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Digital billboards to return though public overwhelmingly rejects

Updated: Nov 27, 2022


October 24, 2022


ONE GATEWAY PLAZA

Mail Stop 22-9

Los Angeles, CA 90012


Attn: Shine Ling, Development Review Team


Re: Transportation Communications Network (“TCN”) Draft Environmental Impact Report (DEIR), comments due October 24, 2022


Two decades ago, the City of Los Angeles imposed a ban on digital off-site signs, Ordinance 174547. Now, Metro and the City of Los Angeles have entered into a Memorandum of Agreement (C-139852) that would allow digital billboards to be erected on property that is co-owned by Metro and the City. For the reasons outlined more fully below, the Del Rey Residents Association (“DRRA”) is opposed to the Metro Transportation Communications Network (“TCN”) program. The following comments on the DEIR are not exhaustive of all our concerns but are those that are feasible for non-experts to address.


Aesthetics

The public has spoken and has been opposed to digital advertising for decades. Please see the dozens of communications from the public and community impact statements from Neighborhood Councils in Council Files 11-1705 and 22-0392. The DEIR has no discussion of the cumulative effects of visual clutter on the general public and drivers alike.


In Del Rey, we are most concerned about the billboards FF29 and FF30 proposed for the intersection of the Marina (90) Freeway and Culver Boulevard. That is next to the Ballona Wetlands Ecological Reserve, and we take issue with the DEIR conclusion that the potential impacts to views of the Ballona Wetlands would be less than significant (DEIR, IV.A.3.d. Threshold (a)(1)). We also disagree with the statement “Furthermore, based on the Site Location of the proposed TCN Structure next to a freeway or major roadway, their size and height, and the existing urban setting of the Site Locations and surroundings, the TCN Structures would not substantially contrast with the existing aesthetics features, such as trees, landscaping , and open space areas” (DEIR, IV.A.3.d, Threshold (c)). The signs would attract attention and detract from the benefits the open space of the Wetlands provide for drivers. Our comments on the TCN Initial Study[1] (attached) noted that a digital sign on a business at 5450 Lincoln Boulevard (in Del Rey) is clearly visible from the other side of the Ballona Wetlands (about 1.5 miles away). We would like Metro to respond to each of the concerns raised by us in that letter.

Despite our particular interest in ensuring that no digital billboards are erected near the Ballona Wetlands Ecological Reserve, and our desire to have all static billboards removed from Metro property along the Culver Blvd. Bike Path that runs through Del Rey (from the 405 freeway to McConnell Avenue, about 1.5 miles), we support Alternative One – the no project alternative. In our opinion, there is no take down ratio that would be sufficient to overcome the negative effects of digital billboards in Los Angeles.


The DRRA fully supports the removal of all static display billboards from Metro-owned property. Complete removal would improve the quality of life in our neighborhoods by reducing cyclist, driver and pedestrian distractions, reducing the commercialization of our lives and eradicating the unsightly structures that hold up the billboards. We should not have to allow digital billboards as the price for having the static billboards removed.

Biological Resources

According to the DEIR, the Project will have “less than significant” impact from “Substantial Light or Glare.” In fact, the DEIR fails to address the effect of light and noise from billboards on humans and wildlife. A recent article in The Atlantic[2] raises this issue, as does the story of the migrating goose that disrupted the October 12, 2022 Dodgers-Padres playoff game.[3] The best way to mitigate the light pollution from the digital billboards is to choose Alternative 1, i.e. No Project.



Energy consumption – Section IV.E

We disagree with the conclusion that the cumulative impacts reElated to energy use and conflicts with plans will have a less than significant impact.

According to the DEIR, the Project will result in a net increase in energy demand of 2,288,690 kWh per year. DEIR, Section IV.E. Per the U.S. Energy Information Administration, in 2020 the “average annual electricity consumption for a U.S. residential utility customer was 10,715 kWh.” Thus, the net increased use from the TCN will be equivalent to the energy consumption of 213 homes per year.

The DEIR analysis places too much reliance on the increase in energy usage as a percentage of the total sales (0.1%) of the Department of Water and Power (DWP). This is a specious argument given the size of DWP. We are in an era of climate change when the mandate is to reduce energy use, not rationalize ways to increase it. According to the DEIR, this Project is not contemplated to reach 100 percent renewable energy until 2035. Section IV.E.3.c.


Gov. Newsom has proposed clean electricity targets of 90% by 2035 and 95% by 2040. https://www.gov.ca.gov/2022/08/12/governor-newsoms-ambitious-climate-proposals- presented-to-legislature/ (8/12/22). Increasing consumption will make these targets harder to reach. Even if renewable energy were the answer to climate change, increases in consumption mean more renewable energy will need to be produced. Until 100% renewable energy is available for all, those using such energy force others to use continue using dirty energy.


The energy consumption of the digital billboards should be re-analyzed with an emphasis on the effects of the increase in energy use. We suggest that a redirected analysis will find that the demand during operation will cause wasteful, inefficient, and unnecessary use of energy and impacts will be significant.


Land Use and Planning, Section I.

The DEIR acknowledges that the Project Impact on Land Use and Planning would be “Significant and Unavoidable.”


The DEIR Section IV (Other CEQA Considerations) is required to discuss the significant and unavoidable impacts that would result from the Project, and the reasons why the Project is being proposed notwithstanding the significant and unavoidable impacts. Our Councilmember Mike Bonin summed it up clearly[4]: “[T]he scope and intent of the project is clear: install large digital billboards at highly visible Metro-owned locations for revenue generation purposes.” Other than the generation of revenue to be allocated in a manner yet to be specified, what benefit will result from Metro being allowed to ignore a ban on digital billboards that has been in place for two decades? A piecemeal dismantling of the ban will make it increasingly difficult to stop digital pollution of our environment. Why should Metro be allowed to erect digital billboards when private companies cannot?


Zoning

The Project will require an amendment to the Zoning Code that has not yet been written or approved, although the City Council has instructed the Department of City Planning to draft the amendment (CF 22-0392). After years of study, the City of Los Angeles has developed a new Zoning Code that is currently going through the adoption process with the Downtown Community Plan Update. The Zoning Ordinance enabling the implementation of the TCN Program would apply solely to the 56 proposed Site Locations for the TCN Structures and any locations for associated sign takedowns. (Executive Summary, page I-6). The DEIR does not explain why Metro needs a Zoning Code that is different from the one that the City Planning Commission recommended for approval on September 23, 2021.


Zoning near each of the 56 TCN Project sites and any potential takedown sites is a critical issue that has not been adequately considered.


1. The executive summary states that industrial zoning “is generally buffered by commercial uses to provide separation from residential uses.” Del Rey has several neighborhoods that are zoned Industrial, and yet apartment complexes and schools have been built in those areas, e.g. the area covered by the Glencoe Maxella Specific Plan and the area between Ballona Creek and Jefferson Boulevard. How will Metro ensure that the digital billboards are not built on Metro property that is next to areas that are de facto residential?


2. The State of California is hoping to make housing more affordable by allowing construction of housing in buildings that were previously zoned for commercial use.[5] The DRRA has been asked to consider a number of such projects, particularly in the Glencoe-Maxella Specific Plan area. However, current land use planning does not provide any certainty as to where those developments will occur. The DEIR should show how Metro is going to ensure that the TCN Project complies with the Community Plans that are being updated citywide. At a minimum, this should include a review of the draft plans that are in circulation and a letter from the Department of City Planning confirming that they agree or disagree with the statements in the DEIR.


The Palms Mar Vista Del Rey Community Plan was adopted in 1997 and has been going through updating since 2019. Del Rey is transected by Centinela Avenue and bounded by Lincoln, Washington, Sepulveda and Jefferson Boulevards. The State of California has changed the law to promote housing construction within half a mile of any of these streets. The analysis in the DEIR must ensure compatibility with planned and reasonably foreseeable residential use, not just with areas specifically zoned residential. For all project sites, adequate mitigation measures must include siting, orientation, buffering, and screening from all residential dwellings.


3. Alternative 3 assumes that the Project would “eliminate or relocate FF-29 and FF30 outside of the coastal area of the Palms-Mar Vista-Del Rey Community Plan.” The DEIR does not clearly define what is meant by the “coastal area of the Palms-Mar Vista – Del Rey Community Plan area” and should include a map showing where relocation might be considered. Except for the areas within the Glencoe-Maxella and Playa Vista Specific Plans, the rest of Del Rey falls within the Coastal Transportation Specific Plan. Parts of Del Rey also are within the jurisdiction of the California Coastal Commission. As stated above, we are opposed to FF-29 and FF-30 at any location.


Community Benefits

If digital billboards are permitted, who will decide what community benefits must be provided in exchange? Who will determine which community gets those benefits? How will the revenue sharing from the billboards be allocated within the City? Any system of allocation must provide for notice to the community, an opportunity for the community to be heard, consideration of the environmental impacts and findings.


Metro needs to analyze each potential TCN Project site separately and to provide data showing what was analyzed and what methodology was used. Each structure erected or taken down will have a unique environmental impact, depending on its location.


Take-downs

The DEIR states that in exchange for being allowed to erect 56 TCN structures (98 digital ad faces, according to Scenic LA), static billboards with twice the square footage of the digital billboards (DEIR page I-7) would be removed. This take-down ratio is far too low.

Because one digital billboard can feature ads from multiple advertisers, a digital billboard can generate far more revenue than a static billboard. At a minimum, the environmental impact of each digital billboard should be offset by taking down the number of static billboards that generate the same amount of revenue as the digital billboard. This is likely to be closer to a take-down ratio of 10 to one.


The DEIR does not explain how it would be decided which static billboards would be taken down and when that would occur. How would Metro ensure that those decisions are made fairly and equitably so that the static billboards are removed from the same neighborhood that is being burdened with a digital billboard?


Transportation: Section IV.K and Appendix K

Gibson relied on three studies to analyze the whether the TCN structures present potentially significant traffic safety concerns. Two of the three studies were conducted by the Foundation for Out of Home Advertising Research & Education (“FOARE”). DEIR Section IV.K.3.b. The FOARE research projects “help ensure OOH [out of home] advertising is competitive and a preferred means for marketing and promotion.” The Board of Directors of the Foundation are all from advertising companies.

The use of studies conducted by a foundation created to further the interests of the business that will benefit from the Project is an egregious conflict of interest. Moreover, studies that demonstrate safety concerns have been ignored. The Transportation analysis must be redone using unbiased research and without the use of the FOARE studies.

We note the oft-referenced study by the National Center for Transportation Systems Productivity and Management that “revealed that the presence of digital billboards increased the overall crash rates in areas of [digital] billboard influence compared to control areas downstream of the digital billboard locations.” Digital Advertising Billboards and Driver Distraction (April 1, 2015)(Contract #DTRT12GUTC12 with USDOT Office of the Assistant Secretary for Research and Technology, Section 7.1.1.)


Furthermore, the Transportation analysis uses the expected benefits of the TCN program to rationalize digital billboards. The purpose of the CEQA process is not to weigh the benefits of a project against the detrimental impact on the environment. CEQA requires the environmental effects of adding offsite digital advertising billboards to Metro property to be analyzed independent of the benefits other aspects of the Project may deliver. For example, see Section IV.K.3.d.1(a)(1). “For example, the TCN Program would aim to improve the bus passengers’ experience by helping to facilitate transit signal priority and bus wi-fi and efficiently relay bus arrival time information to riders. Therefore, the Project would not conflict with the applicable goals and initiatives set forth in the Vision Plan.”


The DEIR does not explain why Metro cannot use intelligent technology components to promote roadway efficiency, improve public safety and augment Metro’s communication capacity without using digital billboards.


According to the Department of City Planning, the City and Metro entered into a Memorandum of Agreement (C-139852) to share revenue generated from the off-site advertising on these signs for 20 years. It is unclear who will pay the costs to erect the TCN, or who will decide who will build the TCN, who may advertise on the TCN and what may be advertised on the TCN. In short, the DEIR is seeking to assess the environmental impacts of a Project that is not yet ready to be evaluated.


Appendix B: Metro TCN Lighting Study

In Del Rey, we are most concerned about the billboards FF29 and FF30 proposed for the intersection of the Marina (90) Freeway and Culver Blvd. because of the proposed location next to the Ballona Wetlands Ecological Reserve. However, light pollution from the digital billboards must be addressed citywide. What will be done to prevent “sky glow” from the billboards? (See “A switch’s flip side” from Los Angeles, Times, September 22, 2022, page 1[6], and “The Sky Needs Its ‘Silent Spring’ Moment”[7] from Scientific American).


The whole point of a digital billboard is for the advertising to be seen, preferably over as wide an area as possible. If there is no “potential visibility” of the sign, its advertising is not effective.


Appendix B, Part A. Summary, states that “the proposed Project will not introduce a new source of light trespass and or glare at residential properties or other sensitive use properties within the City of Los Angeles.” Then the DEIR states that it also monitored “potential for visibility of the Signs” from residential properties nearby. However, if the digital billboard is visible from residential property or sensitive use property, it will be disruptive, particularly if the display changes every eight seconds, 24 hours a day.

To prepare the Lighting Study, not all of the proposed Project Sites were monitored to determine if there was a “potential for visibility” from residential properties nearby. Further, the DEIR does not explain where the monitoring sites were located. The Project Sites needed to be monitored from the residential properties or other sensitive use properties where the billboards would be visible.


The Initial Study in April 2022 states on page 9 that the “digital display faces would be set to refresh every eight seconds and would transition instantly with no motion, moving parts, flashing, or scrolling messages.” Does that mean that there will be no videos like the ones shown on the digital billboard at Manchester Avenue and the 405 in Inglewood, which announces upcoming entertainment offerings? Where is that regulated? Who decides on the content of the advertising on the billboards?


Earlier this year, the City Council agreed to the Sidewalk and Transit Amenities Program (STAP) (CF 20-1536 and 20-1536-2) which would allow digital advertising on transit furniture in the public right-of-way. The STAP program will have digital elements in Transit Shelters, Digital Kiosks, Interactive Kiosks, Digital Urban Panels. STAP raises the same issues as the TCN program – energy consumption, light pollution, effects on traffic – and like TCN, it is seen as a revenue source for the City. We believe that the revenues from these digital signage programs do not outweigh the damage caused by the signs.



Best regards,

DEL REY RESIDENTS ASSOCIATION


By Elizabeth Campos Layne, President

Attachments

1. Del Rey Residents Association Comment Letter of August 1, 2022

2. “How Light and Noise Pollution Confound Animals’ Senses”, The Atlantic, July 2022

3. “Where has goose gone?” Los Angeles Times, as posted on Yahoo News, October 13, 2022

4. Mike Bonin’s comment letter of June 1, 2022

5. Article about new housing laws, Los Angeles Times, page 1, September 29, 2022

6. “A switch’s flip side,” Los Angeles Times, page 1, September 20, 2022

7. “Saving the Night Sky,” Scientific American (October 2022)


Cc: (via e-mail)

Shine Ling, tcn@metro.net

Councilmember Mike Bonin (C.D. 11), councilmember.bonin@lacity.org

Del Rey Neighborhood Council, board@delreync.org

Westside Regional Alliance of Councils, Land Use and Planning Committee, wraclupc@gmail.com

City Clerk – clerk@lacity.org re CF 22-0392


Department of City Planning


[1] DRRA letter of August 1, 2022, attached. [2] https://www.theatlantic.com/magazine/archive/2022/07/light-noise-pollution-animal-sensory-impact/638446/ [3] “Where Has Goose Gone?” from Los Angeles Times, published in Yahoo News, October 13, 2022. [4] Letter of June 1, 2022 from Mike Bonin re Metro’s TCN Notice of Preparation (attached) [5] “2 laws expand options for new housing,” L.A. Times, September 29, 2022, page 1, regarding Senate Bill 6 and Assembly Bill 2011, which take effect January 1, 2023. [6] See attached pdf copy. [7] Doi:10.1038/scientificamerican1022-46, article by Joshua Sokol, originally published with the title “Saving the Night Sky” in Scientific American 327,4, 46-55 (October 2022). Re: Transportation Communications Network (“TCN”) Draft Environmental Impact Report (DEIR), comments due October 24, 2022


Two decades ago, the City of Los Angeles imposed a ban on digital off-site signs, Ordinance 174547. Now, Metro and the City of Los Angeles have entered into a Memorandum of Agreement (C-139852) that would allow digital billboards to be erected on property that is co-owned by Metro and the City. For the reasons outlined more fully below, the Del Rey Residents Association (“DRRA”) is opposed to the Metro Transportation Communications Network (“TCN”) program. The following comments on the DEIR are not exhaustive of all our concerns but are those that are feasible for non-experts to address.


Aesthetics

The public has spoken and has been opposed to digital advertising for decades. Please see the dozens of communications from the public and community impact statements from Neighborhood Councils in Council Files 11-1705 and 22-0392. The DEIR has no discussion of the cumulative effects of visual clutter on the general public and drivers alike.


In Del Rey, we are most concerned about the billboards FF29 and FF30 proposed for the intersection of the Marina (90) Freeway and Culver Boulevard. That is next to the Ballona Wetlands Ecological Reserve, and we take issue with the DEIR conclusion that the potential impacts to views of the Ballona Wetlands would be less than significant (DEIR, IV.A.3.d. Threshold (a)(1)). We also disagree with the statement “Furthermore, based on the Site Location of the proposed TCN Structure next to a freeway or major roadway, their size and height, and the existing urban setting of the Site Locations and surroundings, the TCN Structures would not substantially contrast with the existing aesthetics features, such as trees, landscaping , and open space areas” (DEIR, IV.A.3.d, Threshold (c)). The signs would attract attention and detract from the benefits the open space of the Wetlands provide for drivers.


Our comments on the TCN Initial Study[1] (attached) noted that a digital sign on a business at 5450 Lincoln Boulevard (in Del Rey) is clearly visible from the other side of the Ballona Wetlands (about 1.5 miles away). We would like Metro to respond to each of the concerns raised by us in that letter.

Despite our particular interest in ensuring that no digital billboards are erected near the Ballona Wetlands Ecological Reserve, and our desire to have all static billboards removed from Metro property along the Culver Blvd. Bike Path that runs through Del Rey (from the 405 freeway to McConnell Avenue, about 1.5 miles), we support Alternative One – the no project alternative. In our opinion, there is no take down ratio that would be sufficient to overcome the negative effects of digital billboards in Los Angeles.


The DRRA fully supports the removal of all static display billboards from Metro-owned property. Complete removal would improve the quality of life in our neighborhoods by reducing cyclist, driver and pedestrian distractions, reducing the commercialization of our lives and eradicating the unsightly structures that hold up the billboards. We should not have to allow digital billboards as the price for having the static billboards removed.

Biological Resources

According to the DEIR, the Project will have “less than significant” impact from “Substantial Light or Glare.” In fact, the DEIR fails to address the effect of light and noise from billboards on humans and wildlife. A recent article in The Atlantic[2] raises this issue, as does the story of the migrating goose that disrupted the October 12, 2022 Dodgers-Padres playoff game.[3] The best way to mitigate the light pollution from the digital billboards is to choose Alternative 1, i.e. No Project.


Energy consumption – Section IV.E

We disagree with the conclusion that the cumulative impacts related to energy use and conflicts with plans will have a less than significant impact.

According to the DEIR, the Project will result in a net increase in energy demand of 2,288,690 kWh per year. DEIR, Section IV.E. Per the U.S. Energy Information Administration, in 2020 the “average annual electricity consumption for a U.S. residential utility customer was 10,715 kWh.” Thus, the net increased use from the TCN will be equivalent to the energy consumption of 213 homes per year.

The DEIR analysis places too much reliance on the increase in energy usage as a percentage of the total sales (0.1%) of the Department of Water and Power (DWP). This is a specious argument given the size of DWP. We are in an era of climate change when the mandate is to reduce energy use, not rationalize ways to increase it. According to the DEIR, this Project is not contemplated to reach 100 percent renewable energy until 2035. Section IV.E.3.c.


Gov. Newsom has proposed clean electricity targets of 90% by 2035 and 95% by 2040. https://www.gov.ca.gov/2022/08/12/governor-newsoms-ambitious-climate-proposals- presented-to-legislature/ (8/12/22). Increasing consumption will make these targets harder to reach. Even if renewable energy were the answer to climate change, increases in consumption mean more renewable energy will need to be produced. Until 100% renewable energy is available for all, those using such energy force others to use continue using dirty energy.


The energy consumption of the digital billboards should be re-analyzed with an emphasis on the effects of the increase in energy use. We suggest that a redirected analysis will find that the demand during operation will cause wasteful, inefficient, and unnecessary use of energy and impacts will be significant.


Land Use and Planning, Section I.

The DEIR acknowledges that the Project Impact on Land Use and Planning would be “Significant and Unavoidable.”


The DEIR Section IV (Other CEQA Considerations) is required to discuss the significant and unavoidable impacts that would result from the Project, and the reasons why the Project is being proposed notwithstanding the significant and unavoidable impacts. Our Councilmember Mike Bonin summed it up clearly[4]: “[T]he scope and intent of the project is clear: install large digital billboards at highly visible Metro-owned locations for revenue generation purposes.” Other than the generation of revenue to be allocated in a manner yet to be specified, what benefit will result from Metro being allowed to ignore a ban on digital billboards that has been in place for two decades? A piecemeal dismantling of the ban will make it increasingly difficult to stop digital pollution of our environment. Why should Metro be allowed to erect digital billboards when private companies cannot?


Zoning

The Project will require an amendment to the Zoning Code that has not yet been written or approved, although the City Council has instructed the Department of City Planning to draft the amendment (CF 22-0392). After years of study, the City of Los Angeles has developed a new Zoning Code that is currently going through the adoption process with the Downtown Community Plan Update. The Zoning Ordinance enabling the implementation of the TCN Program would apply solely to the 56 proposed Site Locations for the TCN Structures and any locations for associated sign takedowns. (Executive Summary, page I-6). The DEIR does not explain why Metro needs a Zoning Code that is different from the one that the City Planning Commission recommended for approval on September 23, 2021.


Zoning near each of the 56 TCN Project sites and any potential takedown sites is a critical issue that has not been adequately considered.


1. The executive summary states that industrial zoning “is generally buffered by commercial uses to provide separation from residential uses.” Del Rey has several neighborhoods that are zoned Industrial, and yet apartment complexes and schools have been built in those areas, e.g. the area covered by the Glencoe Maxella Specific Plan and the area between Ballona Creek and Jefferson Boulevard. How will Metro ensure that the digital billboards are not built on Metro property that is next to areas that are de facto residential?

2. The State of California is hoping to make housing more affordable by allowing construction of housing in buildings that were previously zoned for commercial use.[5] The DRRA has been asked to consider a number of such projects, particularly in the Glencoe-Maxella Specific Plan area. However, current land use planning does not provide any certainty as to where those developments will occur. The DEIR should show how Metro is going to ensure that the TCN Project complies with the Community Plans that are being updated citywide. At a minimum, this should include a review of the draft plans that are in circulation and a letter from the Department of City Planning confirming that they agree or disagree with the statements in the DEIR.


The Palms Mar Vista Del Rey Community Plan was adopted in 1997 and has been going through updating since 2019. Del Rey is transected by Centinela Avenue and bounded by Lincoln, Washington, Sepulveda and Jefferson Boulevards. The State of California has changed the law to promote housing construction within half a mile of any of these streets. The analysis in the DEIR must ensure compatibility with planned and reasonably foreseeable residential use, not just with areas specifically zoned residential. For all project sites, adequate mitigation measures must include siting, orientation, buffering, and screening from all residential dwellings.


3. Alternative 3 assumes that the Project would “eliminate or relocate FF-29 and FF30 outside of the coastal area of the Palms-Mar Vista-Del Rey Community Plan.” The DEIR does not clearly define what is meant by the “coastal area of the Palms-Mar Vista – Del Rey Community Plan area” and should include a map showing where relocation might be considered. Except for the areas within the Glencoe-Maxella and Playa Vista Specific Plans, the rest of Del Rey falls within the Coastal Transportation Specific Plan. Parts of Del Rey also are within the jurisdiction of the California Coastal Commission. As stated above, we are opposed to FF-29 and FF-30 at any location.


Community Benefits

If digital billboards are permitted, who will decide what community benefits must be provided in exchange? Who will determine which community gets those benefits? How will the revenue sharing from the billboards be allocated within the City? Any system of allocation must provide for notice to the community, an opportunity for the community to be heard, consideration of the environmental impacts and findings.


Metro needs to analyze each potential TCN Project site separately and to provide data showing what was analyzed and what methodology was used. Each structure erected or taken down will have a unique environmental impact, depending on its location.


Take-downs

The DEIR states that in exchange for being allowed to erect 56 TCN structures (98 digital ad faces, according to Scenic LA), static billboards with twice the square footage of the digital billboards (DEIR page I-7) would be removed. This take-down ratio is far too low.

Because one digital billboard can feature ads from multiple advertisers, a digital billboard can generate far more revenue than a static billboard. At a minimum, the environmental impact of each digital billboard should be offset by taking down the number of static billboards that generate the same amount of revenue as the digital billboard. This is likely to be closer to a take-down ratio of 10 to one.

The DEIR does not explain how it would be decided which static billboards would be taken down and when that would occur. How would Metro ensure that those decisions are made fairly and equitably so that the static billboards are removed from the same neighborhood that is being burdened with a digital billboard?

Transportation: Section IV.K and Appendix K

Gibson relied on three studies to analyze the whether the TCN structures present potentially significant traffic safety concerns. Two of the three studies were conducted by the Foundation for Out of Home Advertising Research & Education (“FOARE”). DEIR Section IV.K.3.b. The FOARE research projects “help ensure OOH [out of home] advertising is competitive and a preferred means for marketing and promotion.” The Board of Directors of the Foundation are all from advertising companies.

The use of studies conducted by a foundation created to further the interests of the business that will benefit from the Project is an egregious conflict of interest. Moreover, studies that demonstrate safety concerns have been ignored. The Transportation analysis must be redone using unbiased research and without the use of the FOARE studies.


We note the oft-referenced study by the National Center for Transportation Systems Productivity and Management that “revealed that the presence of digital billboards increased the overall crash rates in areas of [digital] billboard influence compared to control areas downstream of the digital billboard locations.” Digital Advertising Billboards and Driver Distraction (April 1, 2015)(Contract #DTRT12GUTC12 with USDOT Office of the Assistant Secretary for Research and Technology, Section 7.1.1.)

Furthermore, the Transportation analysis uses the expected benefits of the TCN program to rationalize digital billboards. The purpose of the CEQA process is not to weigh the benefits of a project against the detrimental impact on the environment. CEQA requires the environmental effects of adding offsite digital advertising billboards to Metro property to be analyzed independent of the benefits other aspects of the Project may deliver. For example, see Section IV.K.3.d.1(a)(1). “For example, the TCN Program would aim to improve the bus passengers’ experience by helping to facilitate transit signal priority and bus wi-fi and efficiently relay bus arrival time information to riders. Therefore, the Project would not conflict with the applicable goals and initiatives set forth in the Vision Plan.”


The DEIR does not explain why Metro cannot use intelligent technology components to promote roadway efficiency, improve public safety and augment Metro’s communication capacity without using digital billboards.


According to the Department of City Planning, the City and Metro entered into a Memorandum of Agreement (C-139852) to share revenue generated from the off-site advertising on these signs for 20 years. It is unclear who will pay the costs to erect the TCN, or who will decide who will build the TCN, who may advertise on the TCN and what may be advertised on the TCN. In short, the DEIR is seeking to assess the environmental impacts of a Project that is not yet ready to be evaluated.


Appendix B: Metro TCN Lighting Study

In Del Rey, we are most concerned about the billboards FF29 and FF30 proposed for the intersection of the Marina (90) Freeway and Culver Blvd. because of the proposed location next to the Ballona Wetlands Ecological Reserve. However, light pollution from the digital billboards must be addressed citywide. What will be done to prevent “sky glow” from the billboards? (See “A switch’s flip side” from Los Angeles, Times, September 22, 2022, page 1[6], and “The Sky Needs Its ‘Silent Spring’ Moment”[7] from Scientific American).


The whole point of a digital billboard is for the advertising to be seen, preferably over as wide an area as possible. If there is no “potential visibility” of the sign, its advertising is not effective.


Appendix B, Part A. Summary, states that “the proposed Project will not introduce a new source of light trespass and or glare at residential properties or other sensitive use properties within the City of Los Angeles.” Then the DEIR states that it also monitored “potential for visibility of the Signs” from residential properties nearby. However, if the digital billboard is visible from residential property or sensitive use property, it will be disruptive, particularly if the display changes every eight seconds, 24 hours a day.

To prepare the Lighting Study, not all of the proposed Project Sites were monitored to determine if there was a “potential for visibility” from residential properties nearby. Further, the DEIR does not explain where the monitoring sites were located. The Project Sites needed to be monitored from the residential properties or other sensitive use properties where the billboards would be visible.


The Initial Study in April 2022 states on page 9 that the “digital display faces would be set to refresh every eight seconds and would transition instantly with no motion, moving parts, flashing, or scrolling messages.” Does that mean that there will be no videos like the ones shown on the digital billboard at Manchester Avenue and the 405 in Inglewood, which announces upcoming entertainment offerings? Where is that regulated? Who decides on the content of the advertising on the billboards?


Earlier this year, the City Council agreed to the Sidewalk and Transit Amenities Program (STAP) (CF 20-1536 and 20-1536-2) which would allow digital advertising on transit furniture in the public right-of-way. The STAP program will have digital elements in Transit Shelters, Digital Kiosks, Interactive Kiosks, Digital Urban Panels. STAP raises the same issues as the TCN program – energy consumption, light pollution, effects on traffic – and like TCN, it is seen as a revenue source for the City. We believe that the revenues from these digital signage programs do not outweigh the damage caused by the signs.



Best regards,

DEL REY RESIDENTS ASSOCIATION


By Elizabeth Campos Layne, President

Attachments

1. Del Rey Residents Association Comment Letter of August 1, 2022

2. “How Light and Noise Pollution Confound Animals’ Senses”, The Atlantic, July 2022

3. “Where has goose gone?” Los Angeles Times, as posted on Yahoo News, October 13, 2022

4. Mike Bonin’s comment letter of June 1, 2022

5. Article about new housing laws, Los Angeles Times, page 1, September 29, 2022

6. “A switch’s flip side,” Los Angeles Times, page 1, September 20, 2022

7. “Saving the Night Sky,” Scientific American (October 2022)


Cc: (via e-mail)

Shine Ling, tcn@metro.net

Councilmember Mike Bonin (C.D. 11), councilmember.bonin@lacity.org

Del Rey Neighborhood Council, board@delreync.org

Westside Regional Alliance of Councils, Land Use and Planning Committee, wraclupc@gmail.com

City Clerk – clerk@lacity.org re CF 22-0392


Department of City Planning

[1] DRRA letter of August 1, 2022, attached. [2] https://www.theatlantic.com/magazine/archive/2022/07/light-noise-pollution-animal-sensory-impact/638446/ [3] “Where Has Goose Gone?” from Los Angeles Times, published in Yahoo News, October 13, 2022. [4] Letter of June 1, 2022 from Mike Bonin re Metro’s TCN Notice of Preparation (attached) [5] “2 laws expand options for new housing,” L.A. Times, September 29, 2022, page 1, regarding Senate Bill 6 and Assembly Bill 2011, which take effect January 1, 2023. [6] See attached pdf copy. [7] Doi:10.1038/scientificamerican1022-46, article by Joshua Sokol, originally published with the title “Saving the Night Sky” in Scientific American 327,4, 46-55 (October 2022).




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