Action Alert:  PLUM will consider approving the drafting of an ordinance to allow for the placement of digital billboards in LA that are part of the Metro digital billboard program (Transit Communications Network / TCN ) at its next meeting on Tuesday June 21st.  Please submit comments in opposition and help to spread the word to generate written public comment in advance of Tuesday’s meeting. Please also consider calling in to voice your opposition. 

Written comments can be submitted on the form at:   https://cityclerk.lacity.org/publiccomment/?cfnumber=22-0392

Call-in instructions to give oral testimony/public comments can be viewed at the top of the PLUM agenda:  https://lacity.primegov.com/Portal/MeetingPreview?compiledMeetingDocumentFileId=36961

The Council approved a Memorandum of Agreement (MOA) between the City and Metro on Dec. 8 for the TCN program –  – this, without any public outreach or discourse.  The MOA motion indicates that Metro is the lead agency responsible for CEQA compliance.  Metro has just started the EIR process with recent scoping meetings in May (not well publicized and whose comment period ended June 1^st (!)).  Is it appropriate for the City to be moving forward with the ordinance and the program prior to an EIR being completed that will reveal impacts and possible alternatives to the program?

The City continues to ignore the serious driver distraction dangers of changing digital messaging and ignores public comment about studies done around the world that document these dangers. Are Vision Zero goals no longer important in our city that sees escalating carnage on our streets?  The Dept. of Transportation has never been tasked with a review of the recent studies and literature available.  Why not?

In a city that should be working to increase our urban tree canopy, instead we see a rush to occupy our streets and highways with structures containing changing digital advertising messages. The logic behind adding more and more signage to generate ad revenues is folly.   A strategy to reduce signage thereby increasing the revenues generated from fewer select signs has never been considered.  The City appears to be pursuing a strategy to allow growing numbers of signs which carry the assumption that more signage equals more revenues.  Not demonstrated as true!  Rather,  the city should adopt a policy to derive the greatest income from the LEAST numbers of signs. Aesthetics matter.  Contracts for signage last for many years, and in the case of the TCN, the agreement goes for 20 years.  Once installed, these structures will be polluting our environment for years to come.

There are also important legal considerations and concerns that this program (and others currently under consideration in the City) may serve to undermine the City’s long-term authority to regulate off-site signage/billboards — the result of hard-won court victories over many years that defined the City’s authority.  

The proposed Metro program has identified placement for both freeway-facing and non-freeway facing locations for its digital changing billboards. Maps showing the current proposed locations of the signs in LA City can be viewed in the slide program posted online 6/2 on pages 15, 16 and 17:  https://www.dropbox.com/sh/7l3vazv99twwyo2/AACpUExTf80X3bLjEuk2TQ4da?dl=0&preview=TCN_Scoping+552022.pdf    What is the process for changes to this list, additions to this list, etc.?  

The program proposes:  “34 Freeway-Facing structures and 22 Non-Freeway-Facing structures in the City of Los Angeles on Metro-owned property.  Freeway Facing structures can be viewed from freeways and highways, and Non-Freeway-Facing structures would be viewed from major streets and boulevards.” 

The impacts on nearby properties, property values, quality of life and on the environment have NOT been assessed. Metro is just starting the environmental review process, so how can the City move forward now without that report and an analysis of impacts, alternatives and mitigations needed?  

Finally, if and when any new digital signs are installed, a stringent mandatory takedown requirement to rid the City of old signs must be pursued. The proposed takedown of old static billboards that is part of the Metro program is completely insufficient when considering the numbers of new digital billboards proposed (some of which are proposed for LA City and others outside of the city).   The City Planning Commission recommends a takedown ratio of 10 existing static billboards for every digital billboard erected.  Digital billboards generate many times more revenues than old static billboards with the billboards targeted for removal signs that Metro inherited from the railroads when land was transferred to them years ago.  (Recent comparisons of revenues show that digital billboards command 20 times the revenues of a static billboard in a similarly placed location. The disparity will be even greater for older static signs.)

This is but one program of many currently under consideration in the City that seeks to place new advertising structures on our public right-of-way in exchange for a cut of ad revenues.  The newly proposed street furniture program (STAP) proposes a new LA Municipal Code that will allow for undefined, unlimited numbers of new advertising structures on our public right-of-way in addition to those allowed for transit shelters (and for which a dedicated LAMC already exists).  The LA Tourism and Convention Bureau is proposing the “IKE” program that seeks to place HUNDREDS of “interactive” ad kiosks on our sidewalks/parkways presented as information for tourists but placed across the City.  Together these constitute a takeover of our public right-of-way with changing advertising messages.  Is this what our streets, sidewalks and parkways should be used for?  

Protect our visual environment from an onslaught of dangerous visual pollution.   

The Council File is:  CF 22-0392 at:  https://cityclerk.lacity.org/lacityclerkconnect/index.cfm?fa=ccfi.viewrecord&cfnumber=22-0392

Please act now, submit public comment, and help to spread the word and speak up for our visual environment and our shared public right-of-way.

22-0392 (CFMS) Date Activity ; 05/12/2022: Community Impact Statement submitted by Westside Neighborhood Council. 05/10/2022: Planning and Land Use Management Committee continued item to/for a date to be determined. cityclerk.lacity.org

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———————————————————————————————————————————————————————– Points you may wish to consider or incorporate in comments: ​Premature to consider any City ordinance to allow this program to move forward until the EIR for the program identifies impacts, available mitigations and alternatives and can be publicly reviewed. Failure of the City to address the critical issues related to digital billboards and driver distraction coupled with the city’s increasing numbers of accidents, injuries and deaths of pedestrians and bicyclists – our most vulnerable street users. Lack of adequate public discussion and opportunity for neighborhood council and community input (now and at the time of Metro-City Memorandum of Agreement approval in December 2021). Failure to address aesthetic issues and impacts on nearby properties. Failure to address quality of life issues for those in these sign’s visual reach. Failure to acknowledge cumulative impacts of placing more and more digital changing messaging structures on our public right-of-way (through this program and others currently under consideration).. Absence of analysis of impacts on the City’s legal/ long-range ability to regulate off-site signage/billboards Failure to recognize and address the larger policy issues related to minimizing the numbers of advertising faces on our public right-of-way while maximizing revenues from those LIMITED sign faces allowed. Lack of any mechanism to allow for public input, council district input, neighborhood council input into the actual placement of these proposed billboards. Potential conflicts with existing City programs and ordinances such as specific plans that regulate signage and /or are contained in the City’s General Plan and Mobility Element.