the 1990s, some artists called for artistic social intervention in public space. These efforts employed the term "new genre public art" in addition to the terms "contextual art", "relational art", "participatory art", "dialog art", "community-based art", and "activist art". "New genre public art" is defined by Suzanne Lacy as "socially engaged, interactive art for diverse audiences with connections to identity politics and social activism". Mel Chin's Fundred Dollar Bill Project is an example of an interactive, social activist public art project. Rather than metaphorically reflecting social issues, new genre public art strove to explicitly empower marginalized groups while maintaining aesthetic appeal. An example was curator Mary Jane Jacob's 1993 public art show "Culture in Action" that investigated social systems though engagement with audiences that typically did not visit traditional art museums. Curated public art The term "curated public art" refers to public art produced by a community or public who "commissions" a work in collaboration with a curator-mediator. An example is the doual'art project in Douala (Cameroon, 1991) that is based on a commissioning system that brings together the community, the artist and the commissioning institution for the realization of the project. Memorial public art Memorials for individuals, groups of people or events are sometimes represented through public art. Examples are Maya Lin's Vietnam War Memorial in Washington DC, Tim Tate's AIDS Monument in New Orleans, and Kenzō Tange's Cenotaph for the A-bomb Victims in Hiroshima Peace Memorial Park in Japan. Controversies Public art is sometimes controversial. The following public art controversies have been notable: Detroit's Heidelberg Project was controversial for several decades since its inception in 1986 due to its garish appearance. Richard Serra's minimalist piece Tilted Arc was removed from Foley Square in New York City in 1989 after office workers complained their work routine was disrupted by the piece. A public court hearing ruled against continued display of the work. Victor Pasmore's Apollo Pavilion in the English New Town of Peterlee has been a focus for local politicians and other groups complaining about the governance of the town and allocation of resources. Artists and cultural leaders mounted a campaign to rehabilitate the reputation of the work with the Baltic Centre for Contemporary Art commissioning artists Jane and Louise Wilson to make a video installation about the piece in 2003. Sam Durant's Scaffold (2017), installed in the Walker Art Center's garden represented the gallows used in seven government