Comments from Jim Hogan - ENDEVCO

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Digital changing message displays are much older than indexing units like mine. Only the newerDigital boards with LEDs versus the incandescent light bulb are newer than the others.Presently all billboards in the county are lawful nonconforming displays due to the currentordinance. If this ordinance is approved only new LED Digital Changing Message Billboards willbecome legal conforming displays and be granted a variety of privileges and combinations asbeing larger and/or, taller and/or brighter than other existing billboards and/or business signs.They can be moved and relocated at any time. Additionally only they can be replaced ifcompletely damaged by hurricanes or other major storm damages. They can also concentratemore on locating closer to competitors billboards to absorb their customers, especially if a 1000foot separation is used per the draft. All these advantages are grossly unfair and discriminatingto us and others.As we know the concept of the new ordinance is to remove a number of existing billboards andor faces replacing them with new LED Digital Changing Message displays. Presently the recitalsection of the ordinance suggests that the swap is for at least two (2) existing faces for each newsingle LED Digital face added. This would not be a problem for us.However, the latest draft I've seen reads in section 20.7-6(2) that now minimally two (2)existing billboards must be removed and swapped for one (1) single digital face. That is a swapof four (4) regular faces for one (1) new LED Digital face. Therefore, four (4) double facedbillboards or 8 faces must be swapped for one (1) double faced new LED Digital ChangingMessage Billboard with two (2) faces. That becomes a problem for us and others. Specificallyfor us because we have only one (1) billboard structure with six (6) multiple changing messages.Although it doesn't suggest the number of faces in the draft, we must ASSUME the billboardsare double faced.In direct contradiction in Section20.7-6(2) a, It further provides that the aggregate squarefootage of existing faces to be swapped out must equal minimally 180% of the new LED Digitalface. Perhaps I’m not interpreting the text correctly, however that is what it appears to state.Therefore, this allows a little less than two (2) regular faces to be swapped for one (1) newdigital face? This allows 220% more credit . The only thing I can think of for this reference istrying to provide credit for smaller boards, which only Clear Channel has. It doesn't seemrational or fair.My single structure has well over the original requirements in the recitals, which is more thanadequate for four (4) existing faces swapped for each new double faced LED Digital ChangingMessage Display ( stated as two standard non conforming faces swapped for one newconforming digital face). Also, it has more aggregate square footage for the three (3) faces onone side or 300% as compared to smaller faces apparently credited at 180%.But, it does not meet the newer suggested requirement for removal of four (4) existingbillboards or eight (8) faces for one double faced LED Digital Billboard since it only is onestructure with six (6). This becomes discriminating and unfair. As the first and only multiplemessage display in the county I should have the option to take advantage of the being legally2
conforming and upgrading as necessary to a level playing field. I shouldn't be penalized forhaving only one structure because the county prohibited new billboard construction in the past.Since we already are a Changing Message Display in the same family of signs and trying toaccomplish the same things as LED Digital Changing Message Displays we should be given thesame rights and privileges without all of the swap out ratios. The indexing or trivision displayscame after the incandescent lamp Digital Changing Message Displays to provide multiplemessage capability at one location, thus reducing the number of structures in a given area usinglow energy technology. Why should we be penalized for introducing the same benefits to thecommunity?.The 1000 foot separation between displays is not enough. Although it is the old countyseparation limit and the maximum saturation point allowed by the state, Clay County neverreached this saturation point before stopping the issuance of new permits. These new digitaldisplays are larger, taller, brighter, more attention getting and can be seen from a greaterdistance. For example, Blanding Blvd. between Middleburg and the Duval County line only hasabout (1) one billboard per mile on either side of the road. Park Avenue, or SR17 has only two(2) billboards for 14 miles between Duval County and below Green Cove Springs. Only two (2)in the county are within 1000 feet of each other or less.When you are trying to increase the number of displays in the county you would naturallyreduce the separation between displays. If you are trying to reduce the number of displays, asin this case, you would spread them out more. We are proposing the reverse by reducing thenumber of displays and also reducing the separation between them. This, for example, couldcreate four (4) changeable message displays on Blanding Blvd. at the Orange Park Mall all with inviewing distance of each other between the county line and the South end of the mall. Attachedare two maps demonstrating this. Additionally, a 5th large on-site unit could be added by themall who owns and operates a Changing Message Display at their other mall at the Avenues.Advertising is about Location, Location, Location. Billboard companies would like to locateDigital Displays in the highest commercial and trafficked areas in the county. Blanding Blvd.between the Orange Park Mall and I-295 is the busiest non interstate corridor in the county.Map “A” shows the two billboards in that area, mine and one by CBS, between the DuvalCounty line to the North and to the South end of the mall. It will stay that way if we establisheda 1500 foot separation requirement. Map “B” demonstrates what will occur with a 1000'separation. What happens if some are single faced or across the street from each other? Thiscreates the over proliferation, which is the opposite of the ordinance's intent. To have four (4)LED Changeable Message Displays all within sight of each other just between the county lineand the back or South entrance to the mall would be an unplanned surprise for everyone fromplanners to landowners, to the citizens of the community and even the owners and operatorsof the sign. THIS IS THE MAIN ENTRANCE INTO CLAY COUNTY. Four (4) double faced LED DigitalChanging Message Displays broadcast eight (8) advertising messages per face. That's a totalpotential of 54 advertising messages all within view of each other versus the present total ofeight (8) in the same area. This is more than overkill.3
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Comments from Jim Hogan - ENDEVCO

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