March 30, 2012

Mr. David Chernushenko City Councillor City of Ottawa

110 Laurier Ave. West Ottawa, ON K1P 1J1

Dear Mr. Chernushenko,

We represent the community associations of Centretown, Sandy Hill, Old Ottawa East, Old Ottawa

South, Carlington and the Rockcliffe Park Residents Association. We are writing to you to express

our concerns regarding proposals to amend the City of Ottawa Permanent Signs on Private Property by-law to allow the use of digital signs. We have serious reservations about the haste with which the City

appears to be prepared to enact by-law amendments to allow digital signs of all types to be erected.

We believe that:

• the City is not sufficiently prepared at this time to institute a regulatory regime that adequately protects residents and their right to enjoyment of property against light pollution, distraction and visual blight generated by digital signage;

• the City does not have a reasonable grasp on the traffic and pedestrian safety impacts of the technology to allow digital signage to proliferate;

• it’s uncertain whether digital advertising billboard technology provides a net benefit to the community; careful consideration should be given as to whether the City should even allow digital billboards;

• a moratorium on digital billboards should be imposed until concerns about safety risks and the negative impact to residents can be adequately addressed

We believe the City should defer consideration of any sign bylaw amendments until it is better prepared to

introduce an appropriate regulatory environment that, at a minimum, ensures the following:

• digital signs and digital billboards ARE NOT visible from residential properties or areas;

• digital signs and digital billboards ARE NOT visible from parkland or heritage areas/districts;

• digital signs are not allowed where billboards are currently prohibited;

• the existing notification radius for digital sign applications is widened to ensure that a digital sign or digital billboard is NOT visible from residential properties given the increased illumination;

• all adjacent ward councillors are notified of digital sign and digital billboard applications due to the increased illumination and projection of the digital technology (not simply the ward councillor where the digital sign resides);

• strict controls are placed on the apparent brightness of digital signs and billboards when viewed from nearby land uses, with a meaningful metric defined and applied;

• digital signs are not allowed to be any larger than the largest allowable billboard under current regulations (e.g. so-called “art walls” should be prohibited);

• the size of a digital sign and digital billboard dictates the level of control and restriction (i.e. the larger the sign the stricter the control and regulation)

City Acting in Haste and With Insufficient Data to Provide Good Regulatory Guidance

The haste placed by the City on new digital sign by-law amendments short-circuits meaningful public

debate on the role digital signs should play in our City. The City has also failed to address serious concerns in the community about the many detrimental impacts that the introduction of digital signage will inevitably bring. This failure will only serve to repeat (within communities across the City) conflicts,

outcries and controversies similar to that which occurred over the introduction of the Royal Ottawa Hospital Sign.

The City has not yet sufficiently evaluated the results from its current pilot program on City-owned property to allow an intelligent roll-out of digital signage. What’s more, the City’s pilot project was too

narrowly focused to guide sweeping city-wide changes in the regulatory environment to allow proliferation of digital signs of all types. Under the circumstances, the City is ill-prepared to construct or enforce an appropriate regulatory regime that protects residents’ safety and their right to enjoyment of their property

AGAINST industry efforts to install digital signs for profit.

In fact, the City’s pilot project appears to have been poorly and superficially conducted based on a concerted push by the City to allow a prompt introduction of digital signs and billboards at the behest the

sign industry. Even if the City were to conclude its pilot program today, it would still be necessary to take time to reasonably assess the results and appropriately gauge public reaction before instituting new regulations for digital signage throughout the City.

Adverse Impacts of Digital Signs on Neighbouring Residents

One of the principal concerns regarding digital signs is the intensity of illumination and movement added

to the visual environment by this technology. These signs have far more intrusive effects on residentially zoned lots and parkland than non-digital illuminated signs. The negative impacts are exacerbated by the intensity of light projected by digital signs. This results in light shining directly into homes and residential neighbourhoods. Digital signs are also distracting due to their frequently changing messages. All of these

impacts are often disregarded or dismissed by the industry, so the City must ensure that regulations and review processes adequately protect residents.

The concern over light trespass must not be ignored. It has substantial detrimental impacts on individuals

and to the health and well-being of urban core communities, especially to those near traditional main streets and those adjacent to gateway nodes to commercial zones. Residents must be protected from the negative impacts of significant light pollution. The regulations governing location, positioning, setbacks

and illumination of digital signs need to be more stringent than is currently the case for existing illuminated signage.

Traffic and Pedestrian Safety Hazards

The City appears ready to accept the sign industry’s arguments that traffic and pedestrian safety are not a concern. The sign industry has thus far successfully shifted the burden of proof away from itself.

However, independent behavioural studies1 (see enclosed table of references) show the measurable

distraction and safety risks caused by this technology. With significant traffic safety reports pending from TCA and FHWA, it would be prudent for the City to place a moratorium on digital signs until these reports are issued.

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Beijer, D.D. (2002). Driver distraction due to roadside advertising. University of Toronto, Department of Mechanical and Industrial Engineering

Beijer, D. D., Smiley, A., & Eizenman, M. (2004). Observed driver glance behavior at roadside advertising. Transportation Research Record, No. 1899, 96-103.

Fisher, D. (2009). Presentation to the Human Factors Workshop on Visual Clutter in the Road Environment. Washington, DC: Transportation Research Board 88th Annual Meeting.

Smiley, A., Smahel, T., and Eizenman, M. (2004). Impact of Video Advertising on Driver Fixation Patterns. Transportation Research Record 1899, 76-83.

Smiley, A., Persaud, B., Bahar, G., Mollett, C., Lyon, C., Smahel, T., & Kelman, W.L.(2005). Traffic Safety Evaluation of Video Advertising Signs. Transportation Research Record: Journal of the Transportation Research Board, No. 1937, pp. 105-112. Washington, DC: TRB.

Young, M.S., & Mahfoud, J.M. (2007). Driven to Distraction: Determining the Effects of Roadside Advertising on Driver Attention. Final report of a Study Funded by The Rees Jeffreys Road Fund. West London: Brunel University.