The Century and Consumers Buildings: Their Complicated Saga and the Precedent They Might Set

Chicago’s State Street houses a number of America’s earliest and most historic skyscrapers. These skyscrapers, recognized as the “Chicago School” of architecture, represent the creativity of engineers and architects working in steel frame construction to both maximize light through distinctive window patterns, and to draw the public into the buildings (and the services they provided) through unique applications of Classical ornamentation. While the architecture of these buildings is well regarded, it is their adaptability that has proven to be a true point of character. While built to house commercial offices, they have proven to accommodate modern uses—an architecture of the past that fits the future city. The Century and Consumers Buildings, owned by the federal government since the early turn of the twenty-first century, are a part of this creative matrix. Yet, the federal government, in an act of inconceivable uncreativity that disregards movements towards adaptive reuse and rehabilitation, intends to demolish them.

In 2005, the United States General Services Administration (GSA), the federal agency tasked with managing federal property, purchased the Century and Consumers Buildings. The acquisition, the GSA stated, would provide the GSA with additional office space in the Loop, and would provide a safety buffer for the neighboring Everett McKinley Dirksen US Courthouse.¹

Nine years earlier, a nine-block stretch of State Street from Ida B. Wells Drive (then Congress Parkway) to the south and Randolph Street to the north, within which the Century and Consumers Buildings were located between Adams and Jackson, had been dramatically reconfigured after a pedestrian mall plan in 1979 failed to deliver on revitalizing the downtown shopping district. During the first half of the twentieth century, State Street was a thriving commercial, retail, and entertainment thoroughfare, lined with department stores like Woolworth’s and Marshall Fields, and anchored by theaters and late-night restaurants. Yet, by the late 1970s, the quality of nightlife and retail on State Street had diminished as it competed for attention with suburban shopping malls. “Major blight has been inflicted on the street by fast food restaurants and junky stores which proclaim their presence with signs, materials, and colors in screamingly bad taste,” wrote Chicago Tribune architecture critic Paul Gapp in 1978.²

The City of Chicago believed it had a solution in pedestrianizing State Street. Traffic was narrowed to two lanes, only accessible by city buses and emergency vehicles. Sidewalks were widened from 22 feet to 40 feet, with space given to massive bus shelters and landscaped mini plazas. Instead of revitalizing retail and entertainment, the pedestrian mall made State Street a desolate cavern of concrete and bus exhaust. Failing to do what it intended, State Street’s pedestrian mall was redesigned in 1996.

The renovation of State Street at the turn of the new millennium signaled a new modern future for Chicago’s Loop and served to be the catalyst for development that the 1979 renovation couldn’t achieve. By 2005, State Street was again a vibrant commercial and retail thoroughfare, and it was also Chicago’s newest residential neighborhood. Citizens were working, playing, shopping, learning, and now living on State Street. New creative uses were being developed for old buildings. The Reliance Building, a late nineteenth-century office building once marked for demolition, had been transformed into a restaurant and boutique hotel in 2000, becoming a blueprint for adaptive reuse projects citywide and creating a halo effect on the block. A new theater district was created through the restoration of the Chicago Theatre and Oriental (now the James M. Nederlander) Theatre. Colleges like DePaul University and the School of the Art Institute of Chicago had made State Street their campus at the beginning of the decade. Two aptly named infrastructure projects, Millennium Park and Millennium Station, had just opened to the public in 2004 and 2005 respectively, after years of anticipation.

At the time of the GSA’s acquisition of the Century Building, located at 202 South State Street, and the Consumers Building, located at 220 South State Street, both buildings were poised to join that urban ecosystem and add to the vibrancy of the streetscape between Jackson Boulevard and Adams Street, much like the restoration of the Reliance Building had done five years earlier. Across the street, a former 1920s Woolworth store on the block housed a Foot Locker and Lady Foot Locker. A top grossing McDonalds was located within the 1936 Streamline Modern Benson & Rixon Building, next door to the Consumers Building. Roberto’s, a menswear shop, sold flamboyant suits out of a curving glass storefront between the Century and Consumers Buildings. DePaul University was set to renovate the former Lytton & Sons department store into the College of Communication.

The 2005 acquisition of the Century and Consumers Buildings was positioned to extend the legacy of the General Services Administration’s stewardship of the built environment. The GSA owns and leases over 8,000 buildings in more than 2,200 communities nationwide, including historic buildings representing a broad timeline of American architecture, from the early nineteenth century to the Federal Modernism of the 1970s.³ The Consumers Building was acquired first, then the GSA moved to acquire the Century Building after a plan to convert the building into a boutique hotel failed and a lender had foreclosed on the property. The GSA then acquired three additional buildings on the block: the Benson & Rixon Building at 230 South State Street, and the two buildings between the Century and Consumers Buildings: 212 South State Street and 214 South State Street. Yet, as State Street continued to thrive, all four buildings, almost half of the block, remained unoccupied.

While the GSA stated that the buildings were acquired to form a security buffer around the Dirksen and that they would be used as office space, the agency eventually began to look for other ways to use them, including redevelopment by a private developer. In 2014, the GSA released a request for information asking for ideas from developers and other interested parties. In 2016, Crain’s Chicago Business reported that the GSA had decided to dispose of all four of the buildings.⁴ Federal agencies, then local and state governments, were given the opportunity to acquire them prior to the properties going out for public bid. In May 2017, the City of Chicago, on behalf of the GSA, released a request for proposals, looking to find a qualified private developer to renovate the properties.

In June 2017, CA Ventures, a real estate developer with experience converting historic buildings into housing, agreed to purchase all four properties—the Century and Consumers Buildings, as well as 212 and 214 South State Street.⁵ The City of Chicago would purchase the buildings from the federal government and would then sell them to CA Ventures. The $141 million redevelopment would transform the Consumers Building into 270 micro apartments, the Century Building into 159 studio and one-bedroom apartments, and incorporate 214 South State into the renovation through a newly constructed two-story building on the parcel. 212 South State Street would be demolished, with a new fifteen story building built in its place as a connected addition to the Century Building.

In July 2017, Chief US District Judge Ruben Castillo expressed concern in his State of the Court address that the renovated buildings would jeopardize courthouse security. In September 2019, the City of Chicago withdrew their support of the CA Venture plan, two and a half years into the project, citing, as Judge Castillo had, security concerns with the redevelopment plan.

“Recent assessments by the Federal Bureau of Investigation, Bureau of Alcohol, Tobacco, Firearms and Explosives, and US Marshals Service, among others, found that the sale of these properties would create significant public safety vulnerabilities threatening the public servants who work in the Dirksen Courthouse and the general public who utilize the building,” then Chicago Mayor Lori Lightfoot wrote in the letter, published in the Chicago Tribune.⁶

The security assessment was not made public, and neither the City of Chicago nor the GSA provided details on the “security concerns,” or how they could be addressed. While the City stated that they would work to find an appropriate solution, the Century and Consumers Buildings entered the second decade of the twenty-first century—and the COVID-19 pandemic—without plans for renovation.

After 2020, the vibrancy of State Street that seemed to be on a continuous upswing was ravaged by the effects of the COVID-19 pandemic. “For Lease” signs on retail spaces were posted everywhere. Downtown office workers were no longer commuting, driving office vacancies as jobs went hybrid or remote. Across the street from the Century and Consumers Buildings, retail vacancy proliferated across the whole empty block.

After nearly twenty years of vacancy, the Century and Consumers Buildings continued to deteriorate, a situation of the GSA’s own making. In waiting to repurpose or dispose of the buildings, the GSA performed only basic repairs and remediation. Buildings of the age and complexity of the Century and Consumers Buildings require specialized maintenance, no matter their use status or condition, but the most effective tool against deterioration is to return buildings to use. The buildings had been mothballed, and a sidewalk canopy had been installed to prevent the terracotta, the primary façade material on both the buildings, from falling on pedestrians below. The buildings had been noted as endangered by Preservation Chicago, the citywide historic preservation nonprofit, while they continued to face an uncertain future.⁷

It was under these circumstances that an almost inconceivable plan of action for the Century and Consumers Buildings was announced. Senator Dick Durbin had secured $52 million dollars in federal money to demolish them, including 212 and 214 South State Street. “Simply put, there has been no plan put forward for private development that has adequately addressed the security risk,” Senator Durbin stated in an op-ed in the Chicago Sun-Times in 2022.⁸ Once demolished, the GSA would replace them with a landscaped secure lot.

The public broadly and completely rejected the idea that demolition was the only option. No demolition of a building (or buildings) of similar size and height had been proposed in Chicago since the razing of the Old Chicago Mercantile Exchange Building twenty years earlier, and not since the days of urban renewal had the demolition of viable buildings been funded by the federal government in this manner in Chicago.

As State Street boomed, the GSA spent an entire decade in possession of the Century and Consumers Buildings before deciding that the agency could not use them. The agency would then entertain one development option and then reject it due to “security concerns.” This same vague claim has been used without further detail habitually by the GSA from the moment the 2017 CA Ventures project had been rejected, through the federally mandated process to evaluate the plan to demolish them.

The Century Building, the northernmost of the two buildings on the corner of State and Adams, was built as a sixteen-story commercial investment property by the Buck & Rayner drug company in 1915 and designed by Holabird & Roche. The Consumers Building was built in 1913 as a twenty-one story professional office building and was designed by Mundie & Jensen. Both buildings are works of the Chicago School of Architecture and are listed on the National Register of Historic Places as properties contributing to the Loop Retail Historic District, listed in 1999.

The National Register status of the Century and Consumers Buildings, as well as the federal money appropriated to demolish them, requires the GSA to follow federal environmental and historic preservation laws. The National Environmental Policy Act (NEPA) requires federal agencies like the GSA to assess the environmental effects of their proposed actions. Section 106 of the National Historic Preservation Act (NHPA) requires federal agencies to consider the impact of their actions on historic properties. While these two processes are separate, they are often carried out together. The Section 106 process requires federal agencies to identify historic properties, assess the effects of the action on them, and then take steps to avoid, minimize, or mitigate any harm that may come. Both processes require public participation and input from those with a vested interest in historic preservation, and have culminated in a series of evaluations, public meetings, and documents explaining the impacts of demolition.

Through the NEPA process, federal agencies are required to evaluate the effects that a project may have on the natural environment, and prepare detailed written statements on these effects, referred to as Environmental Impact Statements (EIS). Within the draft version of the EIS, the GSA revealed the rigidity of their requirements for adaptive reuse through fifteen security requirements.⁹ Most notably, per the GSA, was item number two in the list of security criteria, that the properties were not to be used for short-term or long-term residential or lodging. Not only did the GSA not entertain an alternative to the 2017 plan to convert the Century and Consumers Buildings into housing, but the NEPA process, through the Environmental Impact Statement, revealed that the GSA would not entertain any future plans to do so.

In contradiction to these actions, the Biden administration launched a multi-agency initiative in October 2023 to encourage states and cities to convert more empty office buildings into housing units.¹⁰ This initiative, which calls on the GSA specifically, to “expand on its Good Neighbor Program to promote the sale of surplus federal properties that buyers could potentially redevelop for residential use,” is designed to “supercharge” the creation of new housing units, particularly near transportation hubs. Access to the Chicago Transit Authority’s (CTA) Red Line, a 24-hour, rapid transit line and the system’s busiest, is located just outside of the front door of the Consumers Building, with the rest of the CTA’s transit systems within arm’s reach.

The Advisory Council on Historic Preservation (ACHP), an independent federal agency that administers the requirements of the National Historic Preservation Act, including Section 106, released its own housing policy statement in December 2023.¹¹ The statement outlines federal agency responsibilities regarding considering housing as a part of their program planning, and specifically states that “It is the policy of the ACHP to encourage and accelerate rehabilitation of historic buildings for housing and to assist in harmonizing historic preservation and housing goals.” The policy statement continues: “The ACHP will integrate these principles into its oversight of the federal Section 106 review process and into the advice it provides to federal agencies.”

When a federally funded or permitted project has been determined to have substantial effects on historic places, the ACHP participates in the Section 106 process and provides guidance, advice, and technical assistance to federal agencies. The ACHP also has the ability to determine how thoroughly a federal agency, like the GSA, has avoided, minimized, or mitigated adverse effects on historic places as these efforts have been described through the Section 106 process. Based on their determination, the ACHP could then require a federal agency, like the GSA, to revisit those efforts and declare a different course of action.

The NEPA and Section 106 processes require federal agencies to act in good faith, and with preservation-minded solutions at the forefront of their actions. And yet, from the initial announcement that federal funds had been allocated for the demolition, the GSA has approached demolition as a matter of course, while simultaneously stating in public meetings, as required (and as expected) that they are looking into more than one outcome. This outlook is apparent from the GSA’s attitude toward providing detail on the “security concerns” that renovating the Century and Consumers Buildings raise. The GSA has been unable (or unwilling?) to provide information on what ultimately initiated the demolition: security concerns at the Dirksen Courthouse.

The Ludwig Mies van der Rohe-designed Everett McKinley Dirksen US Federal Courthouse, of which the GSA has stated they are proud to be the steward as a historic property within their portfolio, was constructed in 1964. Per the GSA’s own website, the agency installed a perimeter-wide security bollard system in 2002 in response to increased security requirements for federal properties post 9/11.¹² The exterior curtain wall was replaced in 2006 and repainted in “Miesian black paint.” In 2007, the Federal Emergency Management Association (FEMA) produced a document providing guidance against potential terrorist attacks. This guidance document emphasized that site and urban design for security should take in to consider the nature of the public realm including streets and sidewalks, and encourages planning for safety along with local programs for streetscape improvement.¹³ Included in the case studies was the Dirksen Courthouse, and that the GSA had taken a design approach that had addressed that the Dirksen Courthouse was “bounded on all sides by narrow streets and large buildings with little setback.¹⁴ In 2012, the GSA completed a $110 million dollar renovation of the courthouse, which included work to replace the heating and cooling systems in the building. The GSA has detailed guidance regarding the security of its properties, which include hardening a building’s structure and envelope, and states that, “at times, modification of the facility is the best strategy to reduce risk.”¹⁵ And yet, in the draft Environmental Impact Statement for the Century and Consumers Buildings, the GSA stated: “the ability of the federal government to retrofit the Dirksen Courthouse with countermeasures to address known security needs would be infeasible from both a construction and then cost consideration standpoint.”¹⁶

The EIS continues, “security, numerous studies by the FBI and the United States Marshals Service have demonstrated that additional countermeasures at the Dirksen Courthouse are cost prohibitive and not possible because of the design and the construction of the Dirksen Courthouse. Additionally, other suggested countermeasures, such as blackout curtains, are not acceptable security standards.” These “countermeasures” hang on the U.S. Courts Design Guide, which emphasize “the need for flexibility in the design and construction process.”¹⁷ Other documents, such as the GSA’s own “Technical Preservation Guidelines for Upgrading Historic Building Windows,” provide options for secure replacement glazing in historic buildings that could apply to both the Dirksen Courthouse and the Century and Consumers Buildings.¹⁸

The stated unfeasible nature of the retrofitting the Dirksen Courthouse is refutable by the stated flexibility of the design guidelines, and the prevalence of Modern-era buildings—over 550 properties in the GSA inventory—that the agency maintains. Simply put, the GSA has stated that securing the Dirksen Courthouse against the threat of an adaptively reused Century and Consumers Buildings is not possible, despite the guidance for US courts being purposefully flexible.

It is a matter of national security for federal agencies like the GSA to not promulgate information that may provide terrorists with a blueprint on how to inflict harm. Yet, the GSA has settled on not providing detail on those stated “security concerns” as a matter of public safety, while that vagueness simultaneously acts as a shelter under which they can justify the demolition of the Century and Consumers Buildings without providing evidence that may prove that the GSA has not thoroughly considered ways in which the Dirksen Courthouse can be secured, or the Century and Consumers Buildings can be adaptively reused.

The GSA has declined to provide enough functional detail to assist those with a vested interest—engineers, architects, and preservationists, with experience in hardening even Miesian Modern buildings from a potential terrorist attack—to work collaboratively with the GSA on solutions which may be able to determine a way in which the buildings can be adapted to respond to the “threats.” It is impossible to solve a problem when the problem itself has not been made clear.

Another issue with the Century and Consumers Buildings is the insistence on grouping them together, even though they are not connected and not designed by the same architect. The GSA, and the public, have largely combined discussions of both buildings since they were acquired by the federal government in 2005. While the buildings are similar, and in proximity to each other and to the neighboring Dirksen Courthouse, there are enough variances in their design and location to lament the treatment of both, located approximately fifty feet apart, as one. The rear elevation of the Century Building, facing the Dirksen US Courthouse, has no windows, and is buffered by two late nineteenth-century buildings with Adams Street façades, both four stories each, and owned by the Berghoff Restaurant. The Century Building is located approximately 130 feet from the Dirksen Courthouse. At approximately 85 feet from the courthouse, the Consumers Building has windows on all four sides, and is larger in both footprint and height to the Century Building. The contrast between both buildings would presumably present different adaptive reuse and security needs for both.

The historic significance of the Century and Consumers Buildings is not in question. They have been included on the endangered buildings lists of Preservation Chicago, as well as Landmarks Illinois and the National Trust for Historic Preservation. In May 2023, the Commission on Chicago Landmarks voted to recommend local landmark status for the Century and Consumers Buildings, an action that signaled the City of Chicago’s willingness to take a stand for preservation against the interests of another government agency, while also providing assurance to the GSA that the Landmarks Division was willing to exercise flexibility regarding adaptive reuse and site security.¹⁹ In the Environmental Impact Statement, the GSA stated that it would have no position either for or against landmarking, but that the agency, while respecting the Chicago Landmarks designation, would be “bound to the outcome of the Section 106 process rather than the local landmark process.”²⁰

In the Environmental Impact Statement, the GSA stated that “no federal funds are available for the rehabilitation, preservation or restoration” of the Century and Consumers Buildings.”²¹ Separate assessments for both buildings conducted by a private consultant, revealed that “the original building façades are in distress.” The need for significant repair is due to the GSA’s own inability to determine a solution for the buildings over a nearly twenty-year period, within which the buildings have been minimally maintained. According to a report commissioned by the GSA, the cost estimates for renovation of both buildings would run at an average cost of $1,500 per square foot.²²

While the cost estimates provided by the GSA do not specify the type of renovation, every economic and social indicator points toward the Century and Consumers Buildings not being renovated into commercial office space, despite the GSA’s direction through the rigidity of the fifteen security criteria, that a commercial office renovation would likely be the one of the only acceptable uses. With the redevelopment of the James R. Thompson Center by Google being the exception, Chicago is looking to convert commercial office space into other uses, not create more of it. In January 2024, Crain’s Chicago Business reported that office space vacancy in the central business district hit an all-time high of 23.8%.²³

While Chicago holds a surplus of office space, it holds a deficit of affordable housing. Adapting office space into housing could prove to be a path forward to reducing that deficit. According to a report by Housing Action Illinois and the National Low Income Housing Coalition, Chicago has a shortage of 126,165 affordable rental homes for those with the lowest incomes.²⁴ This trend is echoed nationwide, and encouraged the Council of Economic Advisors, an agency charged with providing the President objective economic advice, to provide guidance on addressing office vacancies through commercial-to-residential conversions.²⁵ The Council stated, “facilities with the appropriate building, land-use, and economic characteristics can provide a new source of housing where it is badly needed, and the adaptive re-use of these properties can have the added benefits of improving the efficiency and reducing the emissions of existing buildings.” Within the policy principles outlined in the Advisory Council on Historic Preservation’s Housing Policy Statement is a call for federal, state, Tribal, and local governments to “lead by example through disposition or outleasing of excess or underutilized historic government buildings for housing development.”²⁶

While details regarding ownership and management, as well as the physical complexities of converting office buildings to residential would need to be resolved, nearly every factor outside of the GSA’s “security concerns” points towards renovating the Century and Consumers Buildings into housing. This alternative carries the most public support, makes the most economic sense, and is the best option for Chicago looking to do right by the housing needs of its citizens.

Yet, the City of Chicago, even if the buildings are landmarked, does not have the power to prevent the GSA from demolishing the Century and Consumers Buildings. With the federal processes drawing to a conclusion, the ability for the buildings to have a new life rests on whether the Advisory Council on Historic Preservation will review the process objectively, looking to its own recently released guidance as a path forward, guiding the GSA away from demolition.

While historic preservation is seen as the central issue surrounding the Century and Consumers Buildings, this matter is bigger than preservation. In a post 9/11, global pandemic reality, their proposed demolition asks more broadly: “who has a right to the city?” We are mired within a framework where the Federal bureaucracy trumps the best interests of a municipality within it, and where that bureaucracy somehow still claims it has the interests of its citizens, but is unable to listen to them, or to disengage itself from its own myopia.

Governments—local, state, and federal—have been working in earnest to develop new policies that reverse the harm done by historic policies that would never correct themselves without direct action. These new policies must work in concert in order to be effective.

As the federal processes draw to a conclusion, the GSA has stabilized the parapet of the Century Building and removed its fire escape, while a sidewalk canopy continues to surround both buildings. The situation with deferred maintenance at 212 South State Street, a non-contributing building to the Loop Retail Historic District, was so dire that in 2023, the GSA insisted that the building’s façade was at risk of collapse, and the building would have to be immediately demolished.

In the spring of 2023, 212 South State Street was demolished. It was quickly replaced with a landscaped lot full of shrubs and hostas, with a permeable walkway winding through it, secured by a heavy non-scalable secure fence. This expeditious work was likely considered as a way for the GSA to illustrate to the public how they would care for and maintain the secure lot that would be created once the Century and Consumers Buildings were demolished, yet it achieves the opposite. The lot is cold, forbidding, and worthless. This is the future that the GSA wants for the Century and Consumers Buildings, but is it also the future for the other properties on State Street that the GSA owns? Could the GSA acquire other buildings in the vicinity of the Dirksen Courthouse, like the Marquette Building and the Monadnock Building—two other Chicago School skyscrapers—and attempt to turn them into vacant, secure lots? Are viable buildings next to federal courthouses nationwide also at risk for demolition due to “security concerns”?

Beyond the question of if the GSA is following this process in good faith, what is the precedent that this could set for the sweeping and destructive power of the federal government under the guise of public safety?