identify it as theirs or to feel they have a right to control or determine the activity

taking place within it. It is easier for outsiders to gain access to and linger in the interior areas of

a building shared by 24 to 100 families than it is in a building shared by 6 to 12 families.”

Beginning in 1992, the HOPE VI Program was developed as a result of recommendations by the National

Commission on

Severely

Distressed

Public

Housing,

which

was

charged

with

proposing

a national

action

plan to eradicate severely distressed public housing. The following is one of the Hope VI Program’s five

key objectives:

“Changing the physical shape of public housing by demolishing the worst developments—high‐

rises and barracks‐style apartments—and replacing them with garden‐style apartments or

townhouses that become part of their surrounding communities.”

LCP’s plan for the southern portion of the Lathrop site inexplicably proposes to do the exact opposite of

this recommendation, by replacing low‐rise units with those in a high rise.

Conclusion I remain adamantly opposed to a high rise on the Lathrop site. Lathrop Homes residents and the

surrounding neighborhood community organizations and nearby residents who have been concerned

and frustrated with the planning process to date share this view. Before LCP moves any closer to

submitting a planned unit development application for the site, I am requesting an opportunity to meet

with you to discuss these concerns in detail. I appreciate your consideration of my views on this



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important public housing redevelopment plan and look forward to discussing them with you in detail

soon.

Sincerely,

Scott Waguespack

Alderman 32nd Ward

City of Chicago

Cc: Mayor Rahm Emanuel

1st Ward Alderman Proco Joe Moreno

Daniel Levin, Chairman of The Habitat Company

Andrew

J.

Mooney,

Commissioner,

Department

of

Housing

and

Economic

Development

Eleanor Gorski, Assistant Commissioner, Landmarks Division

Patricia Scudiero, Zoning Administrator, Department of Housing and Economic Development

Mike Jackson, Chief Architect, Illinois Historic Preservation Agency

Anne E. Haaker, Deputy State Historic Preservation Officer, Illinois Historic Preservation Agency

Erik Sandstedt, PE General Engineer, U.S. Department of Housing and Urban Development

Robert Whitfield, Attorney for the Central Advisory Council

Lathrop Community Partners



November 9,

2012

Charles Woodyard

CEO

Chicago Housing Authority

60 E Van Buren

Chicago, IL 60605

In August 2012 Lathrop Community Partners (LCP), the development team selected to implement

redevelopment of

Julia

C.

Lathrop

Homes,

released

three

development

scenarios

for

the

site.

After

a

thorough review of these three development scenarios, I have concluded that they are lacking in several

key respects, including:

Excessive and unprecedented density,

Lack of meaningful public participation in the planning process,

Failure of any scenario to preserve the historic character of the site, and

Failure to meet CHA’s goal of LEED ND platinum or gold certification.

The primary concern, shared by each of the undersigned neighborhood community organizations, is the

unprecedented and inappropriate level of density of up to 1,600 units. I will not accept the premise that

revitalization of

Lathrop

Homes

should

be

accomplished

primarily

through

excessively

dense

high

‐rise

residential development, regardless of whether these units are market rate or affordable. This approach

is fundamentally flawed because it attempts to solve one problem, segregated public housing, by

replacing it with another equally damaging problem, excessive density. In so doing, LCP demonstrates a

lack of concern for the implications of the plan for Lathrop on the long term health and vitality of the

surrounding neighborhoods.

The Chicago Housing Authority (CHA) selected LCP after issuing a Request for Qualifications (RFQ) on

January 7, 2010. This RFQ detailed some very specific expectations for the scope of the proposed

redevelopment. It is particularly disturbing that the LCP plans do not follow the parameters of the RFQ,

which were

developed

in

extensive

consultation

with

elected

officials,

neighborhood

representatives,

and Lathrop residents. This RFQ describes the redevelopment scope as,

“Approximately 800‐1,200 units of market quality, new and/or rehabilitated mixed ‐

income housing, both ownership and rental, approximately 1/3 of which must be public

housing.”



Page 2 of 5

None of the three proposed development scenarios falls within these specifications with respect to

density—the number of residential units—or the proportion of public housing units.

I appreciate the willingness of you and other senior CHA staff to meet with myself and Alderman

Moreno recently to discuss these concerns. My objective now is to work with the CHA to reintroduce

the public

participation

that

the

RFQ

stressed—a

necessary

element

absent

over

the

past

ten

months.

I

am under no illusion that it will be easy to reach the appropriate balance among the varied interests at

play in developing a plan for Lathrop. However, in my experience when communities have a meaningful

voice in land use planning decisions, they demonstrate a remarkable capacity for the type of informed

compromise necessary to facilitate true progress.

The following points elaborate on the primary concerns I and our neighborhood community

organizations have with both the proposed development scenarios and the process that led to their

creation.

Density—There are no objective planning principles that support the proposed level of density at this

site. The

proposed

scenarios

are

completely

inconsistent

with

the

context

and

character

of

the

surrounding development. The levels of density LCP is proposing, up to 33 percent in excess of the

amount called for in the RFQ, and the associated building heights of up to 28 stories, are only

appropriate in or very nearby dense urban cores and close to transit hubs. The intersection of Damen /

Diversey / Clybourn has neither the transit service nor the wealth of nearby services, amenities, and

attractions essential to make high‐rise residential development livable and feasible. It is no accident that

the proposed density is well in excess of anything north of North Avenue and off of the Lakefront.

CHA’s stated goal of integrating the site with its surrounding neighborhoods will not be practical unless

the density and scale of the proposed structures is compatible with the residential areas that border the

site. The

objective

of

increasing

linkages

between

the

site

and

its

surroundings

is

unachievable

so

long

as building heights reminiscent of the high rises the CHA has recently torn down elsewhere dominate

the plan. As a community we must demand better planning than a revival of the Tower in the Park style

of isolated groups of high‐rise residential towers, which these scenarios represent. This style of

development amounts to a vertical suburb that isolates its residents, rather than a pedestrian‐oriented,

interesting urban neighborhood capable of complementing its surroundings.

We have seen the devastating effects of consolidating public housing units in high rise towers. The CHA,

in consultation with its court appointed receiver, has demolished these towers and replaced them with

predominately low to mid‐rise units that resemble the scale of the existing buildings at Lathrop. It defies

explanation

that,

just

as

the

CHA

is

emerging

from

receivership,

it

would

propose

to

reverse

this

trend

by replacing the neighborhood oriented two and three‐story walkups at Lathrop with high rise and mid

rise towers.

The area’s transportation network simply cannot accommodate anywhere near 1,600 units without

slipping inexorably into gridlock given the lack of high‐capacity, fixed‐route transit service to the site.

The over 2,000 cars that would be accessing the site on a daily basis associated with the residential units

alone, not counting the traffic associated with up to 70,000 square feet of automobile‐oriented retail,



Page 3 of 5

would easily overwhelm the surrounding street network. Existing congestion in this area is so severe

that the City, working in conjunction with my office, is currently planning to invest $36 million to

improve the Damen / Elston / Fullerton intersection just on the other side of the Damen Avenue bridge.

The traffic volume generated by these proposed scenarios would override the mitigation of congestion

this investment would otherwise achieve.

Process—The CHA’s RFQ detailed requirements for a vigorous, community based planning process. The

RFQ stated that the successful candidate should possess:

“demonstrated ability to manage an open, public planning process with a wide

range of participants.”

LCP held an initial round of three meetings billed as workshops to provide the public with background

necessary to participate in a series of public design charrettes. However, LCP scrapped the charrettes

without explanation. Over the past ten months there have been no opportunities for public input as LCP

developed the three scenarios. It follows that the scenarios are devoid of any evidence that key

concerns of

surrounding

residents

were

incorporated

into

the

plans.

Preservation—Julia C. Lathrop Homes, the first federal public housing development in Chicago, is on the

National Register of Historic Places. Section 106 of the National Historic Preservation Act of 1966 (NHPA)

requires Federal agencies to take into account the effects of their undertakings on such historic

properties. These regulations highlight the important role of public input in the Section 106 process,

“Public involvement is a key ingredient in successful Section 106 consultation, and the

views of the public should be solicited and considered throughout the process.”

Outside the initial series of interviews at the very outset of their contract with the CHA, LCP has failed to

solicit any

public

input

on

the

historic

characteristics

of

Lathrop

Homes.

LCP conceded when presenting the three scenarios to the working group that none of them would be

eligible for federal historic tax credits because of their inability to sufficiently preserve the historic

content and character of Lathrop. Abandoning any possibility of attaining historic tax credits without any

opportunity for public involvement is the antithesis of the spirit of Section 106, and the process

described in the CHA’s RFQ for Lathrop. Instead, LCP is proposing that the project receive $30 million or

more in public subsidies from the establishment of a new tax increment financing district.

Nearby residents express an understandable desire to reinvent the physical context and character of the

site

to

remove

a

stigma

caused

by

decades

of

CHA

neglect.

Preservation

advocates

have

fought

for

preserving as many of the existing buildings as possible. The existing two‐story townhomes and three‐

story walk‐ups complement the surrounding neighborhoods exceedingly well in terms of their height

and building scale. However, there is no question that the existing buildings will require extensive

renovations to bring them up to modern standards in terms of room sizes and amenities.

Preservation of a site such as Lathrop Homes is a complex issue. I am aware that many of the nearby

neighborhood organizations, and my constituents who comprise their membership, have disparate



Page 4 of 5

views on the extent to which the existing buildings can or should be preserved. However, there is no

disputing the historic importance of Lathrop. I will not accept that decisions about preservation should

be made by LCP in isolation. I have no doubt that a vigorous public discussion about the disposition of

the existing buildings will be challenging. However, rather than accepting the notion that these interests

cannot be reconciled, the decision about the future of the existing structures must revolve around what

is best

for

both

existing

residents

and

surrounding

neighborhoods.

Sustainability—The RFQ cites LEED for Neighborhood Development (LEED ND) Gold or Platinum

Certification as a key goal of the redevelopment plan. The LEED ND Rating System integrates the

principles of smart growth, urbanism and green building into the first national system for neighborhood

design. Each of the three LCP scenarios abandons key elements of the LEED principles.

A review of the LEED ND guidelines quickly reveals that one of the primary challenges for the site to earn

credits is its lack of proximity to transit. The high level of density reflected in the scenarios, despite the

lack of this transit access, makes it difficult to overcome this disadvantage with other sustainable design

elements. Other credits the site could qualify for, such as a significant influence on walkability and

connectivity, are overwhelmed by the effort to cram unreasonable amounts of residential units, retail

space, and parking on the site.

Next Steps As Alderman of the 32nd Ward I had an obligation to share the information I received on these

development scenarios with my constituents so that I could work in concert with them to initiate a

coordinated response to the unreasonable and damaging elements in these plans before it was too late.

LCP

stated

in

its

presentation

of

these

scenarios

that

it

was

going

to

finalize

the

planning

process

by

February. Delaying the presentation of these plans to the public, for whatever reasons, between August

and November with a goal of finalizing the plans by February is unacceptable. Moving forward, I

anticipate working with CHA staff and LCP to help recalibrate the levels of density, building heights,

retail space, and parking to levels that are capable of complementing, rather than overwhelming, the

surrounding neighborhoods. I appreciate the attention of you and your staff to these serious concerns

over the future of the Lathrop Homes Community.

The following neighborhood community organizations have signed onto this letter in support of the

concerns over the course of the planning process and the results to date:

Hamlin Park

Neighbors

Executive

Board

Roscoe Village Neighbors

West Lakeview Neighbors Association

South Lakeview Neighbors



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West DePaul Neighborhood Association

Wrightwood Neighbors Association

Sheffield Neighborhood Association

Bucktown Community

Organization

Wicker Park Committee

Ranch Triangle Association

Preservation Chicago

Logan Square Preservation

LEED Council/North Branch Works

Cc: Mayor Rahm Emanuel

1st Ward Alderman Proco Joe Moreno

Daniel Levin, Chairman of The Habitat Company

Andrew J. Mooney, Commissioner, Department of Housing and Economic Development

Eleanor Gorski, Assistant Commissioner, Landmarks Division

Patricia Scudiero, Zoning Administrator, Department of Housing and Economic Development

Mike Jackson, Chief Architect, Illinois Historic Preservation Agency

Robert Whitfield, Attorney for the Central Advisory Council

Lathrop Community Partners

Alderman Scott Waguespack Lathrop Letter to CHA 012714

Documents

Transcript of Alderman Scott Waguespack Lathrop Letter to CHA 012714