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July 13, 2018

Friends of Red Rocks


P.O. Box 102891
Denver, CO 80250

Denver Landmark Preservation Commission


Community Planning and Development
201 W. Colfax Ave., Dept. 205
Denver, CO 80202

Re: Proposed Modifications to the Planter Boxes at Red Rocks Park & Amphitheatre

Dear Commissioners:

Over the past two decades, Friends of Red Rocks (FoRR) has dedicated thousands of
volunteer hours to Red Rocks Park & Amphitheatre. We meet monthly for park clean-
ups; build trails, stairs, and fences; plant and tend the native garden; and educate
Red Rocks’ patrons about its history and importance. FoRR was also deeply involved
in the successful effort to designate the Park & Amphitheatre a National Historic
Landmark. We are dedicated to preserving the magic of this internationally famous
and historically significant place.

Denver Arts & Venues capably manages Red Rocks as Denver’s premier outdoor
venue, and we are proud partners with this department. We understand the need to
balance the unique history of Red Rocks with its ever-increasing popularity. Red
Rocks has undergone significant changes to accommodate its heavy use, such as the
construction of the Visitor’s Center, the agora, and the stage roof. But while we
understand the inevitability of change, we also take seriously the public necessity of
protecting and perpetuating structures of historical, architectural, and geographic
significance.

FoRR appreciates some aspects of Arts & Venues proposal to rehabilitate the planter
boxes, including additional plantings and a renewed commitment to caring for the
existing juniper trees. But its proposal to pave over and install railings in the
Amphitheatre’s planter boxes may be unnecessary, unsafe, and would ravage Red
Rocks’ architectural history. We understand that Arts & Venues feels that action is
needed to improve the aesthetics of the planter boxes and to address possible liability
issues. But we believe these goals can be achieved without pavement and railings. For
these reasons, which we explain below, we respectfully request that you reject Arts &
Venues’ proposal to alter the planter boxes.

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1. The railings are unnecessary, and may even make the Amphitheatre
more dangerous.

Arts & Venues proposes installing painted metal railings in virtually all of the historic
planter boxes that border the Amphitheatre’s seats. The justification for railings is Arts
& Venues insistence that railings are required to “comply with building code,”
specifically pointing to Section 105.4. In the 2018 International Building Code, that
section refers to “validity of permit,” and does not mention railings. Presumably, Arts
& Venues is actually relying on Chapter 10: Means of Egress, and specifically Section
1015.2, which requires guards “along open-sided walking surfaces…that are located
more than 30 inches measured vertically to the floor[.]” However, it is not clear
whether this provision requires “guards” (railings) in the planter boxes, which are
informally used as viewing areas and are not a means of egress. And even if this
provision were applicable to the planter boxes as they are currently used, the Denver
Design Guidelines for Denver Landmark Structures & Districts (Guidelines) explicitly
states – twice – that exceptions to the building code may be made for historic
structures.1 Arts & Venues has stated that it has sought a waiver for the planter boxes
and was denied, but has not produced evidence of its request or of the denial.

Arts & Venues also relies on Section 30.7 of Denver’s Municipal Code, which states
that construction for the purpose of “remedying of dangerous conditions” “may
proceed without further delay.” The Code goes on to state that the Landmark
Preservation Commission must be given notice of any order or directive by an
authorized City official to address dangerous conditions. We have asked for, but have
not yet received, evidence of any such directive. And we do not agree that the planter
boxes are in “dangerous condition.” Indeed, there have been no serious planter box-
related injuries despite patrons using the planter boxes as viewing areas for most of
Red Rocks’ 77-year history.

What we have informally heard is that the City Attorney has expressed concern that
the City is exposed to liability for failure to install railings in the planter boxes. We are
unaware of any formal opinion or analysis from the City Attorney expressly stating
that railings are required. What’s more, railings may not be the only solution to avoid
potential lawsuits. Warning signs in the planter boxes and waivers on concert tickets
may absolve the City. Staff that already police shows can help ensure that those using
the planter boxes as viewing areas are doing so safely.

Even if something must be done, there is yet another solution: fill the planter boxes
with vegetation to dissuade use of the planter boxes as viewing areas. This option,
simply put, would restore the planter boxes to their original condition and function
and preserve them. The staff brief prepared by the Landmark Preservation Manager
reviewing a prior, similar proposal from Arts & Venues states: “Landmark staff would
prefer that railings are not introduced into planter boxes, and that other means were
used to deter recreational use of the planter boxes.” Preservation is the simple, elegant
solution - the “other means” that has seemingly been overlooked here. The
preservation option would simply extend the holistic restoration of the outer half of
each planter box, as in Arts & Venues’ plan, to the inner half of each box as well, thus

1Design Guidelines for Denver Landmark Structures & Districts, page 3 states: “All
construction projects must meet [Chapter 10 of the Revised Municipal Code], although
special exceptions may be available for historic properties.” Page 31 states: “Note that
exceptions to building code requirements are often available for historic structures.”
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fully restoring the original “buffer function” of each box, rather than partially restoring
it.

The Guidelines, on page 66, encourage stewards of historic structures to “consider


alternatives to making an addition to a historic property,” yet these and other
alternatives do not seem to have been seriously considered.

Finally, we share the concern of the National Park Service that adding railings will
create an attractive nuisance, inviting concertgoers to sit on or hang from them,
greatly increasing body-to-ground distance. Concertgoers could also become crushed
against them. In short, railings may be even more dangerous to patrons than the
absence of railings.

2. The railings would adversely affect the planter boxes, which are
character-defining features of the Amphitheatre.

The planter boxes are a character-defining feature of the Amphitheatre. As stated in


the National Historic Landmark nomination:

“The planters, built with quarry-faced sandstone walls and dressed-stone


copings, were conceived by Burnham Hoyt as a transition from the theater aisle
traffic. While the geometric planters are clearly Modernist in their stark
functional aesthetic, the native juniper plantings were intended to ‘screen the
late comers from the audience, and define the theater shape, forming a pleasant
transition between the man-made theater and the natural rock cliffs.’

“When viewed in its entirety, the overwhelming impression of the amphitheatre


is formed by the curving seating. In fact, there is a marked absence of straight
walls and lines throughout the amphitheatre.” (Emphasis added.)

“The key character-defining features are the curving benches of the continental
seating plan, gradually sloping floor rising with stone-faced concrete risers, side
aisles separated from the seating with sandstone planters and juniper trees
and, finally, massive rock formations on the sides, all of which are virtually
unchanged from Burnham Hoyt’s original vision.” (Emphasis added.)

The Amphitheatre was designed to elegantly blend with the surrounding landscape.
Arts & Venues has identified a paving material with compatible color and texture that
would attempt to uphold this blend. But railings serve as jarring violations of this
design. The planter boxes were designed to screen spectators from the adjacent stairs,
as well as to act as a natural buffer between the Amphitheatre seats and the iconic
monoliths. Promoting additional spectator use of the planter boxes is counter to these
original purposes.

More importantly for this body, installation of railings is counter to the Guidelines:

“Preservation practice is based on making the least invasive repairs,


modifications and other changes necessary for preservation and reuse of a
historic structure and its character-defining features.” (page 20)

The railings are unnecessary ornament.

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Guideline 2.10 (c): “Do not add architectural details that were not a part of the
original structure.” (page 28)

The railings were absent from Burnham Hoyt’s original design and detract
from its elegance and blending with the natural environment.

Guideline 2.58: “Do not select a use that requires alteration of the structure’s
character-defining features.” (page 57)

This project would formalize the planter boxes as viewing areas, thus
changing their primary purpose of housing the juniper trees that screen
patrons from the adjacent stairways and serve as a natural transition
from the monoliths to the Amphitheatre’s seats.

The intent of the guidelines with regard to additions is “[t]o maintain the
general appearance of a historic structure, especially from key public vantage
points, when building an addition,” and “[t]o avoid adversely affecting the
character-defining features of a historic district when building an addition.”
(page 64)

Look at the photos below, which were submitted with the National Historic
Landmark application. Consider how the elegance of the planter box and
seating design would be interrupted with the eyesore of metal railings.
Notice how the eye is drawn to railings in these photographs. Now multiply
that distraction throughout the entirety of the Amphitheatre.

Stone planters, south stairway, seating at Red Rocks Amphitheatre; view to


west. Photo by Deon Wolfenbarger, 11/14/2012.

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Stone planters, seating at Red Rocks Amphitheatre, Ship Rock (background);
view to south/southwest. Photo by Deon Wolfenbarger, 11/14/2012.

Guideline 5.1 – Preserve original landscape and features, such as walkways,


fences, site walls, street trees, historic stairways and special planting or
ornamental site features that are character-defining features of the property or
historic district.

The installation of pavement could have an adverse effect on the trees,


which were planted by the Civilian Conservation Corps almost eighty
years ago. These trees have survived well under natural conditions for all
those years. The proposal calls for installation of utilities and irrigation
systems. We are unaware of any formal analysis from a professional
arborist evaluating the effects of these plans.

3. This significant change should not be considered absent preservation


guidelines specific to Red Rocks, or explicit direction from a City Official.

As the Guidelines note on page 8, some areas benefit from additional guidelines due to
their “distinct characteristics.” Among these are Civic Center, County Club Gardens,
Lower Downtown (LoDO), and Speer Boulevard.

The City has recognized that Red Rocks, being unique and incredibly important to
Denver’s history, deserves its own set of preservation guidelines. A work group was
developed in 2016 to establish those design guidelines. Until that work is complete, it
is entirely inappropriate to consider such a significant change to a character-defining
feature of one of Denver’s most treasured landmarks.

Arts & Venues has represented that it would not propose installation of railings if it
were not required to do so by the City Attorney. However, when asked for
documentation of the City Attorney’s directive, Arts & Venues could not produce it. If
Arts & Venues claims its hands are tied, the public has a right to inspect its chains.

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4. This proposal echoes a previously rejected proposal to convert the
planter boxes into box seating.

Again, the National Historic Landmark application provides important historical


context:

“With the theater’s growing popularity and ability to attract major headliners
came the pressure to compete with other state-of-the-art venues. In 1999, the
City announced an improvement plan that some feared would turn the
amphitheatre, as reported in The Denver Post, ‘into a clone of corporate kitsch.’

The plans proposed to replace the juniper planters with box seats, narrow the
seating and add a riser at the top of the theater to accommodate more people,
build a visitor center, sell advertising, and construct restrooms and concessions
on the natural south slope as an option to stabilize the eroding soil. Opponents
of these plans brought awareness to the park and theater’s irreplaceable beauty
and historic significance.

Organizing into the Friends of Red Rocks, this group garnered support from
Denver residents, musicians, and scholars, including Vincent Scully, Sterling
Professor Emeritus of the History of Art, Yale University, who wrote of Red
Rocks: ‘It is one of the few works of contemporary civilization that can be called
sublime. There is no other word, and it is valued in those terms by architects,
planners, and theater people all over the world, as by millions of ordinary
people everywhere.’ Through these efforts, and after two public meetings held
by the Denver Landmark Preservation Commission, Denver abandoned its
plans for the increased seating, box seats, and the south-slope addition.
Instead, the City developed plans for a new under-plaza visitor center that
would reference to Hoyt’s original drawings that depicted an ‘agora,’ or
marketing place, at the top of theater. That plan, developed by Hoyt, had not
been completed. The Friends of Red Rocks felt that adhering to Hoyt’s original
design acknowledged the high responsibility of caring for this special place.
Completed in 2003, the new Visitor Center is largely underground and offers a
gift shop, restaurant, and a museum.”

We understand there is no explicit intention by Arts & Venues to convert the planter
boxes into box seating. However, there are also no barriers to advertisers and
promoters deciding to use those areas as VIP seating or to hang their advertisements
from the railings. Future management will no doubt be tempted to make the planter
box spectator areas available as premium paid seating. The planter boxes as designed
and the historic junipers as planted provide a natural barrier to this temptation.

Commissioners, it is your burden to determine if installation of pavement and railings


will truly retain and preserve the historic character of the “crown jewel” of the Denver
Mountain Parks System. It is up to you to decide if this proposal will assure Red
Rocks’ historical and architectural integrity. This body alone can protect Red Rocks
from unnecessary, unsafe, and jarring additions. Again, we respectfully request that
you reject this proposal.

Thank you for your consideration.

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Sincerely,

Board of Directors, Friends of Red Rocks


Susan Guokas
Amy Harris
Jack Mellon
Shelly Ryan
Steve Zorn

cc: Council President Pro-Tem Jolon Clark


Councilmember Rafael Espinoza
Councilmember Kevin Flynn
Councilmember Paul D. López
Councilmember Kendra Black
Councilmember Mary Beth Susman
Councilmember Paul Kashmann
Councilmember Christopher Herndon
Councilmember Wayne New
Councilmember Stacie Gilmore
Councilmember Robin Kniech
Councilmember Deborah “Debbie” Ortega
Erika Warzel, History Colorado
Tom Keohan, National Park Service
Alan Salazar, Office of the Mayor
Steve Good, Founding Member, Friends of Red Rocks

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