HomeMy WebLinkAbout02-05-14 YPC Packet"o M,4 '1.`, II"I' Dix"iI '"1111,°I' "' "' ]!'PA "7"' ". . "
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City of Yakima Planning Commission
WORK SESSION
City Hall Council Chambers
Wednesday February 5, 2014
3:00 p.m. - 5:00 p.m.
YPC Members:
Chairman Dave Fonfara, Vice -Chair Scott Clark, Al Rose,
Ben Shoval, Paul Stelzer, Bill Cook
City Planning Staff:
Steve Osguthorpe, Community Development Director/Planning Manager; Jeff Peters, Supervising
Planner; Chris Wilson, Assistant Planner, and Rosalinda Ibarra, Administrative Assistant
Agenda
I. Call to Order
II. Roll Call
III. Staff Announcements
IV. Audience Participation
V. Work Session - Continue Discussion on YMC Title 15 Text Amendments
a Review Draft Ordinance
VI. Other Business
VII. Adjourn
Visit rwv " ,IT t r _lrt tLrvice lailLhig under Quick Links for additional information.
City of Yakima Planning Commission
City Hall Council Chambers
Wednesday February 5, 2014
Beginning at 5:00 p.m.
Study Session
PLEASE WRITE LEGIBLY
Page 1 02/05/14 YPC Meeting
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MEMORANDUM
TO: Planning Commission
FROM: Steve Osguthorpe, AICP, Community Development Director
SUBJECT: Continued Discussion - Billboards & Digital Signs
Date: February 5, 2014
As follow-up to our January 29 meeting, I have prepared the attached draft ordinance
that hopefully captures the comments and direction of the Planning Commission
pertaining to both billboards and digital signs. The one thing that I did not think I would
be able to include in the ordinance is proposed standards for illumination other than
ISA's recommended standards. You will recall that we decided to recommend adopting
ISA's standards as an interim measure until we could more fully research and propose
more definitive standards. As it turns out, I found some really good information that I
believe speaks to the issues raised by Al Rose pertaining to how brightness can be
measured. This includes
(a) Excerpts from a PowerPoint presentation given by Clarion Associates at a
Colorado Chapter APA Conference in 2012;
(b) A report prepared by the U.S. Naval Observatory Flagstaff Station and other
Arizona based individuals titled, "Digital LED Billboard Luminance Recommendations —
How Bright is Bright Enough?";
(c) A report prepared by the Illinois Coalition for Responsible Outdoor Lighting
called, "Digital Billboards: New Regulations for New Technology"; and
(d) Excerpts from the City of Pittsburg sign code pertaining to regulation of
electronic advertising signs.
Copies of these items are attached for the Commission's consideration.
Some of the reports provided insights, if not criticisms, of ISA's recommended
standards. The consistent take away or recommendation from each of the three reports
was that (a) luminance, as measured in nits, was the more effective means of regulating
digital signs, and (b) digital signs should be limited to 1000 nits daytime, and 100 nits
nighttime. The Pittsburg code was apparently based upon some of these studies, and
the city nonetheless decided to enact a limit of 2,500 nits daytime, and 250 nits
nighttime. I therefore incorporated the same standards as Pittsburg lighting limits in the
attached draft ordinance for Yakima. However, the Commission may want to consider
the lower levels recommended in the referenced reports because it was clear in the
reports that even 1000/100 nits is probably too bright in some situations.
I'll share more details of the draft ordinance when we meet on the 5th
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ORDINANCE NO. 2014 -
AN ORDINANCE relating to text amendments to portions of Yakima Municipal
Code (YMC) Section 15.08 Signs.
WHEREAS, the City of Yakima's sign code currently ; and
WHEREAS, the City of Yakima recognizes that ; and
WHEREAS, the City of Yakima desires to and
WHEREAS, the City finds as follows pertaining to signs:
WHEREAS, the proposed text amendments are consistent with the goals,
objectives, and policies of the City's Comprehensive Plan; and
WHEREAS, the City's SEPA Responsible Official issued, a,determination of Non-
significance for the proposed text amendment on pursuant to WAC 197-11-
350;
97-11-350; and
WHEREAS, the City Community Development, Director forwarded a copy of this
Ordinance to the Washington State Department of Commerce on . ....... . ...............
pursuant to RCW 36.70A.106; and
WHEREAS, the Yakima City Planning Commission held a public hearing on this
Ordinance during its regular City Commission meeting of and
WHEREAS, legal notice of the public hearing was published in the Yakima
Herald on ; now, therefore
BE IT ORDAINED BY THE CITY OF YAKIMA, WASHINGTON:
Section 1. Section 15.08.020 of the Yakima Municipal Code is hereby amended to
read as follows:
15.08.020 Definitions.
For the purpose of this chapter, certain abbreviations, terms, phrases, words and
derivatives shall be construed as specified herein.
"Billboard" means any sign face, the primary purpose of which is to lease, rent let or
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that are minimally and/or coincidentally available on the site.
"Changing message center sign" means
sign that is capable of displingvvDpdG, symbols, figures or
images that can beelectronically ormechanically changed by remote or automatic
means.
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"Nits" are units Qfmeasure of _brightness or luminance. One (1) nit is egual- to one (1)
"Off -premises directional sign" means an off -premises sign with directions to a particular
business located within the city.
"Off -premises sign" means a sign advertising or promoting merchandise, service, goods,
orentertainment sold, produced, manufactured mrfurnished a1aplace other than mnthe
property where the sign islocated. Off -premise signs include but are not limited to
"On -premises directional sign" means a sign directing pedestrian or vehicular traffic to
parking, entrances, exits, service areas, or other on-site locations.
"On -premises sign" means a sign incidental to a lawful use of the premises on which. it is
located, advertising the business transacted, services rendered, goods sold or products
produced on the premises or the name of the business or name of the person, firm or
corporation occupying the premises.
"Static" means without motion.
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otherwise causes visually discernible changes to g _sign or any part of a sign or it
sum,orting structure, or that replacq§ any,gart of a sign or its sign structure with p
.-arts
t�hat are visuaHy, structurally, mechanically, andLor functiongIly different from originqI
oarts, except Ihat replacing siqn ggne�s, letters gr gAher,.forms of cogy with_ li,ke,jype, kind
Section 2. Section, 15.08.050 of the Yakima Municipal Code is hereby amended to
read as follows:
15.08 050 Prohibited siqns.
..........
The following signs are prohibited:
1. Signs on any vehicle or trailer parked on public or private property and visible
from a public right-of-way for the purpose of circumventing the provisions of this
chapter. This provision shall not prohibit signs painted on or magnetically attached
to any vehicle operating in the normal course of bw0iness;
8. Billboards
9, Off- remise signs except off -premise, dirl,gtion gli §ins and sinn e ly g§, al non
Q I g
conforming Wboards.
9-. 10. Any other sign not meeting the provisions of this chapter. (Ord. 2008-46
§ 1 (part), 2008, Ord. 93-81 § 34, 1993: Ord. 2947 § 1 (part), 1986).
Section 8. Table 8-1 of the Yakima Municipal Code is hereby repealed. A new Table 8-1 is hereby adopted, to read as follows:
NOTES:
1. YMC 15.08.140 has freestanding sign provisions for muhiple-building complexes and muRiple-tenant buildings.
2. Nameplates and subdivision identification signs permitted in the residential districts may be placed on a wall --See Table 8-2.
ZONING DISTRICTS
SR
I R-1
R-2
R-3 I B-1
I HB I B-2 SCC I LCC CBD
GC AS
RD M-1 M-2
SIGN TYPE
PERMITTED SIGNS
On -Premises
Nameplate
Permitted as an Accessory Use to an Approved or Existing Use
Signs
Subdivision Identification/ Project
Identificationz
Changing Message Center Signs
Permitted, subject -to the provisions of Section
Roof/Portable Signs
Not Permitted
Class (1) Use
Freestanding'
Subdivision/Proj. I.D. Only
-premises signs meeting the standards of this chapter are considered Class (1) uses requiring Type (1) review.
On -premises signs not meeting the standards of this chapter shall follow the procedures of YMC 15.08.170, and are
Projecting Not Permitted
otherwise not permitted.
See YMC 15.08.150
Freeway
Off -Premises
Directional
Not Permitted
CL (2)
of L (2) Use L (1) Use
Signs
Use
rermitted
Advertising
Not Permitted
Billboards
NUMBER OF SIGNS PERMITTED
On -Premises
Nameplate
1 Per Dwelling
Signs
Subdivision Identification/
1 Per Street Frontage
Use Identification2
Freestanding'
Changing Message Center Signs
Per Parcel larger than One Acre No More than 1 Sign along (oriented toward) any street frontage of a parcel.
Projecting
Not Permitted
1 Per Street Frontage
Wall/Roof/Portable Signs
Wall: YMC 15.08.100/ Roof: YMC 15.08.090/ Temporary: YMC 15.08.110
Freeway
Freeway: See YMC 15.08.150
Off -Premises
Directional
Not Permitted
Directional: See YMC 15.08.120(6)
Signs
Advertising
Not Permitted
Billboards
NOTES:
1. YMC 15.08.140 has freestanding sign provisions for muhiple-building complexes and muRiple-tenant buildings.
2. Nameplates and subdivision identification signs permitted in the residential districts may be placed on a wall --See Table 8-2.
Section 4. Table 872 of the Yakima Municipal Code is hereby repealed. A new Table
8-2 is hereby adopted, -to read as follows:
Freestanding and Projecting Signs
ZONING DISTRICT
Sign is set back 15ft.
Sign is set back 15 ft. or
WALL
FREEWAY
CHANGING
or less from required
more from required
SIGNS
SIGNS
MESSAGE
right-of-way
right-of-way
CENTER SIGNS
SR, R-1, R-2, and R-3
Nameplates up to 2 sq. ft. and subdivision/project identification up
NOT PERMITTED
33 Sq. Ft. per
to 32 sq. ft.
i sign face
HB and B-1
24 sq. ft.
40 sq. ft.
40 Sq. Ft. per
sign face
B-2
40 sq. ft.
60 sq. ft.
SCC
Frontage is less
1 sq. ft. of sign area per
1-1/2 sq. ft. of sign area
than 400 ft. long
lineal ft. of frontage up
per lineal ft. of frontage up
to 100 sq. ft.
to 150 sq. ft.
Frontage is more
1 sq. ft. of sign area per
1-1/2 sq. ft. of sign area
than 400 ft. long
lineal ft. of frontage up
per lineal ft. of frontage up
to 150 sq. ft.
to 200 sq. ft.
LCC
Frontage is less
1 sq. ft. of sign area per
1-1/2 sq. ft. of sign area
than 400 ft. long
lineal ft. of frontage up
per lineal ft. of frontage up
to 150 sq. ft.
to 200 sq. ft.
Frontage is more
1 sq. ft. of sign area per
1-1/2 sq, ft. of sign area
than 400 ft. long
lineal ft. of frontage up
per lineal ft. of frontage up
to 200 sq. ft.
to 250 sq. ft.
CBD
1 sq. ft. of sign area per lineal ft. of frontage up to
150 sq. ft.
SIZE OF
WHERE
GC
Frontage is less
1 sq. ft. of sign area per
1-1/2 sq, ft. of sign area
than 400 ft. long
lineal ft, of frontage up
per lineal ft. of frontage up
WALL TO
PERMITTED: UP
to 150 sq. ft.
to 200 sq. ft.
WHICH
TO 300 SQUARE
Frontage is more
1 sq. ft. of sign area per
1 -1 /2 sq. ft. of sign area
ATTACHED
FOOT
than 400 ft. long
lineal ft. of frontage up
per lineal ft. of frontage up
to 200 sq. ft.
to 250 sq. ft.
AS
Frontage is less
1 sq. ft. of sign area per
1 -1 /2 sq. ft. of sign area
than 400 ft. long
lineal ft. of frontage up
per lineal ft. of frontage up
to 150 sq. ft.
to 200 sq. ft.
Frontage is more
1 sq. ft. of sign area per
1-1/2 sq. ft. of sign area
than 400 ft. long
lineal ft. of frontage up
per lineal ft. of frontage up
to 200 sq. ft.
to 250 sq. ft.
RD
Frontage is less
1 sq. ft. of sign area per
1-1/2 sq. ft. of sign area
than 400 ft. long
lineal ft. of frontage up
per lineal ft. of frontage up
to 150 sq. ft.
to 200 sq. ft.
Frontage is more
1 sq. ft. of sign area per
1-1/2 sq. ft. of sign area
than 400 ft. long
lineal ft. of frontage up
per lineal ft. of frontage up
to 200 sq. ft.
to 250 sq. ft.
M-1
1 sq. ft. of sign area per 1-1/2 sq. ft. of sign area
lineal ft. of frontage up per lineal ft. of frontage up
M-2
to 100 sq. ft. to 150 sq. ft.
MAXIMUM AREA PER SIGN
= 2 TIMES THE MAXIMUM AREA PER SIGN FACE
Section 5. Section 15.08.130 of the Yakima Municipal Code is hereby amended to
read as follows:
15.08 130 Oft prernises directional sins oe
E 1T
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17. US
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a g.
6. No Wilbe-4 shall b— I
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Q. A. Off -premises directional signs are:
Class (1) uses in the M-1 and M-2 districts;
2. Class (2) uses in the B-2, CBD, GC, and RD districts.
Off -premises directional signs may be permitted in these districts after the required
level of review, provided they meet the provisions of this chapter and the specific
standards for the district in which they are located. (Ord. 2008-46 § 1 (part), 2008:
Ord. 93-81 § 40, 1993: Ord. 2947 § 1 (part), 1986).
Section 6.'A new Section 15.08.135 of the Yakima Municipal Code is hereby
adopted to read as follows:
15.08.135 Changing Message Center Signs
A. Brightness. During daylight hours between sunrise and sunset, luminance shall
be no greater than two thousand five hundred (2,500) nits. At all other times,
luminance shall be no greater than two hundred fifty (250) nits.
B. Auto -dimming. All changing message center signs shall be equipped with auto -
dimming technology to ensure that signs do not exceed maximum luminance
levels day and night.
C. Manufacture certification for compliance. All changing message center signs
shall be certified by the manufacturer that they are designed to no exceed
maximum luminance levels defined in this section.
D. Static Image & Hold. Each image of a changing message sign shall be static
except for message change, which shall occur instantaneously and then hold
static for at least 5 seconds between image changes.
E. Signs in Protected Areas. All changing message center signs in protected areas
as defined in Section 15.29.020 of the Yakima Municipal Code, except in
commercial zones, are subject to the following additional standards:
a. Signs are limited to monochrome text on dark background.
b. Signs shall be completely static except for message change occurring
through quick fade-in (1 second min/max).
c. Signs are limited to 33 square feet.
F. Malfunction or Vacancy. Changing message center signs shall revert to an all
black screen in the following instances:
a. The sign malfunctions
b. The premises on which the sign is located is vacated
G. Applicability. The provisions of this section do not apply to signs legally installed
on private property prior to the effective date of this ordinance.
Section 7. Severability. If any section, subsection, paragraph, sentence, clause or
phrase of this ordinance is declared unconstitutional or invalid for any reason, such
invalidity shall not affect the validity or effectiveness of the remaining portions of this
ordinance.
Section 8. Savings Clause. Chapter 15.08 of the Yakima Municipal Code shall
remain in full force and effect until such date as this ordinance becomes effective.
Section 9. Effective Date. This ordinance shall take effect on
INTRODUCED the day of ___............ ...--, 2014.
PASSED BY THE CITY COUNCIL, signed and approved at a regular open public
meeting held this .......... day of ........... w_ 2014,
Micah Cawley, Mayor
ATTEST;.
Sonya Claar-Tee, City Clerk
Publication Date:.
Effective Date:.
APPROVED AS TO FORM::
Mark Kunkler, Assistant Senior Attorney
*DistanceHOW TO MEASURE?
LUMINANCE
@Manufacturer Provides Specifications
*More Costly Equipment To Enforce
ILLUMINATION
signs
*Ambient Li i Problem
*Cheaper Equipment ,p,
How bright is Bright?
--The sun is measured at 6,500 nits
--During the daytime, an electronic sign can be set at
over 10,000 nits
--The Virginia Tech Transportation Institute found
electronic billboards to be 1 OX brighter than the
surrounding area, and 3X brighter than a traditional
billboard
Measuring brightness
A key issue here is the method by which the city will
measure illumination and then the maximum limit the city
sets. As discussed below, we believe there are
advantages to using candelas/square meter (nits), which
measures luminance, over foot candles which measures
illuminance.
Luminance (nits): This is a measurement of the
brightness of the sign face. The units are "candela per
meters squared" or "nits". One can measure sign
brightness by aiming a luminance meter or "nit gun"
towards the sign from a viewer's location. The closer to
the sign the measurement is taken, the more accurate
the measurement.
Advantages of using luminance as a sign measure is
that it is not distance dependent, so the measurement
can occur anywhere, though it is more accurate closer to
the sign. By scanning the sign with the nit gun, the
readings ratchet upward which is helpful in determining
maximum luminance values. Also, manufacturer's
literature provides nits in the specifications.
One disadvantage of using luminance is that the nit
meter is harder to use since it requires aiming and
scanning to record maximum values. It is also two to
three times more expensive than an illuminance/foot
Ev
candle meter.
Illuminance (foot candles): This is a measurement of
the amount of light that is falling on an object or a
person's eyes at a certain distance from the sign. One
can measure sign illuminance or "foot candles" by
aiming an illuminance or foot candle meter towards the
sign at eye level. Since illuminance is distance
dependent, a certain prescribed distance is critical. Also,
the sign must be turned to all "white" for consistent
measurements.
An advantage of using illuminance as a measure is that
the meter is less expensive and easier to use.
Disadvantages of illuminance are several. First, all of
the measurements must be taken at the same distance
and height of every sign. Also, the size of the sign must
be the same since a larger sign will have the higher
illuminances then a smaller sign although the brightness
of each sign is the same.
Based on these considerations, we recommend the use
of luminance as a measure of sign brightness/intensity
(in nits). Moreover, based on national studies by the
Federal Highway Administration and a review of recent
EAS ordinances in other communities, the city should
consider a day/night brightness restriction of 1000
1.1
nits/100 nits maximum from any element on the sign.
Environmental considerations:
One digital billboard consumes 397,486 kWh/year*
The carbon footprint of one digital billboard = 49
traditional billboards or 13.39 homes
One digital billboard = 108.41 tons/year of carbon
dioxide
Standard size digital billboard contains 449,280 light -
emitting diodes
A
ELECTRONIC ADVERTISING
ALL MOTION BANNED
!F 0 Static text and graphics only allowed
0 second "dwell" time
BUSINESS/ID ELECTRONIC
SOME MOTION ALLOWED
Flashing text and graphics banned
* Minimum 10 second "dwell" time
Motion will be a critical and controversial issue. Most billboard
companies want copy that can change every 6 seconds or
less. It's all a matter of ad revenue. 6 changes per minute is
6X revenue of standard billboard or more.
But changeable copy is distracting to neighbors, peds,
motorists.... and may be dangerous.
Highway Safety:
--Anything that distracts the driver from the forward roadway
for more than two seconds significantly increases the chances
of crashes and near crashes.
--23% of crashes and near -crashes that occur in metropolitan
environments are attributable to eyes off the forward roadway
greater than two seconds.
--Nearly 80% of the crashes and 65% of near crashes were
caused by distractions that made the driver look away for up to
three seconds.
F
0 Restrict Size Of Changeable
Copy Area
"Limit The Percentagel
Sign rea That Can be Electronic
Or Changeable
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CONTROLS
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PRE -PERMIT TESTING
offignow,517M.
Digital LED Billboard Luminance Recommendations
How Bright Is Bright Enough?
DRAFT
Christian B. Luginbuhl, U.S. Naval Observatory Flagstaff Station
Howard Israel, Phoenix, Arizona
Paul Scowen, Arizona State University
Jennifer and Tom Polakis, Tempe Arizona
9 November 2010
Summary
Careful and sensible control of the nighttime brightness of digital LED signage is critical. Unlike previous
technologies, these signs are designed to produce brightness levels that are visible during the daytime;
should too large a fraction of this brightness be used at night serious consequences for driver visibility
and safety are possible. A review of the lighting professional literature indicates that drivers should be
subjected to brightness levels of no greater than 10 to 40 times the brightness level to which their eyes
are adapted for the critical driving task. As roadway lighting and automobile headlights provide lighting
levels of about one nit, this implies signage should appear no brighter than about 40 nits. Standard
industry practice with previous technologies for floodlit billboards averages less than 60 nits, and rarely
exceeds 100 nits. It is recommended that the new technologies should not exceed 100 nits.
Introduction
Illuminated signage, for both advertising and informational purposes, has been a fixture of the modern
nighttime environment since at least the invention of electric lighting. Until recently, the principal use
of artificial lighting has been to make signs legible at night: ambient lighting, including skylight and
sunlight, has been considered adequate for daytime visibility. With the advent of digital LED billboards,
however, this is no longer true. Digital LED billboards must generate brightness sufficient to make them
legible during the daytime as well as at night. The brightness necessary to make a sign legible during a
full sunlit day can be many thousands of candela per square meter (also called nits); products available
on the digital LED billboard market commonly advertise maximum luminances between 6500 and 7500
nits. This creates the potential risk of a blinding nighttime brightness should an inappropriate
adjustment for nighttime conditions be made. Thus, the question arises of an appropriate limit to the
brightness of a sign at night, whether a digital LED billboard or any other kind of sign.
Background: Sign Brightness, Drivers, and Visibility
The principal safety and regulatory concerns for drivers viewing signage from a roadway is that 1) the
sign, by its very nature, is seeking to attract the gaze of the driver, i.e. the advertiser intends the driver
to look directly at the sign (and away from the roadway) for a period of time sufficient to discern the
sign's message or messages. Besides the obvious issue of a driver taking his or her eyes from the driving
task, viewing the sign leads to the second problem, 2) the eye adapting toward the brightness level of
the sign. Thus, when the driver returns his gaze back to the roadway, in all cases illuminated to a much
lower brightness than the sign, for some period of time the driver's vision is no longer optimally adapted
to seeing objects on the roadway. This changing visual adaptation when brightness levels change is
referred to in the technical literature as "transient adaptation." Drivers that have their visibility reduced
for objects on the roadway, even momentarily, will be at greater risk for accidents.
The Illuminating Engineering Society of North America (IESNA) recognizes this issue in numerous places
in its literature. The IESNA Lighting Handbook (9th edition, page 3-9) states:
"If the change in [brightness] lies completely within the range of operation of the cone
photoreceptors [i.e., daytime vision], a Lew minutes is sufficient for adaptation to occur.... As
for direction of change... changes to a higher [brightness] can be achieved much more rapidly
than changes to a lower [brightness]." [emphasis added]
This last sentence says that the eye will adapt much more quickly when moving from the dimly lighted
roadway to the bright sign, but much more slowly when returning to the dim roadway.
Design brightness levels for illuminated roadways are in the range of one nit (varying from about 0.3 to
1.2 nits, depending on roadway type (IESNA RP -8-00, 2000)). Thus, a driver viewing a billboard
illuminated to (for example) 100 nits, and then returning his gaze to the roadway, must adapt his eyes to
a brightness range of about 100:1.
What then is an acceptable ratio for transient adaptation, such that a driver's vision will not be
hampered when viewing both more brightly and less brightly illuminated areas while driving? IESNA RP -
33 -99, Lighting for Exterior Environments (page 42) states:
"If... roadways are lighted to a base level, [adjacent] areas should be no brighter than ten times
that level. Additional brightness will not attract more attention, and may present a hazard to
motorists on adjacent roadways."
Further, in IESNA RP -20-98 Lighting for Parking Facilities, we find (page 2).
"it is intended that a driver (or pedestrian) looking at the brightest spot in the field of view will
also be able to detect an object in the dark areas within the field of view. This detection can
occur only if the maximum -to -minimum illuminance is limited to a range that the human eye
can see."
This is followed by the numerical recommendations (page 3, Table 1) of 15-20:1. In other words, the
brightest area should appear no more than 20 times as bright as the faintest to assure that the
brightness remains within a range that the human eye can see.
In IESNA RP -2-01, Lighting Merchandise Areas (page 58), we find:
"... luminance ratios between the lighted retail area and its surroundings should not exceed
20:1. Increasing the lighting level does not add to merchandise attraction, and may create a
hazard to motorists on adjacent roadways or a nuisance for neighbors. A value of 10 times the
average surrounding task luminance is a maximum that should be utilized for the focus
merchandise. This will provide merchandise appeal without producing hazards or creating
conflicts with other nighttime events."
The IESNA recommendations for advertising sign brightness (IESNA Lighting Handbook, 9th edition, page
17-26) are inconsistent with all recommendations noted above. Brightnesses between 250 and 1400
nits are listed in the table titled "Recommended Luminous Background Sign Luminances." These
recommendations, if visible to highway drivers, will subject drivers' eyes to a brightness ratio of 250-
1400:1. According to their own recommendations this ratio is unsupportable and will lead to
compromised visibility and safety on public roadways. From the maximum ratio of 20:1, and assuming
roadways are illuminated to about one nit, signs should be no brighter than 20 nits. It is perhaps telling
that nowhere in the discussion of recommended advertising sign brightnesses is transient adaptation or
the vision of drivers mentioned.
Lighting for Conventional Floodlit Billboards
A series of measurements made for this report in August 2009 (55 billboards, Phoenix metro area),
Novembr 2010 (3 billboards, Chicago area), as well as deduced from data supplied for Tucson billboards
by M. Mayer, give an idea of brightness levels commonly seen in usual floodlit signs. These signs were
constructed and illuminated in most cases without any restrictions on sign brightness. It seems
reasonable to assume that the signs are illuminated to a brightness considered satisfactory by the
industry; if they were not, in most cases there were no regulations preventing them from increasing the
lighting levels.
Tucson Metro Billboards. A lighting inventory undertaken by M. Mayer lists the areas, number and types
of lamp used for illumination for 510 billboard faces located throughout the Tucson metropolitan area.
Since no direct luminance measures were made for this survey, we deduced approximate luminances
using a set of assumptions describing the physical characteristics of the sign lighting installation'. These
assumptions allow the conversion of total initial lamp lumens and area of the signs to the maintained
luminance values shown in Figure 1.
350
298
v
300
u
ra
250
m 200
Z 50
11
0-50
51-100 101-150 151-200
Maintained Luminance (nits)
0
201-250
Figure 1. Number of billboard faces with indicated predicted maintained luminances in the Tucson
metropolitan area.
1 Initial lamp lumen outputs from the manufacturer's literature; Light Loss Factor (LLF) = 0.60; Application
coefficient of utilization = 0.30; Diffuse reflectance of white vinyl sign surface = 0.70
o�
Z 50
11
0-50
51-100 101-150 151-200
Maintained Luminance (nits)
0
201-250
Figure 1. Number of billboard faces with indicated predicted maintained luminances in the Tucson
metropolitan area.
1 Initial lamp lumen outputs from the manufacturer's literature; Light Loss Factor (LLF) = 0.60; Application
coefficient of utilization = 0.30; Diffuse reflectance of white vinyl sign surface = 0.70
Phoenix and Chicago Metro Billboards. Measures of white surfaces on 55 floodlit billboards in the
Phoenix metropolitan area were made in August and November, 2009 using a Minolta LS -100 luminance
meter. An additional 3 billboards were measured in th Chicago area in Novmber, 2010. All of these
billboards are located in an urban environment. The results are presented in Figure 2; the data are
presented in Appendix A.
40
35
v
u
30
v
`m 25
0
m 20
° 15
L
d
E 10
3
Z _
0-50 51-100 101-150 151-200 201-250 251-300
Measured Luminance (nits)
Figure 2. Number of billboard faces with indicated measured luminances in the Phoenix and Chicago
metropolitan areas.
Of the total 510 billboard faces inventoried in the Tucson metropolitan area, the estimated average
luminance is 59 nits; 83% (424/510) are estimated at 100 nits or less, and 98% (502/510) at 150 nits or
less. The Phoenix and Chicago sample shows quite similar results, with an average luminance of 54 nits,
and 90% (52/58) measured at 100 nits or less, and 97% (56/58) under 150 nits.
Toward a Sensible Standard
Following the most conservative information concerning contrast ratios and transient adaptation, it
appears that the maximum luminance for signs visible to drivers on typically illuminated roadways
should not exceed approximately 20 nits. This follows directly from the commonly cited maximum
contrast ratio of 20:1 appearing in the IESNA literature and roadway luminances of approximately 1 nit.
Twenty nits is considerably below the brightness proposed by the OAAA report, and even below the
typical floodlit sign visible to drivers today. Yet IESNA references concerning brightness ratios and
transient adaptation, when discussed in any context other than that of signage (see below), indicate that
choosing a value higher than 20 nits may have visibility consequences for drivers.
When discussing lighting recommendations for signs directly, IESNA recommendations begin at 20 nits
but range higher, in one case much higher. IESNA RP -19-01 Recommended Practice for Roadway Sign
Lighting recommends that roadway signs be designed with luminances between 20 and 80 nits. The
lower value, 20 nits, is consistent with the value deduced from recommended maximum contrast ratios
and typical roadway luminances. The higher value, 80 nits, will present drivers with a contrast ratio of
about 80:1, yet is approximately comparable to typical practice for floodlit billboards. In The IESNA
Lighting Handbook (9th edition), Figure 17-37 Recommended Luminances for Poster Panels, Painted
Bulletins, and Other Advertising Signs recommends illumination levels that are consistent with
luminances of 45 —111 nitsz.
Thus, we suggest that a regulated maximum luminance for any type of sign visible from a roadway,
digital LED billboard or other, should not exceed 100 nits in an urban environment. Though it can be
easily argued that this value is too high, this limit would be consistent with the vast majority of
commercial floodlit billboards in use today, and at least would not increase potential degradation of
drivers' vision above levels experienced with current floodlit billboards. As the adaptation state of
drivers' eyes is generally dominated by the luminance level of the roadway illuminated by headlights,
that is around one nit, it may not be necessary to require lower sign luminances in darker surroundings.
The Outdoor Advertising Association of America Report and Recommendation
To formulate its own recommendations for sign luminance limits, the Outdoor Advertising Association of
America commissioned a study (Lewin, 2008; hereafter referred to as the OAAA report). This report
describes "a method for specification of luminance limits for digital billboards based on accepted
practice by the Illuminating Engineering Society of North America (IESNA)." Based ultimately on
considerations of "light trespass," as developed in another report (IESNA TM -11-00 Light Trespass:
Research, Results and Recommendations), a recommended "brightness" limit and measurement
technique is presented. The technique uses an illuminance meter ("footcandle" meter) held at a height
of 5 feet above the ground and a distance of between 150 and 350 feet from the sign under
consideration, depending on the size of the sign, and aimed at the sign. The illuminance level with the
sign lighting on is compared with a measure made with the sign off: if the value differs by 0.3 foot
candles or less the author proposes that the sign brightness is at an acceptable level. Though direct
luminance measures or limits are not suggested in this proposed regulatory strategy, the report
indicates that this method effectively limits the luminance of signage to 300-350 nits.
Issues with the OAAA Report
The OAAA proposed luminance levels are too high, about ten or more times as bright as recommended
in most IESNA recommended practices, and three or more times as bright as current accepted practice
reflected in billboard floodlighting. They would present drivers with contrast ratios of 300:1 or more.
This is unnecessary for advertising effectiveness and unnecessarily risks roadway safety. Further, the
OAAA recommendations are consistent with only the highest values gleaned from the IESNA literature,
and inconsistent with IESNA recommendations for roadway signs and maximum contrast ratios to
minimize transient adaptation problems.
Besides potentially serious practical issues associated with the measurement procedure proposed in the
OAAA report (e.g. the location for the suggested measurement may often lie within roadways;
determining compliance requires switching the sign on -and -off), there is a fundamental conceptual error
in the approach used to develop the strategy and limits.
Z IESNA recommended illuminance of 200-500 lux for light copy in dark -light surrounds combined with assumed
diffuse sign reflectance of 0.70.
The details of IESNA TM -11-00 are critical to understand if the results of that study are being
appropriately applied to the problem of determining maximum sign luminances. In the study, a group
of observers was presented with a variety of very brightly illuminated (2000 to 7500 nits) panels and
asked to judge whether or not the panels seemed too bright. An in-depth review is beyond the scope of
this discussion, but the following point is critical: the observers were asked only to rate how
"objectionable" they found the illuminated panels to appear; no evaluation of visual performance - the
ability to see objects or read signs - was attempted. This alone brings into serious question the
applicability of theTM-11-00 study to the question of appropriate sign brightnesses, and their potential
impact on driver safety.
The fundamental approach of the OAAA report has confused lighting that has been judged to cause an
acceptable level of light trespass or even just an 'objectionable" sensation with the much more vital
issue of sign lighting that compromises the vision and therefore safety of drivers. The ability to see and
light trespass/objectionability are essentially unrelated. The OAAA report recognizes this, stating
"Digital billboards are not the form of lighting that TM -11-00 was developed to limit." Yet the OAAA
report does just that.
Transient adaptation, and not light trespass, or "objectionability," is the overriding concern for public
safety with regard to the brightness of signage.
References
IESNA, RP -20-98 Lighting for Parking Facilities, 1998
IESNA, RP -33-99 Lighting for Exterior Environments, An IESNA Recommended Practice, 1999
IESNA, IESNA TM -11-00 IESNA Technical Memorandum on Light Trespass: Research, Results and
Recommendations
IESNA, The IESNA Lighting Handbook, 9th Edition, M. Rea (ed.), 2000
IESNA, ANSOESNA RP -8-00 American National Standard Practice for Roadway Lighting, 2000
IESNA, IESNA RP -19-01 IESNA Recommended Practice for Roadway Sign Lighting, 2001
Lewin, I., Report to: Outdoor Advertising Association of America; Subject: Digital Billboard
Recommendations, Lighting Sciences Inc., Scottsdale, Arizona, 2008
Appendix A
Floodlit billboard luminance measurements presented in this report.
Number Advertisement Location AddressLocation Luminance Notes
(nits)
1
Miracle Auto Painting
Tempe, AZ
Tempe Marketplace
103
1
2
Chandler, AZ
202 @ McClintock Dr.
235
1
3
ClearChannel
Ahwatukee,
1-10 between Ray and
114
1
AZ
Chandler
4
Naumann Hobbs
Phoenix, AZ
1-10 & 43rd St.
174
2
5
Fry's
Tempe, AZ
Tempe Marketplace
124
2
6
Bankruptcy/Divorce
Phoenix, AZ
2511 W Indian School
82
2
7
Hastings & Hastings
Phoenix, AZ
1-10 & 42nd St.
42
2
8
Cox Cable
Phoenix, AZ
1-10 & 40th St.
23
2
9
Dare to Compare
Phoenix, AZ
Broadway & 40th St.
19
2
10
Select 55 Lightest Beer
Phoenix, AZ
Elwood & 40th St.
103
2
11
Recession 101
Phoenix, AZ
1-10 & 40th St.
100
2
12
100% USDA Fry's
Phoenix, AZ
Illini & 38th St.
71
2
13
MHM Inc.
Phoenix, AZ
1-10/7th St.
33
3
14
The Experts
Phoenix, AZ
1-10/7th St.
63
3
15
WhataBurger
Phoenix, AZ
I-10/Central Ave.
26
3
16
Univ. of Arizona
Phoenix, AZ
1-10/Central Ave.
40
3
17
Cricket
Phoenix, AZ
1-10/Central Ave.
44
3
18
Run Wild
Phoenix, AZ
1-10/Central Ave.
10
3
19
Kimberly-Clark
Phoenix, AZ
1-10/7th Ave.
75
3
20
Alcock
Phoenix, AZ
1-10/7th Ave.
70
3
21
Flying J
Phoenix, AZ
1-10/7th Ave.
60
3
22
Thirst — McDonalds
Phoenix, AZ
1-10/7th Ave.
30
3
23
Univ. of Arizona
Phoenix, AZ
1-10/7th Ave.
70
3
24
Arizona Heart Inst.
Phoenix, AZ
Durango Curve
53
3
25
Bud Select
Phoenix, AZ
Durango Curve
10
3
26
Park University
Phoenix, AZ
Durango Curve
57
3
27
Geico
Phoenix, AZ
Durango Curve
28
3
28
Michelob
Phoenix, AZ
Durango Curve
73
3
29
Cabella
Phoenix, AZ
22nd Ave. —1-10
24
3
30
Location
Phoenix, AZ
22nd Ave. —1-10
48
3
31
Burger King
Phoenix, AZ
22nd Ave. —1-10
25
3
32
AAA
Phoenix, AZ
16th Ave. - 1-10
6
3
33
Buick
Phoenix, AZ
16th Ave. - 1-10
45
3
34
Lowes
Phoenix, AZ
16th Ave. - 1-10
50
3
35
AZ Lottery
Phoenix, AZ
16th Ave. - 1-10
32
3
36
Landshark
Phoenix, AZ
16th Ave. - 1-10
70
3
37
Qwest Espanol
Phoenix, AZ
11th Ave -1-10
30
3
38
Dex
Phoenix, AZ
11th Ave -1-10
15
3
39
Ronald McDonald
Phoenix, AZ
11th Ave -1-10
18
3
40
Coors Light
Phoenix, AZ
11th Ave -1-10
45
3
41
Senior Care
Phoenix, AZ
7th Ave. —1-10
30
3
42
KTAR
Phoenix, AZ
7t Ave. —1-10
35
3
43
Cancer
Phoenix, AZ
7h Ave. —1-10
40
3
44
Geico
Phoenix, AZ
Central —1-10
36
3
45
St. Lukes Espanol
Phoenix, AZ
Central —1-10
60
3
46
L4D
Phoenix, AZ
Central —1-10
10
3
47
Run Wild
Phoenix, AZ
Central —1-10
16
3
48
Easy Street
Phoenix, AZ
Central —1-10
42
3
49
PHX Zoo
Phoenix, AZ
Central —1-10
50
3
50
Left 4 Dead
Phoenix, AZ
7th St. — I —10
6
3
51
Bud Light
Phoenix, AZ
7th St. — I —10
60
3
52
Mc Donalds
Phoenix, AZ
7" St. — I —10
60
3
53
U of Phx Espanol
Phoenix, AZ
7th St. — I —10
46
3
54
Chipotle
Phoenix, AZ
7th St. — I —10
56
3
55
Droid
Phoenix, AZ
16" St. —1-10
46
3
56
Plainfield, IL
12040 Aero Dr.
76
4
57
Plainfield, IL
12501 S Rte. 59
46
4
58
Naperville, IL
3004111th St.
68
4
Notes:1 measured by P. Scowen; 2 measured by J. and T. Polakis; 3 measured by H. Israel; 4 B. Radner,
Assistant
Director, Will County Land
Use Department, Memorandum 1 November 2010
Digital Billboards:
New Regulations for New Technology
A reprint of the Illinois Coalition for Responsible Outdoor Lighting website page at
http://www.iIlinoislighting.org/billboards.htmI
State, county, and municipal leaders across the U.S. are finding themselves with a new
issue on their agendas: the latest generation of outdoor advertising signage, the digital
billboard. Also known as LED or electronic billboards, dynamic signage, constantly
variable signs, and other names, these signs are a whole new ballgame in outdoor
advertising.
The digital technology features two major changes from the old "static" signage, which
is graphics painted or printed on a surface. The image in the digital sign is displayed by
a myriad of colored "lightbulbs" (light -emitting diodes, or LEDs, actually). So while the
static sign is visible from daylight reflecting off it (or artificial lighting at night), the digital
image shines out, akin to a television set. In the digital signs, the image is supplied to
the sign by a computer; the image can be varied at will, right up to functioning as a Hi -
Def television display. These two properties -- potential for both intense surface
brightness and motion -- pose questions to safety and esthetics issues beyond those
raised by the old static signs, and require new analysis by agencies tasked with
regulating outdoor advertising.
Digital display technology (as in this artist's conception) allows for much greater surface brightness than
old "static" signage, and sudden changes in display.
It makes sense to start off this discussion by addressing the topic of digital billboards
and the future. The large outdoor advertising companies have embraced this technology
as the replacement for static signage; in their book, it is the technology which is here to
stay. To quote a promotional video from the Trans -Lux company, "Nothing's as eye-
catching as an electronic LED display. The brightly -lit text and graphics can be seen
from hundreds of feet away, drawing the attention of everyone within view." Space on
the electronic signs is marketed as being superior to that on static signs; it can cost as
much or more to run your company's sign on the digital billboard as to rent a static one,
even though your sign may only be shown a small percentage of the time on the digital
display, alternating with as many as eight or more others. While the investment in a
page 1 of 10
digital sign is a large one (often quoted as $250,000 - $500,000), the anticipated return
is great. Overhead costs are also cut for the advertising companies; when signs are
designed, they no longer need to be printed, and then installed by a crew in the field; at
the click of a computer mouse, the sign graphic is wired or radioed to the digital
billboard for display. The companies in the multi -billion -dollar outdoor advertising field
have a large financial incentive to change most outdoor signage from static to digital
over the coming years.
Why is our coalition for responsible outdoor lighting discussing the subject of digital
billboards? There are a few issues which directly involve questions of illumination which
we address. The signs emit light into the nocturnal environment, potentially including
residential and natural areas and the sky; they consume large amounts of electricity;
their presence can affect public safety, most commonly by distracting drivers (which,
after all, is the signs' precise intent and purpose). To understand these issues, and
consider ordinances which should regulate the placement and operation of these signs,
we need to understand the details of how the various effects are measured.
Unfortunately, this is not common knowledge; state and local managers may not be
familiar with principles and metrics which apply. Our intent in this paper is to provide
some practical definitions, and cite sensible, logical and defensible levels of regulation.
LUMINANCE
Luminance is a measure of the perceived
brightness of a surface. This differs from
illuminance, which is a measure of the amount
of light falling onto a surface. Luminance is a
key measurement when analyzing surfaces
which emit light, like a computer or television
screen, or a digital billboard. Luminance, with
this sort of light -emitting device, is controlled by
the settings of the device itself. Illuminance is
what allows us to see items which don't emit light; light (illumination) coming from other
sources reflects off the object, rendering it visible to us; illuminance is determined by the
brightness and location of the external light source(s). But any object which we can see
has a specific level of surface brightness or luminance. A computer screen turned up to
high brightness puts out more light per square inch of its surface than when it is set to
low; a piece of paper in the full sun reflects more light per square inch than one in
candlelight. The two billboards in the photo above each present a certain surface
brightness to the observer's eye, whether they emit light like the digital one on the left,
or reflect light like the "static" one on the right.
Illuminance (illumination) is usually measured in units of foot-candles or lux; luminance
(surface brightness) is most often measured in nits or candela per square meter (cd/m2),
which are equivalent. (For further discussion of these units or any other technical terms
used in this paper, see our website's EDSNg1p,pqLlia of T rn'i page.)
Luminance plays a critical role in how a sign like a billboard interacts with the
environment around it. During the daytime, a static billboard lit by the natural daylight
page 2 of 10
will appear to the eye to have a brightness which "fits in" with its surroundings; it will not
cause excessive distraction because of an unusual level of luminance. (Perception
studies show that having something in our field of vision which is either much brighter or
darker than its surroundings causes an involuntarily shift of our vision to the object.) A
digital sign which is set to a luminance level higher than that of the other objects around
it, which are lit by daylight alone, can potentially draw a driver's eyes to the sign when
they need to be looking elsewhere to safely operate their vehicle; levels can even be so
high as to cause vision -disturbing glare.
The luminance level which a digital sign needs to be set at to be visible in the daylight is
far above that needed at dusk or night. This effect can be seen with other luminous
displays, such as on cellphones and laptop computers; brightness levels which seem
high indoors are totally inadequate outside in the much brighter direct sunlight. The eye
of the driver at night compensates for lower light levels by becoming more sensitive to
light; it is even more easily distracted, dazzled, and even disabled by an overly luminous
object than the daytime eye is.
SAFE AND SENSIBLE LIMITS FOR LUMINANCE
While an advertiser's desire might be to draw everyone's attention, for as long as
possible, in the most potent methods possible, logic dictates that it is not in our best
interest to have people who are at the moment operating motor vehicles (and hopefully
practicing defensive driving, monitoring all the other vehicles and activity around, ahead,
and behind their vehicle) be inordinately distracted from that task by advertising or
anything else not related to safe driving. While this goal does not in itself dictate specific
limits to the luminance level of electronic signs, it suggests a logical course for deriving
such limits.
For daylight hours, the maximum luminance level for digital signage should be similar to
what the luminance of an identical sign would be if it was printed out and installed on a
static billboard. In other words, the digital sign would appear no brighter, no more
intense, that the printed sign next to it, or the landscape surrounding it. In practice,
setting a limit of 5000 nits (setting the sign's intensity so that an area on it displaying full -
brightness white has no higher luminance than that figure) ends up delivering a surface
brightness similar to landscape illuminated by sunlight.
At dusk and nighttime, a logical conclusion would be that new digital billboards do not
need to operate at higher surface brightness than the static ones which they are
replacing. The outdoor advertising industry has not, for decades, been telling its
customers that their nighttime advertising is ineffective; quite the contrary. So, what
could be the rationale for setting nighttime luminance limits which are higher than the
brightness of the existing static signs? However, if such limits are not set, it seems that
the advertising industry will be pushing the envelope out further and further, increasing
the distractive effects of the digital signs, the potential disruption of visual perception,
and the flooding of the surrounding neighborhoods with excess light.
page 3 of 10
The single photograph in the frame above, taken May 24, 2010, shows two adjacent
billboards; the one in back (left) a static sign, lit from below by metal halide luminaires,
which obviously has a lower surface brightness that the one in front (right), which is
digital.
From independent surveys of static billboards, we have a good summary of levels of
surface brightness that those signs are currently commonly operated at. A 2009 survey
of static billboards in Arizona found that, out of 565 measured, 98% had a luminance of
less than 150 nits, and 83% measured below 100 nits. A smaller 2008 survey' in New
York State found an average nighttime luminance of 124 nits for static billboards.
The IESNA Lighting Handbook recommends for "illuminated billboards and other large
advertising panels", illuminating such signs at night with 1000 lux in bright locations, and
500 lux for ones in dark surroundings. Assuming that a static billboard has a white face
with a reflectance of 0.8, the luminance of such a billboard would be 250 nits in the
setting (1000 lux) for brightly illuminated surroundings, and 125 nits in the low -light
setting (500 lux illumination). Many digital billboards are mounted on tall masts, above
the driver/viewer, so they appear to "hang in the sky"; at night, this would place them
against that dark background, making the darker -surroundings setting appropriate.
MEASURING LUMINANCE
The Outdoor Advertising Association of America (the trade group of the billboard
industry) hired Dr. Ian Lewin, CEO of Lighting Sciences, Inc. to write a report on "Digital
Billboard Recommendations and Comparisons to Conventional Billboards" 3. The report
proposes both a set of sign brightness limits, and a methodology for estimating sign
brightness. The report is widely cited by the billboard industry as the be-all, end-all of
expert opinion on the matter of sign brightness and safety, but we find it to be notably
flawed in several aspects.
Luminance can be directly measured with a special instrument called a
luminance meter. It works much like a camera, focusing on the surface
which one is determining the brightness of, and measuring that surface's
light output per angular degree of area. Lewin suggests that these
meters, which may cost several thousand dollars, are too expensive for
local sign installers and regulators to obtain. Therefore, instead of direct
measurement with a luminance meter (like the one shown on the right),
page 4 of 10
he suggests obtaining an approximate measurement by using a more common,
generally less expensive illuminance light meter (as shown below). While the cost
savings suggestion is laudable, the proposed indirect method contains several flaws
when applied to real-world situations, leaving it, in our opinion, too lacking to use
anywhere outside of the theoretical laboratory. Lewin's method involves positioning the
observer with the light meter a known distance in front of the sign in question, and
taking one measurement of all the light falling on the light meter while the sign is
illuminated, and another reading while the sign is turned off. The difference between the
two measurements should be the contribution of illuminance from the sign, and if you
know the exact overall size of the sign, and just how far from the sign the
measurements were taken, you can compute the approximate average surface
brightness of the sign.
With a luminance meter, surface brightness can be measured
from any (unspecified) distance, as long as the surface to be
measured fills the field of view of the meter. With the indirect
method, you need to know the distance precisely, and to use
Lewin's "easy" table of calculation, the distance has to be a
pre-set value, like 200 or 250 feet. In the real world, billboards
are often located in hard to reach spots; 200' in front might be a
private property, a highway, a pond, etc. To measure the
distance in most situations, a tape measure would not be practical; either a laser
rangefinder or a precise GPS unit would be needed; purchasing that equipment would
notably reduce the cost difference between the luminance and illuminance meters.
With the luminance meter, the brightness measurement can be taken in any condition of
ambient light -- bright or cloudy day, dusk, or night. With the illuminance method,
daytime light levels will overpower the light readings; separating out the contribution
from the sign will be next to impossible to do to any level of accuracy. Finding this flaw
in Lewin's proposal is not surprising, because he does not address the subject of
limiting luminance during the daylight hours. When discussing digital billboard
technology, this is a glaring omission (no pun intended). Currentroduction models of
LED displays can achieve surface brightness of over 13,000 nits ; this is intensly bright
in the daylight, especially on overcast days. (As a comparison, the bright blue daytime
sky ranges from around 5,000 to 7,000 nits in luminance.) We need to set limits for
daytime sign luminance, too, and to be able to measure that performance.
With the luminance meter, the apparent surface brightness can be measured at any
angle; this includes taking measurements directly from whatever areas of roadway
where the sign will be in view. If the Lewin measurement is taken from the ground in
front of the sign, that will often place the observer notably below the sign (billboards
along roadways often being mounted high off the ground, especially those installed
along elevated highways). The light emanating from digital billboards is somewhat
directional; it is notably more intense along an axis extending out perpendicularly from
the sign's face, and drops off in intensity as the angle away from that axis increases.
The observer at ground level, often 30 feet or more below the lower edge of sign, will
not be intercepting the most intense output of light.
page 5 of 10
The Lewin method requires manipulating the sign display, to take one reading with the
sign on, and one with it off. This precludes the ability to independently measure sign
luminance for code enforcement, because the sign operators will be choosing the
luminance settings during the test. With a luminance meter, any sign can be checked for
compliance at any time, without requiring the involvement of the sign owner/operator.
LIGHT TRESPASS
Light trespass is an issue related to the luminance of a light source, but it is generally
measured in a different way. Instead of considering the surface brightness of the source
(which needs to be regulated separately, as described above), trespass is looked at in
terms of the level of illumination (illuminance) which the light source on one property
shines onto another property. So for this value, we do look at foot-candles (or lux) of
illuminance, generally at the property line of the property being trespassed upon; we do
measure it directly with the illuminance light meter. (Illuminance trespass can also be
calculated during engineering with computer modeling, by inputting the light output
levels and pattern of the light source(s), and the physical layout of the properties
involved.)
In his paper, Lewin uses the term "light trespass," but not in the way which it has
normally been addressed in outdoor lighting regulation. He posits a set of distances
away from the billboards at which to measure illuminance levels, rather than using the
fairly standardized concept of property boundaries. His measurement points (at as far
as 350' from the sign) might end up being on the same parcel which the sign in question
is located on, or the next one over, or one beyond that. This points out a major
difference between sign illumination and most other outdoor illumination; the later
generally serves the purpose of illuminating the property it is installed on; the former
(signs) are often intended expressly to illuminate (be seen from) adjoining properties, or
across entire neighborhoods.
So, comparing the Lewin proposal for limiting "trespass" to the traditional concept of
limiting light trespass is difficult. He arrives (through, I might add, what seems to be an
elaborate use of cherry -picked logic) at a figure of 0.3 foot-candles as his recommended
limit for nighttime trespass at his table of random distances out in front of various
billboard sizes. This shouldn't be mistakenly equated with the location of a neighboring
property; if there was 0.3 f.c. at 350', but a house was only 175' away, the trespass level
to that house would be four times higher.
Trespass should be measured to property lines. Admittedly, this puts billboards at a
disadvantage; it is not uncommon for them to be located on parcels which are barely
larger than the footprint of the signs themselves. But why should they be allowed to light
up adjacent properties any more than any other form of artificial illumination?
Some municipalities, townships, counties and states have light trespass regulations. For
trespass on to properties with any residential class of zoning, a limit of 0.1 foot-candles
is not uncommon. In Illinois, some jurisdictions which have the 0.1 f.c. limit include
Barrington Hills, Crystal Lake, Elk Grove, Homer Glen, Mt. Prospect, Mt. Vernon,
Naperville, Palatine, Park Ridge, Springfield, Urbana, and even Scott Air Force Base.
page 6 of 10
MOTION & DISTRACTION
Digital signs have the ability to display anything which a television or computer monitor
can, including "moving images". It is obvious that a Panavision movie playing along side
a highway would constitute a grossly unsafe distraction hazard for vehicle operators.
The Outdoor Advertising Association of America has accepted that concept, and in its
Code of Industry Practice now states that full-sized billboards should not feature
animation, flashing lights, scrolling, or full -motion video. This self-imposed code of
conduct is laudable, but is missing (at least) two key points.
First, they limit their suggestion to not use moving images to full-sized billboards only. It
is fine with them if "street -sized" signs along the roadways in our busy towns and cities
feature any sort of animation or television -like video. Apparently, they believe that
roadway accidents caused by distraction only occur on highways.
Second, when one image changes to another on a sign within a person's field of view,
the viewer's visual system perceives that change as motion, even though the two
images themselves were "static." (This is how motion pictures operate; they present the
viewer a series of static images, and the mind "sees" motion.) If there is one sign ahead
of us, and it turns into another, what we perceive is a flash, and/or movement. So,
paradoxically, the billboard companies say they won't operate flashing or moving
billboards, but they cannot avoid those effects if they change the displayed images
while we are watching. They also display ads which continue on multiple "frames,"
encouraging the viewer to stare at the sign for a prolonged time to see the next
installment.
OTHER REAL-WORLD CONCERNS
In addressing the issue of sky glow (the "light pollution" which emptied the nighttime
sky of most of its stars over our towns and cities over the past few decades), Lewin
notes that most digital billboard units feature a set of louvers which limit the amount of
light they project upwards. In reality, those louvers are installed to shade the light -
emitting diodes from sunlight, to increase the contrast of the signs during the day and
reduce solar heating. But, they do reduce the amount of light shining "up."
However, the light projection at lower angles above the horizontal is not impeded by the
louvers. As described in the seminal paper "Lighting and Astronomy" by Luginbuhl,
'walker & Wainscoat5, light emitted between the horizontal and just 200 above it
contributes much more to skyglow than light emitted at higher angles, and that low -
angle light's effects are visible over a much broader area. So, the sunshade louvers built
into many digital signs do little to minimize their impact on the night sky.
The outdoor advertisers like to point out some studies (most of which they
commissioned) which show negligible traffic safety problems related to existing digital
signage. But this is new technology; we don't have enough real-world data to make
accurate judgments yet. There are vast numbers of billboards in the U.S. (the OAAA
estimates 450,000), and only a tiny fraction have been converted to digital. Short-term
analysis of that small percentage will not address the safety effect that large-scale, long
page 7 of 10
term installation will have. Picture an Illinois highway which already has a bewildering
display of billboards, like stretches of 1-294 and 1-55 near Chicago, with all of those
signs converted to digital, changing displays. Now picture it with all those displays
turned up to excessive brightness. Many of us can discern that such a situation would
pose increased driving hazards, without the need for a study, or for the accidents,
injuries and fatalities which might occur during the study period.
The big "selling point" which the outdoor advertising companies use is that the digital
signs may be used for posting Amber Alerts in real-time. This is a genuine public
service, and is lauded by many in law enforcement. However, operating roadside signs
every day and night at levels of brightness which makes them too highly distracting
could negate the public safety positives of Amber Alerts by increasing everyone's risk of
accident and injury in the vicinity.
We have heard some people suggest that there are other distraction hazards on the
roads which pose greater dangers, like drivers talking on cell phones, text messaging,
eating, reading, etc. Yes, those are obvious real hazards. But their existence does not
somehow make it logical that we should add even more distractions on the roadways of
this country. Over thirty thousand people die each year here in traffic accidents; this is a
horrible epidemic, and we need to be figuring out how to combat it, rather than
shrugging off safety concerns.
In the real world, once digital billboards are installed, most local regulatory agencies will
find it virtually impossible to ever remove them. If they were allowed by existing
regulations (or lack thereof) to be installed, even removal called for by a change in
those regulations will generally require condemnation procedures to be instituted; that
will entail the governmental body purchasing each offending sign from its owner. At a
quarter to a half of a million dollars per sign, this cost is not affordable to most local
governments, no matter how objectionable they or the citizens of the area have found
the signs to end up being, how the land usage in the areas around the signs has
changed over time, or if signs need to be removed because of road widening or other
civic projects.
SUMMARY
Our organization is not "anti -billboards". We believe that the residents of each
jurisdiction should decide what sort of outdoor advertising should be allowable in their
neighborhoods.
We are also not beholden in any way to the outdoor advertising industry, or any related
trades; we accept no contributions of any sort from these industries. Nor does our
organization or any of its board members stand to gain or lose anything of monetary
value based on the successes or failures of the outdoor advertising industry.
Our charter, as explained elsewhere across this website, is to speak as independent
advocates for safe, environmentally responsible outdoor illumination practices, including
a focused look at energy conservation. Filling that charter, we have studied the potential
real-world ramifications of digital sign technology, including a focus on practical
page 8 of 10
engineering (rather than vague theory) and on precedents which can be derived from
other, well-established technology. Our recommendations for ordinances to govern the
installation and operation of digital signage include the following:
o All digital signage visible from roadways (not just billboard -sized signs) should
only be allowed to display non -animated images, and each image must be
displayed ("dwell") for a minimum of ten seconds. Longer delay times should be
set by local regulation as is needed in specific installations where distraction
hazards are especially high.
o All self -luminous outdoor signs should be subject to surface luminosity limits,
both during the daytime and nighttime hours. During the daytime, based on
normal daylight illumination, a maximum limit of 5,000 nits will keep luminous
signage balanced with the surrounding landscape. During the nighttime hours, a
luminosity limit of 150 nits will provide a surface brightness for digital signs which
is comparable to the nighttime signage which is widespread across this nation,
and is in line with the sign illumination level recommendations of the Illuminating
Engineering Society of North America (IESNA). If the nighttime luminance setting
and limit is based on the sign in question being set to display full white, full
brightness field, a limit as high as 200 nits for this method of calibration and
testing is suitable. Incremental luminance limits between the nighttime limit and
the full sunlight limit may also be specified for overcast or foggy days, or for dusk;
or regulations may require an automatic control of sign luminance based on the
ambient lighting condition, to throttle the sign luminance between the sunny -day
and night maximums.
o Surface luminosity measurements should be made directly with a calibrated
luminosity meter, following the instrument manufacturer's instructions. Readings
should be taken from the area (generally of roadway) where the sign in question
will be visible from, and which is closest to being directly in front of the sign
(where the luminosity output is most focused).
o Outdoor signage should obey light trespass regulations. Into areas zoned for
any type of residential occupation (including parks and preserves so zoned), a
trespass limit of 0.1 foot-candles should be enforced, at the property line.
Considering the effect which large-scale outdoor signage may have on property values
and quality of life issues, regulatory bodies should require public notification and allow
public comment when sign permits are applied for, including requests to convert existing
static billboards to digital.
Currently, some outdoor advertising companies are offering local regulators a "swap -out
plan", where they will remove more than one square foot of existing static billboards for
each square foot of replacement digital billboard. From an environmental perspective,
such an overall reduction in illuminated signage could be an advance. But that only
true if the new signage is no brighter, per square foot, than what it is replacing!
Without regulation to enforce those operating parameters, digital signage may generate
page 9 of 10
negative environmental and safety impacts many orders of magnitude worse than the
old signage it is poised to replace.
UPDATES:
Since this article was written, some good additional resources have become
available. The article LS,.4 -_5i ade
qi l hia's Green Rftirp" by Gregory
�A gg
Young provides an excellent overview of digital signage, and focuses in depth on the
substantial energy consumption by such signs -- tens of times larger than that of
conventionally illuminated "static" signs.
An initial draft of the study "L).igit I LED Billboard Luminance Recomimendaboins: IHow
by Luginbuhl, Israel, Scowen, Polakis & Polakis has been
made available here for distribution; it covers many of the same issues addressed in
this article, and includes substantial real-world measurement of existing sign
illumination to provide a baseline in the discussion of brightness needs and limits.
' "Evaluation of Billboard Sign Luminances", Lighting Research Center, Rensselaer Polytechnic Institute,
March, 2008 2 "IESNA Lighting Handbook, Ninth Edition, July 2000, Mark Stanley Rea, ed. 3 "Digital
Billboard Recommendations and Comparisons to Conventional: Billboards", Ian Lewin Ph.D., FIES, L.C.,
Lighting Sciences, Inc., 2009 4 "P20 Outdoor Full Color I -ED Display", Shenzhen Only Optoelectronic
Technology Co., Ltd. website, June, 2011 5 "Lighting and Astronomy", Luginbuhl, Walker & Wainscoat,
Physics Today, December 2009
2010, Illinois Coalition for Responsible Outdoor Lighting, all rights reserved
page 10 of 10
Excerpts from City of Pittsburg Sign Code
919.02.0 Electronic Advertising Signs
1. General Electronic advertising signs may be erected, maintained, and
replaced according to the standards set forth below relating to motion, dwell
time, brightness, location, and operational controls as applicable. All
electronic advertising signs shall also comply with all requirements for signs
set forth in Article VI, Section 919 of the zoning ordinance.
2. Conflicts The provisions of this section shall take precedence over any
conflicting provisions in Section 919 relating to advertising signs unless the
conflicting provisions result in greater limitations on electronic advertising
signs.
3. New Electronic Advertising Signs Electronic Signs as defined in
Section 919.01.C.3 shall be permitted within AS -0 - Subdistrict A only, and
shall be approved by the Zoning Board of Adjustment as Special Exceptions,
according to the Special Exception Review Standards of 92:2,,,0,71, , and subject
to the following criteria:
(a) Motion All motion is prohibited on an electronic advertising sign
face. Electronic advertising signs shall have only static text and
graphics.
(b) Dwell Time The text, image, or display on an electronic
advertising sign may not change more than once every thirty (30)
seconds. Twirl time between subsequent text, images, or display
shall not exceed twenty-five hundredths (0.25) of a second.
(c) Brightness During daylight hours between sunrise and sunset,
luminance shall be no greater than two thousand five hundred (2,500)
nits. At all other times, luminance shall be no greater than two
hundred fifty (250) nits.
(d) Location
New electronic advertising signs are prohibited in i. City
Designated Historic Districts and the Riverfront Overlay
District as defined in 000.03.E.
No electronic advertising sign shall be erected or ii.
maintained in such a manner as to obscure or otherwise
physically interfere with an official traffic sign, signal or
device, or to obstruct or physically interfere with the driver's
view of approaching, merging or intersecting traffic.
(e) Controls/Testing/Annual Certification
All electronic advertising signs shall be equipped i. with an
automatic dimmer control or other mechanism that
automatically controls the sign's brightness as provided
above.
Prior to approval of any permit to operate an ii. electronic
advertising sign, the applicant shall certify that the sign has
been tested and complies with the motion, dwell time,
brightness, and other requirements herein.
The owner and/or operator of an electronic iii. advertising
sign shall submit an annual report to the City certifying that
the sign complies with the motion, dwell time, brightness, and
other requirements herein.
(f) Maintenance Routine maintenance of electronic advertising
signs is permitted including the replacement of solid state electronic
components, subject to compliance with regulations set forth in
Section, 91,E 9 .mC relating to motion, brightness, and dwell time.
4. Existing Electronic Advertising Signs Existing electronic advertising
signs that do not meet the standards set forth above for new electronic
advertising signs shall become non -conforming uses and structures subject
to the provisions of Article VII, Chapter 921, Nonconformities. Should an
existing electronic advertising sign be reconstructed then it shall be subject to
review and approval as a new Electronic Advertising Sign in accordance with
919.02.C.
OUTDOOR ADVERTISING
HE COR D/ 1111 E
February 4, 2014
City of Yakima
Planning Commission
129 N Second St
Yakima WA 98901
Dear Planning Commission:
Thank you for your efforts as you review the Yakima signage regulations. My name is
Tom Knaub, I am the District Manager for Lamar Outdoor Advertising and have an office
at 401 East Yakima Avenue in The Tower. I have attended most of the commission work
shop meetings and have a couple of comments and concerns.
The planning director, Mr. Steve Osguthrope, has mentioned several times that a majority
of the billboards in Yakima are for out of area businesses. Although I can only speak for
Lamar Outdoor Advertising, my experience does not support his claim. Looking at my
inventory, 78% of the ads are for Yakima businesses or for products sold by Yakima
businesses.
I believe that Mr. Osguthrope continues to disregard Legends Casino as a local business. l
believe that the casino which is only 20 minutes away, injects a lot of revenue into the
Yakima economy. I also believe that Legends Casino would state that they are a local
business and that they are very generous when it comes to sponsoring local Yakima events
and the local community
Mr. Osguthrope implied that the main reason that the billboard companies offer Public
Service Announcements (PSA) ads is to generate a tax benefit. I personally find that
statement offensive. Does that apply to any Yakima business that contributes to charity or
is it just the billboard industry? There are many Yakima residents that benefit from PSA
ads that direct people to agencies that offer help for drug addition, teen pregnancy, foster
homes and even human trafficking. If the City of Yakima wants to eliminate those kinds of
ads or the opportunity for the billboard industry to offer them, I believe it will be sending a
very negative message to the community.
Mr. Osguthrope has mentioned several times how the billboard industry cuts down trees to
improve the read on their billboards. As the Yakima planning director he knows that to
even trim trees on Yakima City property that the tree trimmer needs to apply for and
receive a permit to do so which would include permission from the city. Trees on state
right of ways are similar. Lamar Outdoor Advertising always obtains permits before
trimming any trees.
402 E. Yakima Avenue • Suite 1090-C • Yakima, WA 98901 • (509) 248-2366 • Fax (509) 248-2493
OUTDOOR ADVERTISING
I am in total agreement with Mr. Osguthrope that the condition of many of the Yakima
billboard structures is appalling. I believe that the main offender is CBS Outdoor. They
have many poster structures in Yakima that are left in disrepair. Lamar Outdoor
Advertising would support any regulation that requires the upkeep of all billboard ads.
Does the city have the right to "red tag" a billboard that looks unsightly? This may be a
solution to this problem.
If the planning commission would like to reduce the number of billboard panels on N. 15r
may I suggest adopting a cap and replace policy that would allow billboards to be moved
from the area of congestion to other areas of Yakima that are in need of affordable
billboard advertising. As development increases on the west side of town, some locations
may open up that meet the city's qualifications.
As the planning commission looks at the possibility of amortization, I suggest looking at the
Washington statutes that pertain to compensation for the taking of private property. My
interpretation is that billboards that are forced to be removed due to city ordinances will
be eligible for compensation from the City of Yakima for the loss of revenue that would
have been generated for many years. The cost would be millions of dollars to the City of
Yakima.
If anyone on the planning commission has any questions, please feel free to email me at
tic,oaub(iixlaiLwt ont or call me at (509) 679-8531 and I will do my best to answer any
questions or respond to your concerns.
Thank you,
Tom Knaub
District Manager
Lamar Outdoor Advertising
402 E. Yakima Avenue - Suite 1090-C • Yakima, WA 98901 • (509) 248-2366 • Fax (509) 248-2493
F0 11 I"I 1E
Wll:i C,O I / 111,1"
O U T O® O R
TO: Yakima City Planning Commission
FROM: Peter Grover, Metro Outdoor
SUBJECT: Billboards & Digital Signs
DATE: January 29, 2014
This letter is in response to the memorandum from Steve Osguthorpe regarding billboards and digital
signs dated January 29, 2014.
Differentiating Billboards from On -Premise Signs
The industry is in full agreement as to the purpose of on -premise advertising as well as the fact that on -
premise signage is an essential and crucial component of a local business. Billboards sell space to
businesses not located on the property on which it is located. This is per the city code and necessary,
otherwise, all businesses would have a billboard instead of an on -premise sign as billboards may be
larger in size. It is completely false to state that the majority of entities that advertise on billboards are
located out of the city, region, state or country. Our advertisers are over 95% local, not the opposite,
and this is the same with Lamar Advertising. What isn't understood is that many businesses such as
Anheuser Busch are local buys are come directly out of the local distributor who provide a lot of
employment and tax revenue to the city. There are many businesses in Yakima that have a parent
company out of state; however, this doesn't make them any less relevant or bad businesses. Where a
company's home office is located is completely irrelevant to this discussion.
Costs to Local Government
1. Reduced Property Values: Billboards absolutely do not decrease property values located within
500 feet. The report referred to in Philadelphia has to do with homes near billboards which
would mean these homes were located in commercial or industrial areas. Making the
correlation that the billboards were the issue for decreased property value is completely
misleading. The reason for the decreased value was the proximity to commercial and industrial
activity. The fact is the properties on which our billboards are located increase in value as the
owners have an additional revenue source.
2. ° This is again completely false and misleading. To compare
major U.S. cities such as Philadelphia to a small city like Yakima is irrelevant. The major cities are
combating all sorts of other issues that a small city like Yakima does not have. Crime rates,
median income, and poverty rates are typically larger issues with the major cities. Attempting to
correlate these issues to billboards is absolutely nonsensical. Common sense would prevail that
having stricter billboard controls in Yakima would not help the poverty rate or median income in
Yakima. Ninety percent of the existing billboards in Yakima are east of 16th Avenue due to the
how the code in Yakima is written. The code is very strict and has a large required distance from
residential properties. This forces the billboards to be located on the long stretches of
METRO OUTDOOR, LLC
14362 N. Frank Lloyd Wright Blvd., Suite 1000 • Scottsdale, AZ 86260 • ph 4BO-477-6550 • fx 866-860-6952 • m 480-252-1178
commercial and industrial areas which are primarily east of 16`h Avenue. Commercial properties
on the west side of town typically do not have the required setback to residential.
3. Na Tax Revenue to Local Government: It is completely untrue to state that billboards generate
no revenue to local coffers. Although it may not be a direct correlation, the businesses that
advertise on billboards that need the exposure to help them be successful all pay a lot of taxes
to the local coffers. Again, over 90% of our businesses advertising are local. I think it is bad
policy to penalize any business because of who the city feels they are doing business with, this is
irrelevant. In addition, all of the sub -contractors for maintenance and installation work are local
businesses.
4. Minimal Return tc Local Economy: Again, who a business does business with to survive should
not be at issue, I don't think any business would appreciate such a regulation. Over ninety
percent of our advertisers are local.
a. Anheuser Busch and Budweiser is a local advertiser purchased directly from the local
distributor, same with MillerCoors. Coca-Cola can be purchased at any grocery store in
Yakima, any convenience store, and at most restaurants. McDonald's is a local
advertiser, so is Verizon. Some businesses such as these pay into a national fund and the
buys are placed in the markets where they are located.
b. The content should not be an issue here. Contrary to Toppenish banning new billboards,
Metro Outdoor built a new billboard in Toppenish in 2009 that is still in operation today.
Legend's Casino is a large part of the Valley's economic engine and provides many
sponsorships in the city of Yakima.
c. Public Service Advertising is a way for the industry to give back to the communities that
they serve. To penalize a company for helping it's community by providing free
advertising to non-profit organizations does not make any sense.
5. Litigation: I would agree that the likelihood of litigation can increase regarding amortization but
this litigation would come from any business or industry that is being required to remove some
of their business(es). Each billboard needs to be considered as a business operating on the
property. No city would require that several McDonald's Restaurants be removed because they
thought there were too many and not expect some push back from the owners of McDonald's.
Again, comparisons to a lawsuit in Los Angeles on two billboards that were generating
approximately $200,000 per month is completely beside the point. Attempting to cherry pick
lawsuits across the country in large cities and somehow make them relevant to the situation in
Yakima just doesn't work. There are thousands of other situations where the industry worked
with different cities, counties, and states to come up with amicable solutions to these types of
issues that didn't require any litigation. Issues arising requiring litigation in our industry are
extremely rare.
6. Reguired CoMpgolatigp to IndustoL, Again, any industry or business that is required to remove
a portion or all of their business due to a government taking is due just compensation.. The
example cited is simply not true as compensation is not provided if relocation is agreed upon,
only the relocation costs are paid. Comparing the costs to takings of billboards in Minnesota
where rates are 10 times what are obtained in Yakima are again inappropriate, especially since
METRO OUTDOOR, t LC
14362 N. Frank Lloyd Wright Blvd,, Suite 1000 w Scottsdale, h2 85260 - ph 480-4'7'7-6550 - f>. 866-560-60'52 e m 480-252..1178
LM R 0
there aren't any billboards on the interstate in Yakima. But again, the rates aren't comparable in
the least to those obtained in the large metro markets.
l The Highway Beautification Act absolutely does not allow
companies to clear cut public trees to improve visibility of their billboards; this is completely and
utterly false. Cutting or trimming any trees in our industry is an exhausting effort that requires
permits and approvals from all governing authorities. The example in Florida has to do with an
organization that deliberately planted the trees in an attempt to block the views after the
billboards had been in place for several years. The Florida Department of Transportation agreed
and had them relocated. This would be fair compromise for any business that had its value
severely diminished due to someone else's actions. One thing to consider regarding Lady Bird
Johnson and the Highway Beautification Act is that this bill did not prohibit billboards. This bill
only required states only to allow new billboards on the Interstate System to be in commercial
or industrial areas.
Billboard Regulations in Washington State
As stated earlier, revenue flows back to the cities, counties and states at a very high level. The survey
provided by Mr. Osguthorpe may have 91 percent banning additional billboards but that was the survey
he chose to provide. In addition, 31 of the 47 states surveyed are located in Western Washington which
has a completely different political and business climate as does Eastern Washington. Businesses look to
smaller cities like Yakima to operate in due to "business friendly" climate and lack of unnecessary
regulations and controls like the larger cities in Western Washington. I strongly believe that it is
immaterial as to what other cities are doing in regards to billboards and signage in general. What's
important here is what is most beneficial for the City of Yakima.
The State of Washington currently does not allow digital signage; however, this will change as they are
following the trend across the rest of the country with state after state changing their rules to allow for
digital signage. The industry is not focusing on getting this changed at the state level due to local
prohibitions, they are working with state officials to make this change to help meet the demand of
advertisers who have limited opportunities to advertise on the highways due to the already in place
tight controls on outdoor advertising. If the state were to allow for digital signage on state highways, it
would in no way affect the City of Yakima as there are no state highways in Yakima's city limits that
allow for outdoor advertising so this change wouldn't be seen whatsoever. There is no such thing as a
State's "shield of protection."
Potential for Proliferation:
If the potential were there, why didn't it happen? The existing code has been in place since the early
1990's. As I presented at a prior City Council and Planning Commission meeting recently, there hasn't
been a new billboard in Yakima in four and half years. The number of additional digital billboards hasn't
increased since 2009. The comparison to Rapid City, South Dakota is completely misrepresentative. I
14362 N, Frnnk I.Joyd Wright Blvd., Suite 1000 - Scottsdale, AP B5260 - ph 460 477-6550 - fx. BBB -060 6952 a in 4B0-252-1176
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personally worked in this market for almost two years and there are not 400 billboards in the city limits.
The example provided by Epic Outdoor includes their entire inventory of which only a small portion lies
within the city limits of Rapid City. The remainder is scattered out on the interstates and highways
surrounding the city in a three state radius which include 1-90 East, 1-90 West, Sturgis, Black Hills,
Nebraska, and Wyoming. A city the size of Rapid City may have 200 billboard faces; however, most
structures have two faces minimum so this would mean a total of 100 structures.
Derelict Conditions of Yakima's Billboards: I am in full agreement that our industry should never be
allowed to appear the way they do in the pictures provided by Mr. Osguthorpe. All of these pictures are
of the "poster" type and are typically sold on a short term basis. The company in question has recently
switched to a new "eco -friendly" poster which has been having some issues in the field with adhesion,
especially in cold weather. We are working diligently with this company to have the issues resolved. We
would support any language that requires the billboards to be maintained at all times and with proper
notice and failure to comply, have them removed.
Billboards are not the source of angst on North First Street, there have been issues with crime,
prostitution and drugs long before billboards were constructed. This issue is much deeper than
removing a few billboards and planting some trees.
Staff Tentative Recommendations on Billboards
1. Definition of billboard is acceptable.
2. Prohibition of new billboards is absolutely not necessary based on the fact that there
haven't been any new billboards in Yakima for over four years due to the already in
place strict regulations.
3. It is highly irresponsible to single out one industry on N. 15t Street and have portions of
their businesses removed. This is an expensive process and one that leads to litigation
from any industry affected. The city needs to work with local and civic leaders to come
up with a plan to effectively reduce crime, beautify and improve the area of N. First St.
Limit digital signs to:
a) Adopt industry standards on brightness levels. They are already widely accepted across
the country by cities, counties and states.
b) Whether static or animated does not make a difference. There has been animation on
off and on premise signage for years in Yakima.
c) Message change should be instantaneous, this is the generally accepted mode across
the country.
d) One digital billboard and one digital on -premise sign would be more acceptable than
one total per property as they are different types of signs and codes. This is again tying
the two types together.
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e) No billboards across the country are 33 square feet and effectively would be a
prohibition. A billboard less than 6' x 6' would have no effectiveness. The sizes allowed
in Yakima ate already the smallest standard in our industry.
f) Billboards aren't allowed in the zones he describes anyway, only commercial and
industrial. Limiting any signage to monochrome or dark background makes no impact on
the overall signage, however, it is extremely detrimental to on businesses as they can't
use their logos and colors.
In closing, there are approximately 60 actual billboard locations in the city of Yakima and well over a
thousand on -premise signs. The issue at hand is not a problem or proliferation with billboards or digital
billboards. We are in agreement on lighting levels that meet the industry standards which all companies
already follow. We are in support of requiring all signage to be maintained and not allowed to look like
the photo's presented in Mr. Osguthorpe's report and have a requirement to be removed if not rectified
in a certain time frame. As stated earlier, there hasn't been a new billboard or digital billboard in Yakima
in over four years. The facts are as follows:
Permit totals Since 2009 as of December 2013-
• Pole signs- 103
• Wall signs- 177
• Cell towners- 17
• Total: 297
• New billboards -1
Sincerely,
Peter A. Grover
Owner
Metro Outdoor, LLC
METRO OUTDOOR, 11 LC
14362 N Frank I._layd WrightEilvd„ Snipe 1000 - facat!Aale, AZ 65260 - ph 180..4'77.€;550 # N 000-1360-0952 in 400-252-1176
February 5, 2014
City of Yakima
Planning Commission
Dear Planning Commission,
INTERNATIONAL SIGN ASSOCIATION
On behalf of the International Sign Association (ISA) and the Northwest Sign Council (NWSC), I would like
to submit our organization's comments with regard to Introductory Discussion of billboards and digital
signs. The International Sign Association (ISA) is a 2000 -member trade association, the members of
which are manufacturers, users and suppliers of on -premise signs and other visual communications
products from the 50 United States and 60 countries around the world. ISA supports, promotes and
improves the visual communications industry, which sustains the nation's retail, distribution, service and
manufacturing industries. ISA and the NWSC work actively with officials throughout the northwest to
assist jurisdictions to create reasonable and effective sign regulations.
This letter is in response to the recommendations by Steve Osguthorpe and is included in your packet.
In addition to our recommendations from our January 29, 2014 letter we offer the following additional
comments on the draft digital sign regulations:
«� The proposed brightness limitations of 2500 nits during the day and 250 nits at night are not
supported by the NWSC or ISA. The daytime limitation of 2500 nits will not allow for enough
brightness for a digital sign to be safely seen or to function as intended. With the automatic
dimming ,daytime limitations are not needed. If the City desires to have a daytime limitation we
suggest 7,500 nits as this is based on field studies that were done in Los Angeles.
r We strongly recommend the industry standard .3 foot-candle approach since it is much easier
to enforce and has been proven in many jurisdictions
We do not believe that the manufactures can build and certify that a sign will be at the nits level
that you identified. We recommend that the applicant or owner certify that they will comply
with the operational and brightness standards that are adopted by the City,
• We do not support the color restrictions and dark background restrictions as this will be difficult
to enforce and not needed with the recommended brightness limitations.
Again, ISA and the NWSC hopes that the Planning Commission, staff, Council, and other involved
stakeholders should consider these suggestions to the language of the proposed ordinance. Thank
you for your time and consideration to the ISA recommendations to the proposed regulations. ISA
would be happy to offer any additional assistance in understanding issues involved in the regulation of
on -premise signs.