Advertising, information, and
space: Considering the
informal regulation of the
Los Angeles landscape
Elisabeth J Sedano
Spatial Sciences Institute, University of Southern California, USA
This article analyzes a municipal inventory of billboards within the City of Los Angeles. It has long
been rumored that thousands of the billboards in the city were illegal; since completing their
inventory, city agents now claim that only a fraction of billboards are illegal. I argue herein that a
close reading of the inventory reveals over half of the billboards in Los Angeles either lack permits
or are out of compliance with their permits and are thereby illegal. While some city agents work
to strengthen the city’s regulation of signage, others fail to enforce sign laws, protect the signs
from appearing illegal, and push to rewrite the sign code to legalize technically illegal signs. I argue
that these contradictory actions evidence informality as the city’s mode of regulating signage, and
I seek to understand how state actors, as unique individuals, play a part in the creation of this
informal landscape. Using theories on advertising and urban space, and drawing in information
theory to understand the concatenation of information and space, I tie the varied experiences,
knowledges, and actions of individual state actors to the overarching informality of the state’s
regulation of outdoor advertising.
Production of space, outdoor advertising, information, regulation, informality
In this paper, I explore the regulation of public space in Los Angeles using a municipal
inventory of billboards as my point of analytical ingress. In 2002, the Los Angeles City
Council enacted a program to catalog all billboards within the city’s bounds and determine
their legal status. With this eﬀort, Los Angeles became the ﬁrst city in the United States, and
likely the world, to create a publicly accessible inventory of billboards. For years it had been
rumored that many of the billboards in Los Angeles were illegal. As described herein, the
inventory reveals that over half of the billboards in Los Angeles either lack permits or are
Elisabeth J Sedano, Spatial Sciences Institute, University of Southern California, 3616 Trousdale Parkway, AHF B55,
Los Angeles, CA 90089-0374, USA.
Environment and Planning A
2016, Vol. 48(2) 223–238
!The Author(s) 2015
Reprints and permissions:
out of compliance with their permits. Yet since completing the inventory and conﬁrming this
wide swath of illegality in landscape, the city has made no eﬀort to enforce its laws against
the owners of these signs. On the contrary, City Council members are in negotiations with
outdoor advertisers to grant amnesty to illegal signs.
The government’s regulatory inaction stands in opposition to a worldwide tendency
towards the heightened regulation of urban public space, especially as it is linked to
commercialized public space (Low and Smith, 2006). Although billboards are owned
by private entities, they are sited and designed to be seen by members of the public.
This is true whether they sit on public or private property—the signs gain their value
because they project their messages into public space. In the last 25 years, scholars have
noted the increasingly privatized and commercialized nature of urban public space
(Banerjee, 2001; Sorkin, 1992), and that regulation over public behavior in these
privatized public spaces is high (Fyfe, 1998; Ne
´meth, 2010). The commercialized nature
of these spaces and the heightened regulation over them seeps from these privatized sites
into public streets and sidewalks. For example, Las Vegas local government’s four-
pronged regulatory structure over public sidewalks in ‘‘The Strip’’ district of casino
resorts is designed to, ‘‘prioritize pedestrian circulation, particularly for patrons of the
resorts, and exclude or minimize the eﬀects of undesirable behavior such as panhandling,
vending, homelessness, handbilling, and political protests’’ (Blumenberg and Ehrenfeucht,
An obvious distinction in this case is that the would-be subjects of regulation are outdoor
advertisers—producers of a key aspect of commercialized space and supporters of
consumption—whereas in the numerous cases of heightened regulation of public space
revealed in the political economy literature the purported violators are outsiders to the
broader consuming culture that public and private elites are seeking to engage. For years,
Los Angeles oﬃcials argued that the city lacked the resources to keep up with the lucrative,
nimble outdoor advertising industry. A billboard can be erected quickly, and in a city as
large as Los Angeles, the few individuals charged with enforcing land use regulations are
unlikely to notice when an unpermitted sign goes up. Now that the city has directed
resources to research illegal billboards, its failure to take action based on the results of its
inventory suggests that the landscape of illegal signs is due less to a government inability to
regulate than to a government tactic. Recent literature on urban informality posits
informality as a ‘‘mode of urbanization’’ (Roy, 2005: 148).
What is commonly viewed as a loss of formal governability and control ... or in other words a
failure of urban planning as such resulting in insuﬃcient provisions – is actually (at least in part)
a deliberately produced urban informality by the state itself. The state uses informality as a mode
in order to decide case-by-case whether for example certain land uses are desired or not.
(Follman, 2015: 215).
The concept of urban informality has long been used to understand the economic
practices of the urban poor (see e.g. Hart, 1973), but current work identiﬁes informal
practices among the middle-class and elite (AlSayyad and Roy, 2004). Two key
state practices for enacting the ﬂexibility of informality as a mode of regulation are
unmapping, wherein the state changes or removes spatial information from oﬃcial sets of
knowledge, and the creation of zones of exception to overarching land use structures,
wherein land uses favored by the state can thrive (Roy, 2012). Follman’s (2015) case
study of a mega-development in India shows another common feature of informality: a
complicated state structure of multiple, overlapping agencies, diﬀering interests, and the
ability to change rules and enforcement practices over time. The messiness of this mode
224 Environment and Planning A 48(2)
may create a beneﬁcial ﬂexibility in regulatory practices, but it also produces unintended
eﬀects, such as lawsuits that drag on for years as public and private entities try to sort out
overlapping and competing claims. ‘‘[T]he Indian city,’’ writes Roy, in words that I argue
also describe the landscape of outdoor advertising in Los Angeles, ‘‘is made possible through
an idiom of planning whose key feature is informality, and yet this idiom creates a certain
territorial impossibility of governance, justice, and development’’ (2009: 81).
As described herein, the outdoor advertising industry in Los Angeles operates in and
around a structure of laws that are complicated, subject to change, and made and enforced
by a variety of government departments. The program to inventory billboards that is the
focus of this study was part of a package of laws passed in 2002 to rein in outdoor
advertising. The inventory program and the new regulations put Los Angeles at the
forefront of advertising regulation in the United States, yet from the moment of
enactment, the city engaged in contradictory actions that undermined the laws. Some city
actors fought to complete the billboard inventory, while others delayed it. After the
inventory was completed, some city actors refused to release the data, while others
supported a court action to make it public. Throughout, some city actors entered into
agreements with a handful of elite, global outdoor advertising corporations that vastly
increased the amount and type of advertising throughout the city even as others fought
advertisers in court to maintain the city’s new regulatory framework. This article will help
to elucidate how informality as a mode of regulation produces the commercialized landscape
of Los Angeles by considering the role of space in regulatory practices. Speciﬁcally, I employ
a combined theoretical lens of ideas on the production of space and information theory to
consider the quantitative results of the billboard inventory and the qualitative data of
interviews with state actors in relation to each other. I draw on court rulings and city
planning reports to lay a groundwork of understanding on the recent history of outdoor
advertising regulation in Los Angeles.
In the following section, I describe recent scholarly work on the expanding spatial realms
of advertising and then move to ideas on the production of urban space. I bring in
information theory to draw out the role of personal knowledge in the production of space
and break down the presumed boundary between information and space. Scholars such as
Cronin (2010), Donald (1999), and Benjamin (1999) examine the production of urban space
by drawing on urbanites’ memories, stories, and mental images—what we might also
describe as information. Cronin’s work (2008a, 2008b, 2010) is especially relevant here for
she studies the role of outdoor advertising in the production of urban space. I then
contextualize this study by laying out the legal history of Los Angeles’s 2002 sign
ordinances. I describe the litigation the laws spawned, the dramatic changes in the
Los Angeles landscape as the litigation progressed, as well as my own eﬀorts to make the
results of the billboard inventory public. Next, I analyze the results of the inventory,
highlighting the legal status of signs and the city’s protection of illegal signs within the
inventory itself. I argue that the contradictory state action revealed by the legal history
and the billboard inventory evidence informality as the city’s mode of regulating outdoor
advertising. I draw on my interviews with city actors in a variety of departments to show that
the manifold forces that characterize an informal regime are present at the level of the
individual. I understand city agents as themselves viewers of outdoor advertising. I draw
their personal experiences of signs into regulatory eﬀorts and hence the production of urban
space. I conclude by considering the role of the inventory—and its conﬁrmation of
informality—in the production of cityspace. This includes informal state action as well as
unexpected, creative actions by street artists as they protest the city’s informal regulation
over the visual landscape.
Theoretical framework: Advertising, information, and urban space
Recent scholarly work in media and communications focuses on the spaces of advertising.
Much of this work concerns the increased use of brands and branding through society
(Aronczyk and Powers, 2010). Branding employs logos, colors, and other visual cues to
give a similar look to all of an organizations’ output, from products and advertising to
oﬃce supplies and event design. It is more about evoking feelings and creating
relationships than selling particular products (Lury, 2004). Since it is not tied to a single
product, branding is mobile and adaptable, able to be deployed in nearly any context (Moor,
2007). As marketing and architecture mix, ‘‘brandscapes’’ (Klingmann, 2007) are formed.
New commercial and entertainment centers are ‘‘brand hubs’’, designed around a group of
brands (Hoegger, 2004). For Lury, branding,
involves the marketer adopting the position of the consumer – that is, of imagining the consumer
... the resulting product or products themselves become marketing tools, generating further
information. In other words, the brand progresses or emerges in a series of loops, an ongoing
process of (product) diﬀerentiation and (brand) integration. (2004: 8).
With a focus on outdoor advertising, Cronin (2010) expands this loop to include the
production of space. Drawing on Lefebvre, Cronin’s (2010) model is built on the idea
that space is produced through our lived movements and moments, positing cityspace as
the nexus of social energy, time, and space. In particular, outdoor advertising comprises a
cycle of cityspace, fashioned from the regular placement and replacement of ad campaigns.
These changes create a rhythm as residents become inured to the slightly jarring experience
of new ads periodically popping up in their usual paths.
The regularity of the change does not render space as neat and tidy, however. Cronin
(2010) draws on de Certeau to emphasize that urbanites respond to a variety of inﬂuences in
the city environment. Though outdoor advertising creates a landscape of commercial
messages intended to inspire consumption, it does not always eﬀect its purpose. Cronin
what de Certeau (1988: 93) calls the ‘geometrical’ space of the visual that is constructed by city
planners – and, I would add, commercial planners who own and organise advertising sites in
cities – does not fully determine individuals’ experience and use of city space. ‘The ordinary
practitioners of the city’ develop unspoken and barely legible tactics and ruses that are neither
captured nor determined by the systems in which they develop (de Certeau 1988: 93). For de
Certeau, these tactics and ruses constitute ‘the network of an anti-discipline’ deﬁned against the
disciplining imperative of city planners and, in this case, advertising companies (1988: xv). (2010:
Looking from the top down, the structures of discipline are not necessarily any more
coordinated in their actions than city residents. ‘‘Rather than operating an omnipotent
ideological machine, advertising companies function on a more provisional, reactive basis,
attempting strategic interventions for competitive advantage’’ (Cronin, 2010: 79).
Outdoor advertisers are entities that own sign structures, and their business is to sell ad
space to those with something to sell. They do so primarily by making promotional pitches
to media buyers (Cronin, 2008a). These promotional pitches are inherently stories—stories
about the valuable location of their signs, the people who co-constitute these spaces as
likely consumers, and the productive potential of their overall inventories. Cronin (2010)
links these stories to Walter Bergson’s concept of ‘‘fabulation’’, a human instinct for
ﬁction-making that allows us to accept life’s diﬃculties, from daily disappointments to
226 Environment and Planning A 48(2)
the knowledge of our own unavoidable death. For outdoor advertisers and their clients,
outdoor advertising animates cityspace into a negotiable and lucrative ﬁeld. Further,
Cronin (2010) argues that outdoor advertising provides fodder for city residents’ own
fabulatory instincts; ads are, ‘‘cultural products that have been ‘‘fabulated’’ by
advertising creatives, that can then be used by people to fabulate and make sense of
the world’’ (Cronin, 2010: 111).
The infusion of hope that outdoor advertising oﬀers is a forward-thinking vision, but the
experience of outdoor advertising is also inseparable from the past. Cronin is one of a
number of urban scholars who theorize the experience of cities by drawing on the way
that past experiences mediate current life. Donald (1999) argues that urban space is
diﬀerent for every individual, because we each have our own cache of knowledge that
ﬁlters how we experience space. Made up of memories of personal experiences, movies,
novels, and even sociological studies, we carry these innumerable mental images of city
life with us ‘‘snail-like’’ (Donald, 1999: 7) as we move through cityspace. The result is
that we each live our own ‘‘archive city’’ (Donald, 1999: 7), the experience of which is
visceral and new but are always mediated by our past. Cronin and Donald are both
inspired by Walter Benjamin’s Arcades Project. Benjamin (1999) analyzes 19th-century era
shopping arcades which once showcased the newest consumer goods but which lived on well
past their prime, stubborn relics of a faded era of capitalism. Benjamin analyzes the
experience of the arcades by bringing together hundreds of quotations that reference the
arcades, creating what could be called an ‘‘archive arcade’’. His work reveals the deep eﬀect
that past spaces have on the experience of current ones.
These understandings of space have clear alignments with information theory. (Indeed,
Donald’s (1999) declaration of an ‘‘archive city’’ calls out for this connection.) Space and
information each have traditionally been viewed as immaterial and inert: space in the
Euclidean sense and information in Shannon’s (1948) mathematical model. Shannon’s
theory quantiﬁes information according to the amount of uncertainty in a given message.
Interestingly, the theory does not consider the content of any message, the meaning, but only
its probability. MacKay’s (1969) critique of the model argues that the same piece of
information can mean diﬀerent things to diﬀerent people. In his view, information is
therefore never inert but is ever-changing as it moves within and between channels.
Maturana and Varela (1980) posit information as part of a closed system—a feedback
loop that includes the sender and receiver of information in addition to the information
itself. In this view, called reﬂexivity, information not only has an eﬀect on the recipient of a
message, it has an eﬀect on the sender as well. Hayles (1999) likens this process to Escher’s
hands drawing themselves into existence. Importantly, Hayles acknowledges the materiality
of information. ‘‘Information, like humanity, cannot exist apart from the embodiment that
brings it into being as a material entity in the world; and embodiment is always instantiated,
local, and speciﬁc’’ (Hayles, 1999: 49). In this light, information is material, energetic and,
crucially, made and remade through human action.
On the one hand, space is analyzed as the creative production of individuals, imbricated
by the action and energy of memory, thought, and feeling—personal repositories of
information. On the other hand, information is seen as a process, constantly open to
changing interpretations that may then eﬀect changes in the information. As information
always exists somewhere, iterative changes in information mean changes in its materiality.
Bringing these together, we can analyze information and space as co-constitutive. Bodies as
repositories of information produce space, and this production process creates new
memories, new materialities, new information. This is a feedback loop of information and
space, and it produces cityspace through the energy of human lives.
The space of regulation: The legal and spatial effects
of Los Angeles’s 2002 sign laws
In Los Angeles a plethora of departments play a part in regulating outdoor advertising.
The Planning Commission sets the city’s overarching planning policies; the Planning
Department analyzes speciﬁc projects; the Department of Building and Safety (LADBS)
enforces planning rules; the City Attorney analyzes legal issues arising from planning
matters and represents the city in litigation; the City Council has the power to direct each
of these departments but it is composed of 15 elected oﬃcials with their own goals and
constituencies to represent. The City Council has more power than the Mayor, as it can
override the Mayor’s veto, but the Mayor has the power to appoint the heads of the
Planning Department and LADBS, as well as select members of the Planning
Commission. Each of the departments is composed of hundreds of staﬀ, working in a
hierarchy particular to each department. In 2002, the City of Los Angeles passed a series
of ordinances that dramatically changed where and when new billboards would be
permitted. As with any new law aﬀecting urban development, the ordinances were
initiated by the City Council, and then spent months bouncing between departments as it
was researched by the Planning Commission, drafted by the Planning Department in
conjunction with the Planning Commission and City Attorney, and considered by a sub-
committee of the City Council, before being sent on to the City Council where it was
approved (with, in this case, the Mayor’s approval).
The prior sign law had allowed new billboards on nearly any commercial or high-density
residential zoned property. The 2002 law banned new billboards and modiﬁcations to
existing billboards, with one major exception. It created a new zoning category entitled
Sign Districts, wherein new and modiﬁed signs would be permitted under enumerated
circumstances. The 2002 laws also created the Oﬀ-Site Sign Periodic Inspection Program
(herein referred to the billboard inventory). Under the program, city inspectors would survey
all billboards within city limits, research their permit status, and publish the data in a
publicly accessible inventory. Within weeks, the city’s new veneer of control over outdoor
advertising was belied by its own contradictory actions. It approved a street furniture
program with JC Decaux that allowed the corporation to install thousands of advertising-
adorned bus benches and kiosks at locations of its choosing. The city then created the
Hollywood Sign District and over the next few years approved 49 new signs in
Hollywood, most of which were ‘‘supergraphics’’ covering whole building walls, many
times larger and more visible than traditional billboards.
Outdoor advertisers challenged the 2002 laws in court. Outdoor advertising receives
strong protection under American law, because the Supreme Court recognizes advertising
as a form of speech and hence protected by the First Amendment to the Constitution.
Government bodies may only regulate speech when they put forward a clear public
purpose. Initially, judges sided with the outdoor advertisers in the cases against the new
laws. One court ruled that the JC Decaux contract so undermined the purpose of the 2002
ban—purportedly to limit outdoor advertising—as to render the 2002 ban invalid. While the
city appealed the ruling, the status of the new law was in limbo. Outdoor advertisers seized
the opportunity to put up new signs across the city. Many of these were vinyl supergraphics
that could be unfurled in a matter of hours. When the city cited the owners of these signs for
putting up unpermitted signs, the sign owners sued. The city was forced to defend itself in
court against some 17 lawsuits at one time, an expensive and burdensome endeavor for an
already cash-strapped municipality. Years later, the city won its appeal of the ruling, and its
ban on new signs was reinstated. The illegal signs across the city began to come down, but
228 Environment and Planning A 48(2)
the permitted supergraphics in Hollywood, as well as the growing numbers of JC Decaux
street furniture signs, remained.
While smaller sign companies challenged the ban on new billboards, the three largest
companies in Los Angeles at the time, CBS Outdoor (recently rebranded as Outfront
Media), Clear Channel, and Vista Media (later bought by Lamar), challenged the
billboard inventory program. The city settled these lawsuits after ﬁve years of litigation.
The terms of its settlement with CBS and Clear Channel went far beyond the scope of the
billboard inventory. The city granted these companies the right to transform up to 840
traditional billboards into digital signs and to put up 200 new signs. This grant of rights
violated the city’s 2002 sign ban and thus gave these two companies lucrative rights to the
exclusion of all other outdoor advertisers. The companies agreed to provide the city with lists
of their sign inventories and permitting information of their signs. In exchange, the city
agreed to issue new permits for any signs that lacked valid permits. The city made this
agreement even though it did not know the scope of this promise—it had not yet
conducted its own research, so it did not know how many signs were likely illegal. CBS
and Clear Channel immediately began erecting digital billboards across Los Angeles. Soon
afterwards, a smaller company, Summit Media, challenged the settlement in court.
Though now legally unencumbered, the city delayed restarting the billboard inventory for
years. In 2009, the City Council reauthorized the program, but for months and then years,
no news of the project was released, leading many to believe the city had let the program
stagnate. In 2011, the project supervisor informed me that the billboard inventory was
complete. However, he said, the results would not be publicly released by order of the
City Attorney’s Oﬃce until the Summit Media lawsuit challenging the city’s settlement
with CBS and Clear Channel was resolved. Interviews with members of the City
Attorney’s revealed that there was no consensus about the inventory’s release. One was
convinced that the city had no right to hold on to the inventory data and suggested I ﬁle
an oﬃcial request for access to the inventory under California’s Public Records Act. I did so.
The city refused my oﬃcial request, and I sued in state court. After eighteen months, the city
agreed to settle the lawsuit and released the data.
Days later, the California Court of Appeal ruled that the City Council had exceeded its
legislative authority in granting CBS and Clear Channel the right to install digital billboards
as those rights plainly violated the city’s 2002 sign ban. CBS and Clear Channel were ordered
to turn oﬀ their digital signs.
Spatial information and legal disinformation: the results
of Los Angeles’s billboard inventory
Prior to the billboard inventory program, the Enforcement Division of LADBS lacked the
resources to conduct regular ﬁeld surveys of signs. With the billboard inventory, LADBS
was for the ﬁrst time charged with proactively inspecting billboards and maintaining a
database of the collected information. According to the head of the program, three
inspectors traversed all thoroughfares in the city that were likely to have billboards,
notably those zoned for commercial, manufacturing/industrial, or high-density residential
uses. For each sign identiﬁed, an inspector noted locational data such as address, and
inspection data such the height, size, number of sign faces, and the billboard company (if
shown). The inspectors then researched the permitting status of the signs. This aspect took
the inspectors twice as long as the ﬁeldwork: Los Angeles began issuing permits for
billboards as early as the 1920s, and the records were often haphazardly kept in various
ﬁles of diﬀerent departments.
The inventory LADBS released in 2012 (the ‘‘2012 Inventory’’) contains 17 columns of
inspection data and 20 columns of permit data for each sign face, including the permit
number and the speciﬁc contents of permits, such as the height, length, and width of the
permitted sign. These columns are empty for signs for which the owners did not provide and
the city could not locate permits. The 2012 Inventory also includes three columns of
purported legal ﬁndings. In 2014, LADBS released an updated version (the ‘‘2014
Inventory’’). The 2014 Inventory seems more accurate in terms of speciﬁc sign locations,
as a number of duplicate entries are removed and missing signs added. However, the 2014
Inventory lacks nearly all of the permit data: it provides permit numbers but leaves out the
speciﬁc contents of those permits. The result is that it is impossible to compare the inspection
data with permit data, and therefore to identify illegal signs, within the 2014 Inventory. To
test the legality of signs in the 2014 Inventory, I cross-referenced the 2014 Inventory
inspection data with the 2012 permit data, using the location data and permit numbers
from the 2014 Inventory to ﬁnd the matching permit’s details in the 2012 Inventory.
The 2014 Inventory lists 8514 signs. 7644 of these have a permit; 870 do not. Comparing
the ﬁeldwork data for the 7644 permitted signs with their permit data reveals:
.Sign structure higher than permit allows: 3048
.Sign face wider than permit allows: 1126
.Sign face longer permit allows: 973
.Signs with more sign faces than permit allows (i.e. a double sign on a single sign permit):
In total, the inventory reveals that 4226 of the 7644 permitted signs are noncompliant in
one or more of the four listed ways. Adding these 4226 signs to the 870 unpermitted signs
yields a total of 5096 signs that are illegal, as they are either unpermitted or noncompliant
with their permits.
The 2012 and 2014 Inventories contain a column entitled ‘‘Altered’’ that signals whether a
sign has been altered in violation of its permit. The 2014 Inventory classiﬁes 792 signs as
‘‘Altered’’. According to the head of the program, ‘‘For the most part, structures are
considered altered when they contain more advertising panels than the permit indicates’’.
As noted above, the inventory data reveals 944 double signs with single sign permits.
Both the 2012 and 2014 Inventories contain the city’s legal ﬁndings as to the signs. This
section was not mandated in the ordinance that initiated the program, and prior to the
inventory’s release, city actors claimed that the city’s legal ﬁndings were not public
information and would not be included in the inventory. The Permitted column appears
to clearly note whether a sign has a permit on record, listing a ‘‘Y’’ or ‘‘N’’ to denote
permitting status. In the 2014 Inventory, 7755 signs receive a ‘‘Y’’ while 759 signs receive
an ‘‘N’’. As noted above, 870 signs, not just 759, have no permitting information listed and
thus no permit. The city oﬀers no explanation for identifying 121 signs that lack permits as
The 2014 Inventory contains a ‘‘Remarks’’ column that states for 744 signs: ‘‘Requires
application of B & P section 5216.1’’. For the remaining signs, this column is blank.
California Business and Professions Code Section 5216.1 is a state law that creates a
rebuttable presumption of legality for any sign that has existed more than ﬁve years and
not been cited as unlawful by a government agency. To rely on this code section, a sign
owner must prove that its sign was in place for more than ﬁve years, often shown by a lease
for land where the sign sits or an electric bill for lighting. The 2012 Inventory contains a
Notes column that lists documents that evidence the age of a sign. For most signs that
230 Environment and Planning A 48(2)
receive the 5216.1 designation, however, this column is empty. The Notes column is entirely
absent from the 2014 Inventory, making it impossible to determine whether evidence exists
to support the 5216.1 designation. As with the Permitted column, the city oﬀers no
explanation for how it decided which signs would receive this designation.
There is a wide discrepancy between the city’s purported legal ﬁndings and the legal status
of signs revealed by the inventory’s own data. Figure 1 oﬀers a visual comparison: billboards
in the Hollywood neighborhood of Los Angeles are mapped according to legal status per the
city’s legal ﬁndings versus the inventory data. Of the 187 signs within the map frame, nine
(4.8%) are illegal according to the city’s legal ﬁndings (Figure 1, left), while 101 signs (54%)
are illegal according to the city’s own inventory data (Figure 1, right). The deﬁnitions of
‘‘Legal’’ and ‘‘Illegal’’ in the map based on the city’s legal ﬁndings relies on the undeﬁned
designations employed by the city as described above: ‘‘Legal’’ includes signs that are (1)
‘‘Permitted’’ and Not ‘‘Altered’’, and (2) Not ‘‘Permitted’’ but protected by Section 5216.1;
‘‘Illegal’’ includes signs that are (1) ‘‘Permitted’’ but ‘‘Altered’’, and (2) Not ‘‘Permitted’’ and
not protected by Section 5216.1. For the map showing legality according to the inventory
data, the categories are more straightforward: ‘‘Legal’’ includes only permitted signs that
match their permits, while ‘‘Illegal’’ includes unpermitted signs and permitted signs that do
not match their permits.
Informality at the individual level: Investigating the role of space and
personal knowledge in regulating outdoor advertising
The recent history of outdoor advertising in Los Angeles reveals the contradictory
governmental moves and shifting deﬁnitions of legality that characterize informality as a
mode of regulation. The players in this drama are a multiplicity of agencies and courts with
Figure 1. Billboards in the Hollywood neighborhood of Los Angeles. Mapping billboards according to the
city’s publicized legal findings (left) versus the legal status according to the city’s own inventory data (right)
reveals the indefinite nature of legality in the Los Angeles landscape.
diﬀering jurisdictions and levels of authority, and the scripts they rely on are the written
authorities of municipal ordinances, state laws, and the federal constitution. The Hollywood
Sign District can be read as a zone of exception, wherein the city allows large corporate
players to hang massive signs despite its overarching ban on new billboards. Informality is
seen within the lines of the inventory as well. We see hundreds of signs that are illegal
according to the city’s own laws and inspection data, yet which the city has deemed legal.
The erasure of detailed permitting information from the 2014 Inventory amounts to an
unmapping: the 2012 Inventory laid out the data for identifying thousands of illegal
billboards, and the 2014 Inventory marks an eﬀort to erase this knowledge. Together, this
evidence reveals that the visual realm of Los Angeles is an informal landscape, where the
categories of legal and illegal are unﬁxed. While informality as a mode of state regulation
may be ‘‘calculated’’ (Roy, 2009: 83), we should not,
conceive the state as a monolithic entity or black box, but rather analyse the often diverse
perceptions, interests and claims within the state among the diﬀerent levels and departments
as well as pay special attention to the role of existing regulatory authorities (e.g. environmental
protection agencies) and approval procedures (e.g. Environment Impact Assessments).
(Follman, 2015: 215).
The case study of outdoor advertising in Los Angeles shows that this amalgam of forces
exists at an even deeper level than governing agencies: ‘‘diverse perceptions, interests and
claims’’ (Follman, 2015: 215) exist among individual state actors. For the remainder of this
section, I will consider how the informal mode of regulation is manufactured at the level of
individual regulators. In the model of space and information described above, urban space is
a creation of lived experience mediated by personal knowledges and histories. By considering
individual actors’ experiences, I argue we can consider the production of space as an aspect
The billboard inventory is a spreadsheet of permit numbers, addresses, and
measurements, and as such, is an archetype of information in the traditional sense, a
collection of inert data that together comprises knowledge of the physical world but is
itself immaterial. If we consider the billboard inventory as a process, a series of individual
actions bound up in speciﬁc materialities, the inventory is more than a spreadsheet and even
more than the thousands of signs that the inventory purportedly represents; it includes a City
Council vote, legal complaints and settlements, thousands of survey forms ﬁlled out by
LADBS inspectors, thousands of paper permits, the digital architecture of LADBS’s
servers, a public records request, as well as the mental architectures of the many people
that created the spreadsheet and have perused it since. Thus, the process that is the billboard
inventory is also the process that is space. Each moment of the inventory that we may study
occurs somewhere, at some time; a unique ‘‘spatial present tense’’ (Cronin, 2010: 106) that
was inﬂected by prior moments and may itself aﬀect future ones. In short, we can read the
billboard inventory as a catalogue of the production of space. In this light, the inventory has
more to tell than the permitting status of billboards; it can help explain the behaviors of city
actors that create the informal landscape of signs.
Cronin (2010) understands outdoor advertising as a cycle of cityspace, created by the
fabulation of advertising executives and anti-disciplinary moves of city residents. The
evidence revealed herein suggests that we can extend Cronin’s circle of fabulation, of
discipline and anti-discipline, of barely legible tactics and illegible results. I believe we can
expand the productive cycle of advertising in cityspace to include state actors as tacticians
themselves, not just the foil against which outdoor advertisers act. In my research, I found
that agents representing the city, be they city planners, litigators in the City Attorney’s
232 Environment and Planning A 48(2)
Oﬃce, or members of the City Council, are subject to disciplining forces and capable of
developing ruses just as de Certeau’s ‘‘ordinary practitioners of the city’’ are. The regulatory
actions of the city that together produce a regime of informality can be read at the level of
individual state actors as the haphazard tactics of agents as they negotiate amongst voting
constituents, business interests, more superior members within the government, and state-
based controls including laws and judicial orders. Further, city agents are embodied actors
who themselves experience urban space in unique ways. Indeed, city agents are themselves
residents of the city. They view outdoor advertising as other residents do, in their
daily routines and along their daily routes. Their experience of outdoor advertising is
inﬂected with unique collections of past experiences just as it plays a role in their
fabulation of the future.
The individual experience of outdoor advertising came up time and again in my research
with city actors. On a number of occasions, interviewees interrupted my questions to ask if
there was one billboard in the city that I hated the most. I didn’t have a ‘‘most hated
billboard’’, but I chose a billboard to mention so that the interviewee could then oﬀer his
or her most hated billboard in a reciprocal conversational manner. A former member of the
City Council described with ire a sign directly visible from City Hall, put up by what he
termed a ‘‘scoﬄaw’’ company during the time period after the trial court enjoined the city
from enforcing its sign ban and before the appellate court lifted the injunction. Litigators in
the City Attorney’s oﬃce mentioned various signs that were the subject of lawsuits, such as
one sign whose status was still unresolved so the attorney continued to see it on his daily
commute. These stories invoked the storytellers’ memories of frustration in ﬁghting legal
battles with an understaﬀed oﬃce against companies whose resources aﬀorded them a team
of lawyers to drag out the litigation. Stories like this make it possible to understand why
members of the City Attorney’s oﬃce might dread further lawsuits with outdoor advertisers
and be quite willing to take steps to avoid them. On a more general level, the stories
reveal that actors within the city government have individual experiences of cityspace like
other urbanites. We can posit that these city agents have a twofold role in the production of
space. At one stop in the cycle, they experience the city, the feeling and energy of which is
always inﬂected by memories and knowledges. At another stop in the cycle of production,
their experiences aﬀect their actions as state agents with authority to make and enforce laws
The stories city actors shared about outdoor advertising were not always negative. Amidst
my questions to a Planning Commissioner on a recently approved development project that
will feature large-scale signage, the commissioner strayed from the speciﬁc topic to tell me
about his childhood in rural Chile. He recollected his family’s drives to the city for the
billboards that appeared along the highway. To him, the signs epitomized progress and
success. This Planning Commissioner carries these memories of billboards with him
‘‘snail-like’’ (Donald, 1999: 7) through his life, as he moves through the cityspace of Los
Angeles, just as when he moves in the city’s planning echelons, setting urban policies. In
another instance, a staﬀ member in a City Council oﬃce described her excitement at seeing
new products, movies and television programs being advertised on billboards. To her,
billboards are ‘‘what a city looks like’’ and how she ‘‘knows what to watch’’.
Just as outdoor advertisers fashion presentations for media buyers touting the beneﬁts of
their signage for clients’ products, their lobbyists present promotional materials to elected
legislators on the City Council and members of their staﬀ, selling them on the beneﬁts of
signage for the city as a whole. We can characterize outdoor advertisers’ lobbying eﬀorts as
fodder for fabulation by city agents. The promotional materials oﬀer hopeful tales that
outdoor advertising will improve the economy, help local business, and create visually
exciting urban environments. For city agents such as the woman who ‘‘knows what to
watch’’ because of billboards, the promotional materials and the experience of outdoor
advertising in her daily life reinforce each other: when she sees a new show advertised on
a billboard and subsequently watches it, she proves to herself that the billboard ‘‘works’’.
As she moves through cityspace in her daily life, seeing a new ad reinforces her feeling of
productivity and positivity for the city’s economic future. For elected oﬃcials who aspire to
help the city’s economy, along with being reelected, the placement of outdoor advertisements
throughout the city means their daily routes are dotted with reminders of the lobbying
materials, physical structures whose resolute existence in the face of political pressure
recalls the power of the outdoor advertising industry.
Yet not all legislators and their staﬀ are so motivated by outdoor advertisers’ lobbying.
For some city agents, the promotional materials rub against incongruent stories stored in
their ‘‘archive cities’’ (Donald, 1999: 7). Memories of signs erected in violation of the law,
knowledge of the billboard inventory and the number of illegal signs it reveals, frustration at
signing oﬀ on a legal settlement later ruled illegal—these coexist with memories of lobbying
materials, undercutting the strength of their message. When we consider that city agents
have unique ‘‘archive cities’’, made and remade each day as they travel through the city and
collect new experiences, we can understand why one actor may fabulate one story line for
outdoor advertising while another fabulates a diﬀerent story. When they go through their
working lives, decision and actions regarding outdoor advertising are not quarantined from
these experiences, made subject only to top-down imperatives. Rather, their working lives
are a part of the productive cycle of cityspace; their decisions as city agents are aﬀected by
their individual experiences of the city just as these actions then have their own eﬀect on the
city. The variability of these individual experiences and actions, then, helps explain the
informal mode of regulation that is recognizable in the variability among diﬀerent
agencies and levels of government.
Conclusions: Using the informal landscape to spread knowledge
of the informal landscape
In this concluding section, I consider what the billboard inventory spells for the future of
Los Angeles cityspace. The intention of advertising is to inspire consumption, but a
landscape of advertising can have unintended eﬀects. Cronin (2008b) and Iveson (2012)
describe city dwellers’ creative takeovers of outdoor ads as an example of what Klein
(2000: 281) calls ‘‘culture jamming’’. Further, myriad health and welfare consequences
have been linked to outdoor advertising, including alcohol and gambling addiction,
unhealthy eating, and misogynistic attitudes towards women, and advertising promoting
these social ills disproportionately appear in disadvantaged communities (Lowery and
Sloane, 2014). In the hands of cultural critics such as the Billboard Liberation Front,
‘‘culture jams’’ on billboards critique these negative social eﬀects of outdoor advertising
(Figure 2). Here, I focus on the eﬀects of outdoor advertising as a landscape of
informality. How does the widespread illegality revealed by the billboard inventory aﬀect
the ongoing cycle that is the production of Los Angeles urban space?
I have argued herein that the precariousness of the city’s regulation of signage can itself be
read as a state tactic. The billboard inventory shows not only that over half the billboards in
Los Angeles are technically illegal, but perhaps more importantly, that the city’s designation
of illegality is unclear and subject to change. Hence, the informal landscape of signage is
maintained by a mode of regulation that is itself informal. The ﬂexibility that this mode
provides the city in regulating signage has unintended consequences for Los Angeles
234 Environment and Planning A 48(2)
cityspace. The 2002 sign ban inspired outdoor advertisers to ﬁght the city in court and in
public space as they erected signs in deﬁance of the laws. City agents now claim that the
billboard inventory shows the number of illegal billboards in Los Angeles to be about 1000.
As described herein, a careful analysis of the inventory reveals far more than 1000 illegal
signs. When asked to explain the discrepancy, the head of the program explained, ‘‘Although
many structures are not in perfect sync with their permits, the deviance is considered minor
or insigniﬁcant’’. This tolerant attitude toward code violations in public space goes against
the global trend, noted above, towards heightened regulation in urban public spaces (see e.g.
Blumenberg and Ehrenfeucht, 2008). If we look beyond the example of outdoor advertisers,
however, we see that Los Angeles is willing to enforce its regulations over the visual
landscape against outsiders to the commercial landscape of advertising.
Street artists, in particular, are regularly subject to the city’s enforcement actions, from
having their work ‘‘buﬀed’’ (painted over) to being jailed for years (Wilson, 2012). Street art
in Los Angeles has a long and vibrant history. Large, meticulously planned murals share
space with spray-painted tags of gang members and, more recently, art posters adhered to
walls, signs, and street furniture with wheatpaste (Daichendt, 2012). For years enforcement
over illegal street art was limited to tagging and other graﬃti. After enacting the 2002 sign
laws, however, the city cracked down on muralists and others whose intentions were more
clearly artistic. This crackdown was another unexpected result of the city’s informal
regulation of outdoor advertising. After outdoor advertisers challenged the 2002 sign ban
in court, the City Attorney argued that a mural ban would strengthen the city’s claims in
these lawsuits: outdoor advertisers could not argue that the city was regulating the content of
their signs in violation of the First Amendment if outdoor art was banned as well. The City
Council banned murals on all private property. A local journalist said at the time,
‘‘In Los Angeles, which Councilman [Jose] Huizar likes to boast is ‘the mural capital of
the world,’ the painting of any mural on an outdoor wall, even with permission from that
wall’s owner, is illegal’’ (Wilson, 2012). In 2014, the city enacted a new law to allow murals to
go up with city approval, but not before buﬃng over hundreds of murals throughout the city.
Street artists, therefore, are fully aware that the city has the ability and resources to
enforce rules over the visual sphere of the streets. While the city’s relationship to outdoor
advertising may appear as non-planning, street artists consider the city’s failure to strictly
regulate outdoor advertising as fully planned, fully intentional. Many street artists have used
Figure 2. The Billboard Liberation Front highlights the misogynistic portrayal of women in advertising.
Credits: Kalman, Milton R, 2010.
their art to draw attention to the uneven enforcement of laws regulating public space.
They position their work on billboards to reclaim the visual environment from outdoor
advertisers. Figure 3 shows work thrown up on billboards by Los Angeles artists in a
coordinated attempt to raise awareness of illegal billboards. Figure 3 (left) shows two
signs taken over by the art collective Cyrcle asking, ‘‘Is this illegal? Los Angeles has more
than 4,000 illegal billboards’’. In Figure 3 (right), the artist Desire Obtain Cherish (DOC) is
seen hijacking a billboard with the same simple but subversive message.
On one level, these artworks exemplify the vibrancy and dynamics of urban space.
They emerge from and add to the ever-changing experience of daily urban life that Hack
(2011) calls ‘‘urban ﬂux’’. In particular, these pieces bring ﬂashes of creativity and slightly
jarring moments of curiosity to city residents. Yet the art also operates on a deeper level. The
pieces contest existing power structures through their subversive use of public space. They
are particularly powerful for they interject themselves into public space to contest the
existing power structures of public space itself. They draw meaning and power from their
interaction with the billboards that hold them. The street artists throw these pieces up to
interject a new message in the ongoing production of urban space, remaking the message of
outdoor advertising. The pieces spread the knowledge of the billboard inventory through the
Los Angeles landscape, providing fodder for diﬀerent fabulatory responses to billboards
than those envisioned by outdoor advertisers.
I asked DOC whether the billboard that held his work (Figure 3, right) was technically
illegal. He said, ‘‘We thought about trying to ﬁgure that out for each sign we took over but
then we realized that it didn’t matter ... the point is that so many are illegal you don’t know
which signs are illegal and which aren’t’’. His thought process reveals the eﬀects of informal
regulation: in a realm so suﬀused with legal violations, the very categories of legal and illegal
break down and become meaningless. Not surprisingly, some city agents are uncomfortable
with this eﬀect of informality. There is a movement in City Hall to solve this in the simplest
way possible—to issue valid permits to illegal billboards. In the minds of these city
legislators, the categories of legal and illegal will be reinvigorated, and the cracks in the
city’s facade of authority will be smoothed over. Yet this quick wiping away of illegalities
would conﬁrm that the city’s legal categories are changeable. Other city agents including
members of the City Attorney’s oﬃce, oppose this ‘‘amnesty’’ for billboards. After years of
Figure 3. Los Angeles-based street artists Cyrcle (left) and Desire Obtain Cherish (right) hijack billboards
to publicize the city’s uneven regulation of public space. Photo Credits: i am OTHER entertainment, LLC,
236 Environment and Planning A 48(2)
bitter lawsuits against outdoor advertisers compounded by their daily experience of illegal
signs in the landscape, they are not prepared to grant this gift to the outdoor advertisers.
Thus, the illegal signs stand, the knowledge of illegality created by the inventory spreads, and
the informal landscape continues.
I would like to thank John Given, Dennis Hathaway, Su Jin Lee, and John Wilson for their eﬀorts in
support of this project. I am indebted to the reviewers for their thoughtful consideration and insightful
Declaration of Conflicting Interests
The author declared no potential conﬂicts of interest with respect to the research, authorship, and/or
publication of this article.
The author received no ﬁnancial support for the research, authorship, and/or publication of this
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