Final Draft of CITY OF LA SIGN ORDINANCE

Dear AIA/LA AD HOC Sign Ordinance Committee:

Please find attached for your review a draft of the AIA/LA Position letter that was formulated based on your reaction to the earlier draft of the City of LA Sign Ordinance.  We should probably update the letter and sharpen its focus so that it directly responds to the Final Draft of the Sign Ordinance.  

We will need to have a final position articulated and endorsed by the AIA/LA Board prior to the March 18th City Planning Commission hearing.  

Also, after reviewing the March 11th draft of the City of LA Sign Code (which can be found here:  http://cityplanning.lacity.org/Code_Studies/Other/ReportOrdinance2.pdf), these are my unfettered thoughts:

1.  Prohibited Sign Types 

A. Roof Signs.  Although I am generally supportive of the proposed standards to allow roof signs on buildings between 50 and 150 feet in height, I am wondering if the requirement to have 400 feet or more of street frontage is too restrictive?  Does the Asbury have 400+ feet of street frontage?  What about the Royale Wilshire?  Or some of the apartments along Rossmore Ave.?  If this proposed ordinance would not allow what historically has been shown to positively accentuate our visual environment, then I think it may be at odds with itself. What is the desired parcel dimension for a a gracious high-rise multi family??  

2.  Enforcement 

A.  Private Right of Action.  How do you limit liability exclusively to the sign companies and the property owner?  Doesn't an implicit Private Right of Action already exist for everything under the sun?

B.  Clarification:  Can penalties be directed toward funding enforcement? I disagree with the Office of the City Attorney's attitude on this.  In my opinion, just because the penalties would fund the enforcement DOES NOT mean a conflict of interest would exist.  Do we look at Parking Enforcement this way?  No.  Do we look at Law Enforcement this way?  No.  An inspector must adhere to the law and to the direct responsibilities of his/her job, which equals enforcement.  To say that a conflict of interest would arise because the penalties would help fund additional enforcement DOES NOT automatically equate more violations and, hence, revenue.  It simply means more enforcement.  Which, the practice of is not a conflict of interest.  It's a responsibility.

C.  Clarification:  Can an annual fee be introduced to help fund enforcement?  Once again, Office of City Attorney is interpreting this with a flawed premise.  An ordinance that CAN NOT be enforced is meaningless.  This attitude that new fees cannot be accessed are undermining the entire process of this ordinance and run counter to its objectives.  Creating robust and effective enforcement provisions is the primary objective of this new ordinance, right?  If a fee of $186 every three years can be allocated to fund a program to enforce off-site sign regulations consisting of say, three staff members then why can't a fee of $1,860 every three years be allocated to fund an enforcement program consisting of 30 staff members???

3.  Area, Height, Spacing and Time Restrictions 

A.  Does the discretionary review of signage for larger developments under the COMPREHENSIVE SIGN PROGRAM become the legally-challengeable achilles heel of this sign ordinance?  Does it negate the effectiveness of the entire ordinance?  Or is it a safety valve to ensure due diligence and additional community input?  I'm torn on this one but I'm leaning in favor of support.

B.  Allow more flexible time limits for certain temporary signs?  Absolutely not.  In my opinion, temporary signs are the prime source of visual clutter.  If we must allow them at all, it should only be for very finite, well-regulated moments in time.  Otherwise, you will see a detrimental proliferation of temporary signs less than 20 sq. feet sprout up everywhere like a fungus.

C.  The reason (or, at least a contributing benefit to why...) the New York sign area ratio works so well, in addition to the idea that each property has a maximum sign area allowed is that typically, NY has  a finer grain to its urban fabric.  Property frontage is smaller.  You are less likely to see single developments that take up entire blocks.  LA needs a similar cap, in my opinion.  We need to find a way to regain our sense of scale and this would be one simple method for achieving that goal, albeit indirectly.  Look at the excessive signage allowed in LA as compared to NYC and Chicago for a big-box retail (3,865 sq. ft. v. 500 to 800 sq. ft).  Also, consider the existing condition of Los Angeles:  I bet even know, the vast majority of our retail is well below a 2.5:1 ratio.

4.  Sign Districts 

A.  5,000 linear feet?  Fine.  Transition to surrounding neighborhoods?  Fine.  Sign reduction and/or community beautification?  Fine.  But what about adding a provision for the opportunity to designate a sign district for vertical development?  1,000,000 sq. feet in size??

B.  Pending Sign Districts.  Is this another achilles heel??  How far along in the process are they?  Are they going to surfeit the ordinance?

5.  Exceptions 

A.  Specific Plans cannot surpass sign ordinance?  Fine.

CONCLUSION 

I still favor adding a provision or two that directly conveys the following:  there is a direct correlation to how well a City looks to how well a City performs.  A well designed City fosters, enhances and promotes creative and economic development.  Exemplary sign regulation is only one component to a well designed City.

-Will Wright