Chicago District Header Image


Home > Missions > Regulatory > Public Notices

Public Notices by Year

Bookmark and Share Email Print


Posted: 11/21/2017

Expiration date: 12/14/2017



Section 106 Historic Property Review

110 N. Wacker Drive


U.S. Army Corps of Engineers

Chicago District



Public Notice/Application Number: LRC-2017-583


Comment Period BEGINS:  November 21, 2017

Comment Period Expires:  December 14, 2017




Riverside Investment Development                      The Howard Hughes Corporation

100 N. Riverside Plaza, Suite 2150                       13355 Noel Road, Suite 2200

Chicago, IL  60606                                                Dallas, TX  75240


Proposed Action

Applicants propose to demolish the existing structure on the project site (the General Growth Building, formerly known as the Morton Salt Building) as part of redevelopment of the site.  The Chicago District has determined that the proposed demolition of the General Growth Building constitutes an adverse effect under Section 106 of the Archeological and Historic Preservation Act of 1974.  This notice is part of the Section 106 process to resolve the adverse effect.  The Chicago District is soliciting comments on the proposed action and potential mitigation.  A detailed description of this proposed project is provided on page 2 of this notice.


Location of Proposed Action 

110 North Wacker Drive in the City of Chicago, Cook County, Illinois (SE Quarter of Section 9, Township 39 N, Range 14 E Latitude 41.88378, Longitude -87.63744).  See attached location map.


Interested parties are hereby notified that comments on the proposed action and potential mitigation are requested from the public. You are invited to provide your comments by December 14, 2017 on the proposed work, which will become part of the record and will be considered in the decision.  This project is being reviewed under Section 106 of the Archeological and Historic Preservation Act of 1974 [see 36 CFR 800].

Electronic comments may be sent to the project manager at


Written comments may be mailed to:


U.S. Army Corps of Engineers

Chicago District, Regulatory Branch

Attn: LRC-2017-00583, Michael Murphy

231 South LaSalle Street, Suite 1500

Chicago, Illinois  60604-1437


It should be noted that ALL comments received by this office (via hard copy or electronic) will only be accepted with the full name and address, and email address, if available, of the individual commenting, and must be received by the close of the public notice period.



Project Description


Applicants are proposing to redevelop the property at 110 N Wacker Drive in the City of Chicago, currently occupied by the General Growth Building (formerly known as the Morton Salt Building).  The proposed development requires the demolition of the current structure on the project site.  The Chicago District received a permit application for the construction of a new stormwater outfall structure in the Chicago River to service the new building on the site.  The proposed stormwater outfall will require review and potential authorization under Section 10 of the Rivers and Harbors Act of 1899.  Due to the need for a federal permit for the new development the Chicago District has been determined to be the lead federal agency for this project under the provisions of Section 106.


In August of 2017 the Illinois Historic Preservation Agency (IHPA) determined (see attached) that the General Growth Building was eligible for listing on the National Register of Historic Places under Criterion C for architecture, making it an historic property under the definitions of Section 106.  Subsequently the Chicago District determined that the proposed project will have an adverse effect on a historic property as defined in 36 CFR 800.5 (see attached).  The IHPA concurred with this determination (see attached).


The Chicago District is, as the lead federal agency, required under Section 106 to explore options avoid, minimize, or mitigate the adverse effects to the historic property.  Toward that end the District has issued this Public Notice to inform all interested parties of the nature of the historic property, the proposed activity, and proposed mitigation to minimize the adverse effect on the property through public comments on the proposed activity and mitigation and an invitation to participate in the Section 106 process for this site.




The General Growth Building (formerly the Morton Salt Building) at 110 N. Wacker Drive is a five-story, glass-and-steel office building with two penthouse floors.  It is prominently located on Wacker Drive and occupies a full-block site between Randolph and Washington streets along the Chicago River (see location map).  An example of Mid-Century Modern architecture, the building was erected as the corporate headquarters of the Morton Salt Company, one of the city’s oldest companies and the nation’s largest producer of salt at that time.  The $4 million building was completed in 1958 and designed by the architecture firm Graham, Anderson, Probst and White.  Current photographs of the building are attached to this notice.


The Morton Salt Building was erected with reinforced concrete slab construction and the exterior façade includes extensive use of stainless steel cladding at the slab edge spandrel conditions.  Its two-story lobby featured stainless steel glazed storefronts, and more than 4,500 yards of fiberglass were used for the beige, orange, green, and yellow window drapes of the building.  Plastic paneling, containing mosaic glass and copper wire designs, were used to line the main corridors.  Salt industry operations were the theme for photomurals, displays of wood blocks and etchings, and a selection of contemporary paintings on display.  The interiors of the building were designed by A. Dudley Kelly.


The building was designed by Graham, Anderson, Probst and White, a Chicago-based firm with a nationwide clientele that it inherited as the successor to D.H. Burnham & Company.  During the 1920s, the Graham firm moved away from its predecessor’s repertoire of Beaux Arts styled bank and commercial buildings to offer designs that included stripped classicism, vertical Gothic, and restrained Art Deco.  Such stylistic adaptability was demonstrated in the Civic Opera Building, which is located across Washington Street from the 110 N. Wacker Building, and which exhibits a masterful blend of luxurious classical and Art Deco motifs,


The Morton Salt Company occupied this building for nearly a quarter-century, during which time it expanded into new regions and new products and changed its name several times.  By 1990, most of Morton International’s $3 billion in annual revenues came from the sales of airbags and specialty chemicals.  In that year, the company relocated to a new skyscraper nearby.  Its former headquarters building remained vacant until 1997, when it was purchased by General Growth Properties, which undertook a complete interior renovation.  The building is currently owned by the Howard Hughes Corporation.





The applicants propose to develop a new high-rise office building on the project site (renderings and site plan attached).  The proposed development would require the demolition of the General Growth Building as a first step in construction of the proposed building.  The applicant has stated that they can not avoid the demolition of the General Growth Building while meeting the site design requirements of the City of Chicago and the structural needs of the new construction. The proposed project design has been reviewed and approved by the City of Chicago and the applicants intend to begin construction as soon as January, 2018 and the major tenants for the new building have been identified.


The Chicago District Reviewed project alternatives and determined that all alternatives that meet the stated goal of constructing a high-rise office building require the demolition of the General Growth Building.  Only under a no action alternative could the current structure be spared, but that alternative does not fulfill the applicant’s purpose of constructing a higher density commercial structure.





The applicants have proposed to mitigate for the adverse effect on the General Growth Building by conducting a survey of the structure and documenting it using the Historic Illinois Building Survey (HIBS) methodology under the auspices of the Illinois Historic Preservation Agency.  When completed the HIBS report would be made available to the public and filed with the City of Chicago and the Illinois State Museum.


The Chicago District would like to gather comments on the proposed mitigation plan and any suggestions for alternative or supplemental mitigation.  The District would like feedback from the public as to the adequacy of the proposed mitigation in kind and quantity and is looking for any potential mitigation measures that are proportionate to the proposed impact and can be implemented over a reasonable time frame and cost.


Section 106 provides for the implementation of a Memorandum of Agreement (MOA) for mitigation of adverse effects to historic properties.  The Chicago District will curate a list of proposed mitigation options submitted as part of this public notice process to be included in a draft Memorandum of Agreement.  This draft MOA will be presented to a meeting of signatory and consulting parties on December 15, 2017.  This goal of this meeting will be to write a final MOA to be implemented by the applicant as mitigation for the adverse impacts to the General Growth Building.


The signatory parties to the Section 106 MOA are anticipated to be the Chicago District, IHPA and the applicants.  Consulting parties to the MOA have not yet been determined.  If you would like to be a consulting party to this MOA please let the District know who you are and why you should be included as a consulting party to this Section 106 MOA.  Please submit your request by email to  The Draft MOA Meeting will be held in downtown Chicago on December 15, 2017



It should be noted that materials submitted as part of the permit application become part of the public record and are thus available to the general public under the procedures of the Freedom of Information Act (FOIA).  Individuals may submit a written request to obtain materials under FOIA or make an appointment to view the project file at the Chicago District Corps of Engineers Office of Counsel.


Interested parties wishing to comment on the proposed activity must do so in writing no later than December 14, 2017.  It is presumed that all parties receiving this notice will wish to respond to this public notice;  therefore, a lack of response will be interpreted as meaning that there is no objection to the project as described.


This public notice is not a paid advertisement and is for public information only.  Issuance of this notice does not imply Corps of Engineers endorsement of the project as described.


If you have any questions, please contact Michael Murphy of my staff by telephone at (312) 846-5538, or email at  It should be noted that ALL comments received by this office (via hard copy or electronic) will only be accepted with the full name and address of the individual commenting.








Kathleen G. Chernich

Chief, East Section

Regulatory Branch




Mailing List

To receive Regulatory Public Notice emails, please specify for Illinois or Indiana, and Contact:

Commenting on Public Notices

To comment on a public notice, please make sure that you send it directly to the project manager whose contact information is listed within the notice (either via paper mail or electornic mail).  You must also include your full name and address, as well as the project number.  Please include your email address if you have one.  Thank you.