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On January 16, 2020, the City of Chicago and the Federal Highway Administration (FHWA) released a revised with a laundry list of negative impacts—technically known as “adverse effects”—that the Obama Presidential Center (OPC) would have on the Olmsted-designed Jackson Park and Midway Plaisance. The assessment is part of a required federal review pursuant to , triggered in part because the parks are listed in the National Register of Historic Places. Under normal circumstances, the FHWA, the lead federal agency in the OPC review process, would now seek to avoid, minimize, or mitigate those adverse effects. But instead, the agency is creatively applying a Trump-era policy position—as yet unapproved changes to the National Environmental Policy Act, noted below—to ignore the OPC’s harm to the parkland. Between the lines of the otherwise wonkish and technical federal assessment is the stunning irony that the OPC’s proponents are relying on the Trump Administration’s pro-deregulatory posture to get their project built. Their cause is being aided by Fred Wagner, the former chief counsel of the FHWA during Obama’s presidency, whom the Obama Foundation has hired to help navigate the federal reviews.  

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The assessment states that the OPC would harm “specific elements of the historic district,” further impacting “how Jackson Park and the Midway Plaisance reflect conscious decisions made by the Olmsted firm in determining spatial organization, relationships between major features, views, patterns of circulation, arrangement of vegetation, and hierarchy of buildings and other constructed features.”

In addition, the OPC would have an adverse effect on the Chicago Parks and Boulevard System Historic District because it will “alter, directly and indirectly, characteristics of one portion of the district that qualify it for inclusion in the National Register.” Notably, the stark, monolithic OPC tower would also diminis