Submission (attachment) to invitation for comment on
Draft transport corridor outdoor advertising and signage guidelines
David …..
17 January 2016
I first wish to state that I am very pleased Planning and Environment has developed
this excellent set of guidelines for transport corridor advertising, particularly for
rapidly proliferating digital billboard signage.
I have been concerned for some time that current guidelines did not address this
newly emerging technology and I have lobbied as a concerned citizen for two years in
this regard.
The proposal contains significant thoughtful controls which will benefit our State for
many years. In particular, controls on animation, illumination levels and protection of
significant sites are to be commended.
However, even signage that meets these guidelines, once erected, has the potential to
mar many wonderful streetscapes and landscapes for years to come.
The eternal problem arises that human nature confronted with stated controls runs
with abandon as close as possible to such lines in the sand. I recognise it is impossible
to legislate for good taste and common sense.
I have read carefully the draft document and I attach my submission addressing my
concerns.
1. DWELL TIMES TOO SHORT FOR DIGITAL BILLBOARDS
The dwell time for Digital signs where speed limit is below 80 km/hr should be
greater. Now set at 10 seconds, it should be at least twice this.
Digital advertisers openly promote on their websites the attention-grabbing impact of
ad changes on their large billboards.
APN Outdoor states on its website (http://www.apnoutdoor.com.au/products/digitalbillboards/):
Attention grabbing
The digital format enables incredible visibility, and when
paired with smart content, will get your business noticed.
Anticipation by a driver of refresh or change to such a sign offers a dangerous
distraction.
When a sign changes on a large illuminated billboard, drivers are psychologically
compelled to view this movement and assimilate new content with the potential for
distraction and resultant accidental injury or death to cyclists, pedestrians or other
pedestrians.
Further, speed limit should not be the sole criteria for categorisation of dwell time.
To provide two examples:
Along the Pacific Highway from North Sydney to Hornsby, the road is serpentine,
lanes are very narrow and traffic is typically very heavy and stop-start. Driving on
this road requires great concentration. Heavy transport, including busses and large
articulated vehicles, travels adjacent to small family cars. A digital billboard has
already been inappropriately erected by APN beside the Pymble railway Station on
this stretch of road.
Digital signage is often strategically placed to catch the attention of drivers while
waiting at traffic lights. With these dwell times, drivers are typically distracted by
anticipating changes of signage and do not observe the change of lights with potential
to cause accidents as well as create frustration for other drivers.
At present right turns for drivers across the path of pedestrians who have a green walk
sign is a major cause of pedestrian injury and death. Changing digital signs visible
from bus shelters or digital billboards, designed to “grab drivers’ attention” will cause
further deaths.
My ideal would be to admit that the purpose of dwell times is to grab attention in a
way static signs may not and to limit ad changes to hourly. Is there a reason such a
rule can not be imposed? Advertisers would still have the advantages of being able to
update remotely, avoid costs of sign changes and allow relevance and currency of
content.
The State Government had previously considered a minimum 12 sec dwell time, but
this is far too brief and should be at least 20 seconds. The time must be such that a
driver will not be predisposed to anticipate imminent changes.
2. EXCESSIVE VISUAL IMPACT POTENTIAL ON RURAL VISTAS
I support the restrictions outlined in the report on signage in significant rural vistas,
however these restrictions are still too liberal. Billboards should be banned from
unspoilt rural vistas.
Page 19 shows an illustration of a permitted sign where “surrounding vegetation
reduces unintended visual impacts”. The implication is that the advertiser has planted
the vegetation, but this is not made clear. This example serves to show the opposite
effect. The vegetation is a positive visual asset and is despoiled by the sign entirely.
Dense vegetation is not less worthy or protection from such signage as are open
vistas.
The example if followed literally would allow signage at the edge of roads in
attractive unspoilt forested and heavily vegetated areas.
The visual pollution of what are otherwise thoughtfully and tastefully landscaped and
well-maintained motorways is a serious concern and I believe this aspect needs
strengthening.
Not many years ago the NSW State Government removed many billboards along rural
corridors altogether and yet here even more numerous, larger and more visually
impactful billboards are permitted.
The requirement that “the overall number of signs placed along a transport corridor
should be minimized, preferably with only one advertising sign visible in a given
view” (p 15) is far too generous. If followed it will allow no portion of any trip to be
enjoyed free from the visual impact of such billboards.
3. DISTRACTING BUS SHELTER CYCLING SIGNAGE
These have become more common in recent years. JCDecaux has installed shelter
panels and bollards throughout the city and suburbs of Sydney. The panels always
face the direction of traffic and thus are intended to grab drivers’ attention. Their
audience is not intended to be bus patrons.
Frequently they have been thoughtlessly installed around bends or along very
congested roads. Digital panels have recently been installed along the Pacific
Highway throughout Lane Cove Council area.
I have measured the scrolling JCDecaux bus panels in Willoughby City along arterial
roads to have dwell times as low as 3 or 4 seconds. One example is on the Pacific
Highway outside Kenneth Slessor Park in Chatswood (4 seconds). Will dwell times
for these signs come under these guidelines?
These offer a dangerous distraction to drivers and state controls need to be established
for these rather than being left to Councils or the advertising companies.
4 DIFFICULTY AND COST OF REMOVAL
The difficulty and cost of removing large digital billboards (each costs over
$1,000,000 to install according to one report) from our landscapes in the future
justifies the most conservative and stringent regulation of their installation.
5 TIGHTENING QUALITATIVE REFERENCES
Qualitative, vague or value-laden expressions in the draft such as “if it is likely to
significantly impact on the amenity of…” (p 10) and “a landscape management plan
may be required” (p 18) allow excessive latitude in determinations.
Section 2.5.1 (p17) begins “Advertising structures should meet the following sitespecific
criteria” after which 8 mandated criteria are enumerated, however item (e)
does not mandate a landscape management plan.
These warrant a tightening of criteria.
6 PUBLIC BENEFIT TEST
The Public benefit Test outlined in section 4 is ambiguous.
The suggestion is made in 4.1 that a measure is made of the potential public benefit of
signage but this is then translated in subsequent sections to a possible payment to
offset such an impact.
This allows negative installations to be circumvented by a payment. This should not
be permitted.
Section 4 must specify that any advertisement in this category must nevertheless
meet all criteria in the rest of the document.
7 INTRUSIVE VMS SIGNS
(NB: This bullet point is wrongly placed on p 2 and should be positioned before
“Variable Message Signs (VMS) that are used for….” )
There has been a proliferation of VMS signage outside schools in the past two years.
This has been the result of very active promotion of such signs by particular
companies. These signs have been installed in suburban streets and are often
excessively animated and allowed to operate 24 hours a day.
Animated content is often banal or parochial and has relevance only to the school’s
own clients.
My understanding is that these guidelines will preclude in future the current practice
of constant animation (scrolling, flashing, colour changing) of such text or
animations.
If so, I support such a restriction as I have confronted such brightly lit signs,
containing extensive text and excessive animation both facing oncoming traffic at
busy intersections as well as in quiet suburban streets.
Again, I am encouraged by the issue of these draft guidelines and the opportunity to
voice a response and offer suggestions.
My central concerns remain dwell times, proliferation and positioning of large digital
billboards.
Many thanks,
David …..
Public Archive 
Submission (attachment) to invitation for comment on
Draft transport corridor outdoor advertising and signage guidelines
David …..
17 January 2016
I first wish to state that I am very pleased Planning and Environment has developed
this excellent set of guidelines for transport corridor advertising, particularly for
rapidly proliferating digital billboard signage.
I have been concerned for some time that current guidelines did not address this
newly emerging technology and I have lobbied as a concerned citizen for two years in
this regard.
The proposal contains significant thoughtful controls which will benefit our State for
many years. In particular, controls on animation, illumination levels and protection of
significant sites are to be commended.
However, even signage that meets these guidelines, once erected, has the potential to
mar many wonderful streetscapes and landscapes for years to come.
The eternal problem arises that human nature confronted with stated controls runs
with abandon as close as possible to such lines in the sand. I recognise it is impossible
to legislate for good taste and common sense.
I have read carefully the draft document and I attach my submission addressing my
concerns.
1. DWELL TIMES TOO SHORT FOR DIGITAL BILLBOARDS
The dwell time for Digital signs where speed limit is below 80 km/hr should be
greater. Now set at 10 seconds, it should be at least twice this.
Digital advertisers openly promote on their websites the attention-grabbing impact of
ad changes on their large billboards.
APN Outdoor states on its website (http://www.apnoutdoor.com.au/products/digitalbillboards/):
Attention grabbing
The digital format enables incredible visibility, and when
paired with smart content, will get your business noticed.
Anticipation by a driver of refresh or change to such a sign offers a dangerous
distraction.
When a sign changes on a large illuminated billboard, drivers are psychologically
compelled to view this movement and assimilate new content with the potential for
distraction and resultant accidental injury or death to cyclists, pedestrians or other
pedestrians.
Further, speed limit should not be the sole criteria for categorisation of dwell time.
To provide two examples:
Along the Pacific Highway from North Sydney to Hornsby, the road is serpentine,
lanes are very narrow and traffic is typically very heavy and stop-start. Driving on
this road requires great concentration. Heavy transport, including busses and large
articulated vehicles, travels adjacent to small family cars. A digital billboard has
already been inappropriately erected by APN beside the Pymble railway Station on
this stretch of road.
Digital signage is often strategically placed to catch the attention of drivers while
waiting at traffic lights. With these dwell times, drivers are typically distracted by
anticipating changes of signage and do not observe the change of lights with potential
to cause accidents as well as create frustration for other drivers.
At present right turns for drivers across the path of pedestrians who have a green walk
sign is a major cause of pedestrian injury and death. Changing digital signs visible
from bus shelters or digital billboards, designed to “grab drivers’ attention” will cause
further deaths.
My ideal would be to admit that the purpose of dwell times is to grab attention in a
way static signs may not and to limit ad changes to hourly. Is there a reason such a
rule can not be imposed? Advertisers would still have the advantages of being able to
update remotely, avoid costs of sign changes and allow relevance and currency of
content.
The State Government had previously considered a minimum 12 sec dwell time, but
this is far too brief and should be at least 20 seconds. The time must be such that a
driver will not be predisposed to anticipate imminent changes.
2. EXCESSIVE VISUAL IMPACT POTENTIAL ON RURAL VISTAS
I support the restrictions outlined in the report on signage in significant rural vistas,
however these restrictions are still too liberal. Billboards should be banned from
unspoilt rural vistas.
Page 19 shows an illustration of a permitted sign where “surrounding vegetation
reduces unintended visual impacts”. The implication is that the advertiser has planted
the vegetation, but this is not made clear. This example serves to show the opposite
effect. The vegetation is a positive visual asset and is despoiled by the sign entirely.
Dense vegetation is not less worthy or protection from such signage as are open
vistas.
The example if followed literally would allow signage at the edge of roads in
attractive unspoilt forested and heavily vegetated areas.
The visual pollution of what are otherwise thoughtfully and tastefully landscaped and
well-maintained motorways is a serious concern and I believe this aspect needs
strengthening.
Not many years ago the NSW State Government removed many billboards along rural
corridors altogether and yet here even more numerous, larger and more visually
impactful billboards are permitted.
The requirement that “the overall number of signs placed along a transport corridor
should be minimized, preferably with only one advertising sign visible in a given
view” (p 15) is far too generous. If followed it will allow no portion of any trip to be
enjoyed free from the visual impact of such billboards.
3. DISTRACTING BUS SHELTER CYCLING SIGNAGE
These have become more common in recent years. JCDecaux has installed shelter
panels and bollards throughout the city and suburbs of Sydney. The panels always
face the direction of traffic and thus are intended to grab drivers’ attention. Their
audience is not intended to be bus patrons.
Frequently they have been thoughtlessly installed around bends or along very
congested roads. Digital panels have recently been installed along the Pacific
Highway throughout Lane Cove Council area.
I have measured the scrolling JCDecaux bus panels in Willoughby City along arterial
roads to have dwell times as low as 3 or 4 seconds. One example is on the Pacific
Highway outside Kenneth Slessor Park in Chatswood (4 seconds). Will dwell times
for these signs come under these guidelines?
These offer a dangerous distraction to drivers and state controls need to be established
for these rather than being left to Councils or the advertising companies.
4 DIFFICULTY AND COST OF REMOVAL
The difficulty and cost of removing large digital billboards (each costs over
$1,000,000 to install according to one report) from our landscapes in the future
justifies the most conservative and stringent regulation of their installation.
5 TIGHTENING QUALITATIVE REFERENCES
Qualitative, vague or value-laden expressions in the draft such as “if it is likely to
significantly impact on the amenity of…” (p 10) and “a landscape management plan
may be required” (p 18) allow excessive latitude in determinations.
Section 2.5.1 (p17) begins “Advertising structures should meet the following sitespecific
criteria” after which 8 mandated criteria are enumerated, however item (e)
does not mandate a landscape management plan.
These warrant a tightening of criteria.
6 PUBLIC BENEFIT TEST
The Public benefit Test outlined in section 4 is ambiguous.
The suggestion is made in 4.1 that a measure is made of the potential public benefit of
signage but this is then translated in subsequent sections to a possible payment to
offset such an impact.
This allows negative installations to be circumvented by a payment. This should not
be permitted.
Section 4 must specify that any advertisement in this category must nevertheless
meet all criteria in the rest of the document.
7 INTRUSIVE VMS SIGNS
(NB: This bullet point is wrongly placed on p 2 and should be positioned before
“Variable Message Signs (VMS) that are used for….” )
There has been a proliferation of VMS signage outside schools in the past two years.
This has been the result of very active promotion of such signs by particular
companies. These signs have been installed in suburban streets and are often
excessively animated and allowed to operate 24 hours a day.
Animated content is often banal or parochial and has relevance only to the school’s
own clients.
My understanding is that these guidelines will preclude in future the current practice
of constant animation (scrolling, flashing, colour changing) of such text or
animations.
If so, I support such a restriction as I have confronted such brightly lit signs,
containing extensive text and excessive animation both facing oncoming traffic at
busy intersections as well as in quiet suburban streets.
Again, I am encouraged by the issue of these draft guidelines and the opportunity to
voice a response and offer suggestions.
My central concerns remain dwell times, proliferation and positioning of large digital
billboards.
Many thanks,
David …..