There are many serious problems with the proposed STAP program to be considered by the full Council on TUESDAY, SEPTEMBER 20, 2022.

There are many issues, questions and concerns related to the STAP program that the City has failed to address.

While there is a universally recognized and pressing need for more and better shelter from the elements at transit stops, it is highly questionable whether STAP will actually provide what transit riders need, what was presented, AND there are aspects of the program that are truly alarming.

The program should not be approved because its proponents acknowledge the need; it should only be advanced when it is demonstrated that it will make a significant impact on addressing those needs.  There are no contractual guarantees that it will do so.

Safety: At a time when pedestrian deaths are rising to frightening levels, the placement of digital displays at bus stops will only exacerbate distracted driving.

Privacy: The City does not appear to understand the threat to personal privacy posed by wireless devices collecting cell phone data from passersby.  The City claims that only “anonymous” data will be collected, but does not explain how it will verify this when a private company will actually be operating the system.  Also, supposedly “anonymous” data can be used to target individuals through re-identification, a practice commonly used by data brokers.

Cost: The CAO’s report makes clear that there are actually no guarantees as to how much revenue the program will produce, and yet the City will be required to spend over $230 million to get STAP up and running.  This is fiscally irresponsible. Costs and revenues are uncertain.  The City has taken on the fiscal responsibility and duty to implement vast elements of the program (as well as the public automated toilet program for which there have not been sufficient funds identified).

Equity:  Fiscal pressures apparently require that the early installations of transit shelters be done in affluent areas where the highest revenues will be generated.  This repeats the injustices of the current program where transit riders in the hottest areas will have to wait for shelters.  For how long?

Billboard Ordinance/ Sign Regulations: It appears that one of the main reasons the City is pushing STAP is to revise the LAMC to remove current protections against advertising structures on the PUBLIC right-of-way and to allow all manners of commercial advertising structures without limit: digital billboards, ad displays and advertising kiosks and banners.  The City claims to be helping transit riders, but it appears the true motivation for the program is to facilitate the generation of advertising revenues. 

Aesthetics:  “Great streets” are not defined by their advertising structures.  Protection of the public right-of-way from commercialization is a value worth protecting. 

Sustainability:  Energy conservation is a hallmark of a truly green city.  The addition of thousands of digital structures consuming energy, polluting the night sky, and impacting the lives of the smaller creatures with whom we share the landscape does not meet best sustainability practices.

It would be best to revisit STAP from the very start, but at the very least Council consideration should be postponed for at least six months so that critical issues and questions can be answered, changes made to reflect the problems identified, and a proper CEQA environmental review implemented.  A 10 to 20 year contract deserves the full attention of all those involved and requires careful evaluation.  A hurried approval to meet the Oct. 14 “last date to act” would represent both a terrible injustice and a glaring example of a lost opportunity to make a genuine contribution to improving the quality of life of all transit riders –an opportunity that may not return for another decade. 

  A list of some of the unanswered questions and questions that we hope the Council will ask can be found in the CityWatch article of 9/16:  https://www.citywatchla.com/index.php/cw/los-angeles/25504-stap-trojan-horse-or-transportation-program

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This email contains information about the “IKE” interactive advertising kiosk program is because it will be possible for the program to move forward under the new LAMC that is now part of the STAP program’s Mitigated Negative Declaration document.  That new LAMC will remove protections from advertising on our Public right-of-way and will allow “IKE” – – something not currently possible.  Therefore, it is appropriate to refer to IKE as “Son of STAP.”

Many of those who are receiving this email message are in communities that are now being targeted by the Tourism and Convention Bureau’s planned IKE program:

Despite the fact that these maps and accompanying presentation information have been removed from the Council File records and can no longer be viewed in the open there, they had been saved by someone who viewed and saved them when originally posted.  They demonstrate but one very significant reason why the new LA Municipal Code within STAP should not be adopted and why STAP must be stopped.

Under the new LAMC within the STAP program, it appears that the Board of Public Works will be able to approve this program (whose original Letter of Intent expired at the end of last year when the City thought that STAP would already have been approved) without soliciting community input, without open Council District involvement.  Despite having been developed over a number of years with the recently expired Letter of Intent having originated in July 2017, the program appears to have been shared within a limited circle over those years.  No active community outreach to neighborhood councils or communities was done. Were Council District offices aware of the program and its planned impacts on our streets?

Here are the communities targeted for IKE structures in the initial group of 323 digital advertising “information” structures (of 1000 planned):

Beverly Center and The Grove

Brentwood Retail District

Century City Hotel District

Dodger Stadium

Downtown

Down town San Pedro

Echo Park / USC

Hollywood Walk of Fame

Hollywood West  /Laurel Canyon Entrance

La Brea Tar Pits / Miracle Mile

Larchmont Village

LAX / Century Blvd

Los Feliz / Thai Town / Little Armenia

Melrose Shopping Center

Melrose Studio District

Mid City / West Adams / Arlington Heights Commercial ARea

NoHo Arts District

Palisades Village

Pico-Robertson Restaurant District

Silverlake Commercial Area

Studio City

Venice Beach and Boardwalk

Westside Arts District

Westwood Village/ UCLA

Where are the Valley plans and maps??? 

The IKE business plan is for 1000 digital screens.

Our shared public open space is very limited and precious.  Should be we planting ad structures or trees on our streets?

To our electeds who are copied on this email message and who will soon be asked to approve or disapprove the STAP program:  It must be returned to Public Works.  Most importantly:  It is unacceptable from the point of view of failing to adequately provide for transit users.  It is unacceptable for relying upon unrealistic financial projections, for failure to identify and guarantee the funds necessary to pay for it and for dedicated staff to administer and implement it, for failing to honestly present changes made to the program, for failing to be equitable, for leaving a legacy of visual pollution and the commercialization of our PUBLIC right-of-way, and for intentionally adding dangerous driver distractions to our streets.  There are many additional reasons for the program to be returned to Public Works.

• see the maps on the Scenic Los Angeles website (https://www.scenic.org/chapters-affiliates/losangeles/ ) to facilitate easy access.  Additional information about STAP is posted on the website as well along with links for public comments to the STAP Council Files 20-1536 and 20-1536-S2.