Gene Itogawa
Office of State Historic Preservation
P.O. Box 942896 July 7, 2004
Sacramento, California 94296-0001
Hollywood Heritage strongly opposes the proposed nomination of the Hollywood Bowl Performing Arts Complex (“Complex”) to the National Register of Historic Places. All historic elements of the complex have been systematically demolished and the overall site plan has been significantly altered by the property's owner, Los Angeles County, with the exception of the entryway sculpture and fountain. (It should be noted that the County had legislated to repair and restore these 1940 elements in 2000, but then did not do it, and they remain in a non-operating and altered condition.)
The County's letter of June 8, 2004 requesting support for the nomination refers to eligibility determinations given to the Complex in 1983. Since then, there have been major alterations and demolitions of the site. The 1938 tea room and restaurant was eligible for recognition, but it was demolished in the 1990s for a larger museum structure. The original landscaping has been replanted so many times that it does not resemble any historic photos. The other structures in the Complex all date from the 1960s and later except for the men's room to the south side of the new orchestra shell. Though old enough, the men's room does not justify this nomination.
The performance area consists of the orchestra shell and stage. All of this is brand new, having been built in 2003-4 after the historic shell and stage's demolition in 2003. It attempts to emulate the shape, but not the size or scale of the 1929 orchestra shell. That was the historic one, not this new one. All of the great history and performances in the Bowl took place on the 1929 stage under that shell, nowhere else. Historically, the new shell is no more than a shill for the shell of 1929 and its history. The County eagerly demolished it and now wants it both ways with historic recognition.
The seating area retains its original perimeter and shape, but the seating in it has been changed many times, including “Super Seats,' installed a couple of years ago. In any case, the seating area has no historic significance as the events took place on the stage.
In the lawsuit and appeals filed by Hollywood Heritage, beginning in 2000, to prevent the demolition of the 1929 orchestra shell and stage, the County consistently downplayed the Complex's historic significance when compared to making it into a brand new state-of-the-art entertainment facility. In all of the improvements done to the Complex over the past decade no concern for historic preservation has been exhibited, hence nothing has been preserved. This was the basis for their “Statement of Overriding Consideration” that was issued in the 2000 Environmental Impact Report to allow for the demolition of the 1929 shell and stage to create the new, larger pop venue. (In a bizarre ruling, the Court somehow determined that the shell was built in 1980 and therefore our lawsuit to protect it under historic preservation law was without merit. The County did not question this ruling that the Complex was not historic, but rather defended it on appeals.)
The remaining areas do not qualify under federal regulations for the proposed nomination. If the County feels so strongly, wait 50 years and resubmit it when the new, current, Complex can be evaluated. The four criteria of eligibility for this nomination are: A) Association with significant events; B) Association with significant persons; C) Design or construction significance (considered to be at least 50 years old); and D) potential to yield significant information as described in criteria “A” “B” or “C.” The Complex's history is well known, therefore “D” is not applicable. As described earlier, no remaining structures would qualify under “C” with the exception of, possibly, the altered fountain and sculpture at the entry. This leaves criteria “A” and “B.”
According to the “National Register Bulletin” (U.S. Department of the Interior, National Park Service, rev. 1991) under “criteria A and B” it states;
“A property that is significant for its historic association is eligible if it retains the essential physical features that made up its character or appearance during the period of its association with the important event, historical pattern or person/s.” (page 46)
As the shell and stage where the historic events and association with persons (criteria A and B) took place has been demolished, the other areas would have to provide such recognition.
There is no other such area. Claiming that people sat in the audience is meaningless, or else anywhere people of fame went would qualify for this designation. No person is ever cited in the Complex's history as significant for having sat in the audience. Nor has the County ever filed any notice of historic significance or determination needed when they have altered or removed seating. Anyway, as the seats have been changed several times over the years, it would be impossible to even point to a position where such a person of note sat, or that such a seat actually still existed.
Therefore, even with audience seating, the “physical features” to make an association have been altered, removed, or simply cannot be accurately determined. Otherwise, the parking lot would qualify and even the aforementioned men's room (at least it is more original than the seating) could qualify for recognition to the National Register of Historic Places because of similar associations.
To claim the site of the shell and stage qualify is just as ridiculous. Again, the “physical features” are gone and one cannot nominate the site of demolished structures that were replaced with new ones. If so, there would be no incentive to protect such structures. Tax benefits could be given, the structure demolished, and the designation (and deduction) would have to remain according to such a ruling. If this is contemplated in some convoluted way, we would demand that the IRS be allowed to evaluate this. Several owners of sites of now demolished historic structures on, or eligible for, the National Register, would be interested in obtaining the benefits from their now demolished properties if a precedent such as this nomination is allowed.
We are enclosing additional articles to this letter. One is from our Fall 2003 newsletter that outlines our lawsuit to protect the historic “physical features” of the Complex and how Los Angeles County fought it, and the other is a current review of the new shell, written by Mark Swed of the Los Angeles Times. Both Mr. Swed and the Los Angeles Times were major supporters of the new shell, yet his complaints echo those predicted in our newsletter. He also makes it clear how the larger shell has changed the concert-going experience for the audience, thereby affirming our previous issue with changing the “physical features” for the audience itself.
Please feel free to call me at (323) 463-6418 if you have any questions or require further information (our web site http://www.hollywoodheritage.org has past newsletters covering several Bowl articles back to 2000, as well as various legal documents relating to our lawsuit against the County). We again, ask that those who wantonly destroy our history are not allowed to benefit from it. This is what Los Angeles County has asked you to do by this affront to the importance and sanctity of the National Register of Historic Places.
Sincerely,
Robert W. Nudelman
Director of Preservation Issues
Hollywood Heritage, Inc.
cc: file
Attachments: Mark Swed Times First Review of New Bowl Shell
Mark Swed Times (2nd) Review of New Bowl Shell (7/17/04)
Robert Nudelman article from Hollywood Heritage Newsletter, Fall 2003