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Feedback and Recommendations for the Chicago Casino Proposals Along the North and South Branch

To: Chicago Casino Contact and Feedback

From:  River Ecology and Governance Task Force Development Review Working Group

Date:   May 3, 2022

Initiated in late 2019, The River Ecology and Governance Task Force is composed of local government agencies, civic and community organizations that collaborate on initiatives to support coordination, management, planning, and stewardship for Chicago’s rivers. As part of this Task Force, the group convenes to review new developments that are proposed in and along Chicago’s waterways. This working group reviews projects guided by the Chicago River Design Guidelines and provides additional feedback on ways the development could be improved to increase the health and vitality of the city’s rivers and its riverfront communities. These actionable recommendations are transmitted to City staff through the Department of Planning and Development, who typically partners on these meetings, as well as the development teams.

Chicago Casino Proposals along the North and South Branch

In March of 2021 the City of Chicago released a Casino Evaluation Report which listed three finalists; Bally’s Tribune, Rivers 78, and Hard Rock Chicago. Of the three finalists, two are proposed to be located on parts of the Chicago River: Bally’s Tribune along the North Branch between Chicago and North Avenue and Rivers 78 along the South Branch south of Roosevelt Road. Both sites would be prominent along their respective branches of the river, each including significant portions of new riverwalk, other river edge amenities, and high-rise mixed-use development. A Chicago Casino and entertainment complex represents a significant opportunity to make a bold statement about how new development, recreation, and robust riverine and upland habitats can coexist, independent of which proposal is ultimately selected as the finalist.

Task Force members acknowledge that the casino selection process is ongoing and presentations and designs shared to date by the development teams do not include designs fully aligned with the River Design Guidelines’ Menu of Improvements or detailed site/landscape plans for the river’s edge. Following is a non-exhaustive list of broad items for the development teams and City staff to incorporate as they continue to move through the selection process for both of the projects. We encourage the teams to also refer to the River Edge Design Guidelines for further direction.

Task Force members recommend including native flora-oriented landscape elements to incorporate a more naturalized edge. As either proposal would include half a mile of new riverwalk, the casino sites present an opportunity to marry an urban edge with a naturalized landscape. We recognize that a fully natural sloped edge may not be feasible in some areas, but we encourage the development teams to consider where a partial naturalized river edge could work together with a lowered seawall, and pursue design strategies that can be used to decrease the amount of hardscape & other impermeable surfaces. The South Bank development on Harrison Street along the South Branch is a good precedent for this approach. The elevated walkway, with dense landscape below, is an example of the type of site treatment that allows for people and habitat to share the same space. As the proposals’ landscape design evolves they should seek to create a more naturalized layout and plant selection in conjunction with the proposed in accordance with the River Edge Design Guidelines.

Task Force members recommend providing broad swaths of connected green space along the river’s edge, rather than splitting up green space into smaller sites, even if they total the same amount of area. Each proposal shows limited green space along the river’s edge with additional small parks and plazas interspersed throughout each site. Not all open space is created equal, even if the total amount remains consistent. The proposals should include enough green space of a size to match the density and activity they hope to bring to the site and avoid shifting the burden onto existing greenspace in adjacent communities. Each proposal would need to go through a new Planned Development approval process, and the amount and location of green and open spaces required should be reconsidered with this in mind. Pocket parks and promenades provide some relief in urban areas, but in relation to the scale of these sites,  larger acreage, contiguous open green spaces are more welcoming for members of the public and also valuable as ecological and natural habitat assets as described in the River Design Guidelines.

The river adjacent programming for both proposals appears primarily focused on active uses over passive uses, with a significant amount of space reserved for hardscape. The scale of the sites provide an opportunity to balance passive and active uses, and avoid over commercialization / privatization of the riverfront There should be natural and contemplative spaces available to users that are not patronizing a casino or related businesses. Highly prescribed active uses restrict accessibility for non-conforming users, limit flexibility, and tend to reduce opportunities for natural habitat creation and stormwater management. One strategy for addressing these concerns would be to create circulation flow diagrams that consider how different users will move through each site and where active uses can give way to passive ones.

Site development at this scale should exceed the 30’ setback required by the River Design Guidelines, especially where the riverwalk is expected to support passive and active activities, dining, shopping, and pedestrian and bicycle movement.

The Task Force encourages the development team to think creatively about new habitat creation. Acknowledging that the potential for each proposal to include instream habitat is limited due to active river traffic; on-site strategies could include creating microhabitats throughout the site, such as dense clusters of multi-layered vegetation, incorporating trees of a variety of species, and creating terraces and shelves along vertical sea-walls. More extensive strategies could also include areas of double seawall with cuts for inflow and outlet allowing for river edge shallows that provide marshy ecosystems outside of the active waterway where r naturally sloping shorelines are not feasible. This is also a valuable opportunity to develop habitats that support shorebirds at a key point along the river. Chicago is one of the nation’s busiest cities for migratory birds, and several high priority habitats are located along the lakefront and rivers. The Bally’s Tribune site is especially susceptible to bird strikes because of its location along existing flyways and wider continuous building facades. The proposals should incorporate effective migratory landbird habitat into its riverfront designs as well as protect migratory birds from harm by implementing bird friendly facade treatments.

An often overlooked aspect of public space accessibility is community perception of how welcoming, inviting and inclusive the spaces are. Design decisions that may lead to public spaces that are ‘public’ in name only should be avoided. The development team should carefully consider how public spaces throughout the site interface with one another; large open spaces with the riverwalk, the riverwalk with the Wild Mile and the proposed pedestrian bridge (in the case of Bally’s Tribune), the riverwalk with existing bike and pedestrian infrastructure, etc. The development teams should ask the question ‘How would a member of the public, who is not visiting the entertainment complex, or does not live or work in the adjacent buildings, visit and benefit from the public spaces?’

Multi-use paths and public areas that border them should be clearly marked with signage to designate and welcome people into the space. As noted above, circulation plans and diagrams would be a valuable first step in working towards these accessibility goals. Public rights to new open space, including use hours, should be codified in the Host Community Agreement (HCA). When the HCA drafting is underway, maintenance and stormwater management should also be included, along with parameters for oversight and accountability if public spaces are not operating as promised.

Public programming that serves and seeks to educate the wider community, not just the residents of the buildings, should be incorporated, with content created in partnership with educational institutions, community-based organizations and resident groups from nearby. Whenever possible, riverfront sites and signage should include efforts to educate the public about the river itself, including ongoing efforts to monitor water quality and chemistry and habitat recovery.

We acknowledge how early the Rivers 78 and Bally’s Chicago teams are in their site design and consideration of how each development would interface with their respective areas of the Chicago River. We again urge the development teams to consider the spirit of the Riverfront Design Guidelines, and believe that implementing the above recommendations can be mutually beneficial for the development team, community residents, and the river itself. Along with the recommendations above, it is important for City officials not to overlook the possibility of over privatization of the river edge and long term management of privately owned public space when considering any of the finalist proposals. We welcome the opportunity for feedback, offer our services in the future, and look forward to your responses and future collaboration.

Thank you,

River Ecology Governance Task Force

Development Review Group