top of page



This letter of September 21, 2020, was sent to key authorities,  outlining objections to the development project:

Subject: CASE# DIR-2019-5213-TOC-SPR-PHP – and the Watts Towers

By Luisa Del Giudice

Dear colleagues, 

In a meeting approximately one month ago, we learned (and later saw the drawings) of the  proposed multipurpose housing development in Watts identified as CASE# DIR-2019-5213- TOC-SPR-PHP [and associated parcels and case numbers], 10341 S. GRAHAM AVENUE  Southeast Los Angeles Zone C2-2D-CPIO, SA# 3880. Many of us were stunned to learn that the  project was so far along, without proper and thorough multiple stakeholder vetting. Had we  learned of the actual proposed plans earlier, you would certainly have heard our objections  earlier on in the process.


As a cultural historian of Nuestro Pueblo (the Watts Towers), I was truly alarmed and, as I have  learned more (from other experts) today, I am even more alarmed. I write to kindly request that  you, city and state administrators responsible for overseeing the well-being of this world heritage  site, take into greater consideration two of my greatest concerns — from the perspective of this  landmarked national monument (and the Watts Towers Arts Center campus) — which strongly  suggest that the City of Los Angeles and California State Parks must oppose the proposed  Thomas Safran and Associates development: 

1. View:  The artist’s intent was to situate the monument in such a way as to be visible to commuter traffic on the adjacent railway.  Experts in the history of the Watts Towers have amply shown this to be the case.  [E.g. Thomas Harrison, “Without Precedent:  The Watts Towers,” in Sabato Rodia’s Towers in WattsArt, Migrations, Development (ed. Luisa Del Giudice) and I Build the Tower, film by Edward Landler and Brad Byer.]

The presented TSA concept clearly demonstrates that the angled viewing breaks are, in fact, totally blocking any hope of seeing the Towers from either the station or by riders; since even past the proposed development, their view is then blocked by the Rainbow Bridge and the First Methodist Church at Graham.

2. UNESCO candidacy:  Our first unsuccessful attempt to have the Watts Towers added to the U.S. UNESCO Tentative List in 2016 (submitted by the City of Los Angeles and State Parks) as a World Heritage site, will continue until we are successful, as is certainly the intent of many stakeholders.   Given that the Watts Towers have already been designated a Historic National Monument, official international recognition seems the logical next step.  Nuestro Pueblo is such a unique, extraordinary, and internationally-acclaimed monument, entirely created by one man’s labor and vision, that it deserves official inscription as a World Heritage site.  We sought (and fought) for the Watts Towers’ UNESCO candidacy, but the City was so reluctant to advance this candidacy that a letter-writing campaign became necessary.  We relied primarily on the pro-active intervention of State Parks, in the person of Leslie Hartzell.  The letter, crafted by Edward Landler, Luisa Del Giudice, and Leslie Hartzell was submitted only one day prior to the deadline!  It was curious to all that the City, rather than advancing this monument for candidacy, was hampering it.  In hindsight, I ask myself whether the City already knew of development plans afoot, that such development would not be in the best interest of the monument’s wellbeing, and therefore hesitated endorsing this candidacy (so as not to stand in the way of any future development projects)?  Any proposed heritage site must consider its 2-mile perimeter, in order for it to be considered for inscription, taking care to ease traffic patterns around it, as you must know.

Other arguments against development follow:


1. This project violates and irreparably harms the letter and intent of the property transfer from the Community Redevelopment Agency to the county that designated this land for community benefit through usage for Parks and Recreation, and the preservation of the vital connection between the Watts Train Station and the Towers. The language could not be clearer. There is absolutely no reference to selling the land for private gain, as there wouldn't need to be.


2. The statement by the Council District 15 representative, that there is no other location for such a development, is disingenuous at best. First, there is the other side of the tracks that is already included among the phases. Second, other locations do exist but they may not be so nearly contiguous. Thus, construction cost increases may be used as an excuse, but, even for the current proposed sites, equipment, personnel, and materials cannot freely be moved across the tracks. They all must be trucked from one location to another at the crossing. So, there would be very little inconvenience in going to a different location.


3. How is it more important to house a few people as opposed to serving many more through artistic, community-beneficial green space, and community historic and cultural connections? 


4. And, essentially increase tourist visitation forever. What real gains are there, and what harm to the community and its legacy, as well as to the ideal of cultural and racial equity? A private gain that will only very marginally and remotely encourage positive social engineering in the form of increased public transportation ridership? The CSTRW (Committee for Simon Rodia’s Towers in Watts) fought the city a long time ago with similar arguments.  Luckily, smart reasoning and artistic and cultural sensitivity won out. Why repeat this scenario? Such discriminatory habits must end.  


5. The state has blocked private development before to maintain the site integrity of a state monument. Logically, the same applies in this instance.


6. Los Angeles City Hall stands proudly against the skyline only because it was seen as a beacon representing the city itself and taller blocking buildings were located far away so as to not inhibit that aspect. The Towers are no less a beacon for the area of Watts, and well beyond. They deserve the same reverence.  (In fact, for a time, the masthead on the official city stationery was the Towers, not City Hall.)


7. This project represents a total failure of the process to honor intents, covenants, codes, and the simple will of the people in the surrounding area. It has the optic of having been engineered to effectively ignore precedents, exclude this local underserved community, the general public, or even Los Angeles City departmental and State stakeholders from input in the approval process. Was this a coincidence?


8. This project does not address serious long-term environmental hazards.  As we know, fossil fuels contain carcinogenic materials that off-gas for a very long time, and cumulatively are very toxic, even at very low levels.  Contamination in even very deep soil becomes a special hazard for residents who spend long hours exposed to low levels (only a minor nuisance to a more transient setting). A) A building over such soil traps the offgassing even if open space allows dissipation.  Should this not be researched and made public? B) There have been regular tar or oiling treatments to the railroad ties for decades which likely contaminated both the track roadbed and at least the immediate surrounding soil. C) The wheel assemblies (known as trucks)—especially of the older cars—were known to throw off excess lubrication into the surrounding soil.  As a result, the lack of proper exploration and reportage of the risks, exposes all parties to litigation from any of the future residents who may contract any condition at any time that could have been recognized under the State of California Proposition 65, and other regulations. Failure to properly comply would be open arms to litigation for a very long time. All parties, whether private or government, who had been involved in "ownership" and knew (or should have known) of the potential risks are highly susceptible to litigation.



Therefore, it is with deep-felt urgency that we ask the City Cultural Affairs Department and State Parks, charged with caring for this great cultural asset, do all they can to protect the Watts Towers and the Watts Towers Community Arts Center from encroachment—as well as the entire community, from potential harm.  The Los Angeles County Municipal Code (22.124.020 Purpose; 22.124140 Certificate of Appropriateness) and the California Historical Building Code (CHBC) Character-Defining Feature clearly state where this development project fails to meet municipal and state codes with respect to historic and cultural landmarks.  This project violates and will cause irreparable harm to the “original site-specific intent” of the artist, who built one of the world’s most unique architectural wonders to be appreciated, from the equally historic train station and the thousands of riders on the train.  On behalf of many of the campus’ stakeholders, I implore you to consider our objections and respond as soon as possible—certainly before the process of development proceeds any further.


In earnest, 


Luisa Del Giudice, Ph.D.

Coordinator, Watts Towers Common Ground Initiative

Coordinator, Watts Towers UNESCO Committee

bottom of page