To ensure the design and scale of new development makes a positive contribution to the built form of the area and is respectful to the existing character and streetscape.

Use and development is to maintain the character of the area.

Encourage advertising signs that are compatible with the particular building and area, including the conflicts of competing signage, and preserve the character of existing vistas and views.

To limit advertising on commercial buildings consistent with the character of the area.

1. Relevantly, it is policy[8] to generally discourage promotional signs and moving message signs unless it is demonstrated that (amongst others):
   • the sign will not cause visual clutter;
   • there is a maximum of one sign per premises;
   • an above verandah sign has a maximum area of 1.5 square metres;
   • the sign is designed to complement the building;
   • it does not interfere with the functioning of an adjoining road; and
   • is innovative and enhances the vitality of the area.
2. Policy, however, is to guide decision making. It is a statement of intent and reflects a desired outcome. It is not to be used as a de-facto planning control in such a manner as to prohibit a proposal for which the Planning Scheme allows a permit to be granted. In determining whether or not a permit should be issued, the acceptability or otherwise of the proposed signs must be assessed against the policy background of the Planning Scheme, with reference to the physical characteristics and visual amenity of the host building and its context.
3. It is evident that the policies seek to avoid visual clutter and other undesirable outcomes arising from the inappropriate and/or disorderly display of signs. Although there is an inherent degree of subjectivity in any assessment of visual amenity, this can be limited by an objective consideration of the physical elements that influence an area's appearance and character.
4. The existing business identification signs on the host building are of modest proportions, a simple design, and are located in such a manner to appear as respectful additions to the façade. The proposed signs are positioned on the upper sections of the building, and are well separated from these existing business identification signs. There is no overlap between signs, regardless of which angle they are viewed from. I am not persuaded that the proposed signs will result in the creation of visual clutter on the review site.
5. On a broader scale, the balance of the activity centre is visible further along Dandenong Road to the south-east. As is to be expected within such an environment, a number of signs are evident. These include both promotion and business identification signs. Variations in sign form, size, proportion and illumination are apparent.
6. The review site is located a significant distance from these other signs. Having regard to this separation, the proposed signs will not result in the creation of visual clutter. They are discrete, and unique, elements of a large building which is removed from the consolidated core of the activity centre. Although the existing signs will be visible in the background, they are sufficiently distanced to not have a close visual interaction with the proposed signs. This also arises as a consequence of the elevated form of the proposed signs, and their restricted viewshed due to their siting at an oblique angle to the road, the varied alignment of Dandenong Road, and intervening vegetation and built forms.
7. In passing, I also observe that, in determining to approve the display of the signs on the site in 1996, the Tribunal expressed no concerns regarding the effect of the signs on the amenity of the area in general. The assessment of the signs' visual impact was confined to that on neighbouring residential areas. The Tribunal noted that the site is at the gateway of a long established commercial area which is characterised by various types of signs. If anything, this context is better able to accommodate the proposed signs than was the case at that time, given the emphasis of current planning policy on the intensification of activity centres[9], and the anticipated change in the built form and composition of these types of areas.
8. More proximate to the review site are the advertising signs displayed on the neighbouring service station, and the large promotion sign on the opposite side of Dandenong Road. These signs are all separated from the review site by the intervening roads. The service station signs are in the viewshed of the proposed west-facing sign for only a limited distance. Once adjacent to the service station there is no overlap of the signs. Similarly, the promotion sign is angled toward Tooronga Road, is separated from the review site by the full multi-lane width of Dandenong Road, and is at a lower elevation. The signs are all positioned at opposite sides of the intersection. I have not been persuaded that the display of the proposed signs will result in any visual clutter, or unacceptable conglomeration of advertising elements in this location.
9. As stated earlier, a purpose of Clause 52.05 is to ensure that signs do not contribute to visual disorder. It is arguable that, when compared to the more conventional static billboard signs, animated or electronic signs are more prone to creating or contributing to visual disorder due to their brightness and constantly changing or moving images - which are often displayed at variable intervals. These signs have the effect of constantly altering the appearance of the immediate environment. In this instance, the site's environs include a wide road and intersection, a railway reservation which is elevated in part, and an absence of buildings on the southern side of Dandenong Road. Having regard to this context and to the restricted visibility arising from their siting and angle to the road, I do not consider that the signs will result in visual disorder.
10. I am also satisfied that the display of the signs will not cause detriment to the amenity of residential areas. The signs will not be visible from the dwellings to the north, in John Street. From the residential area on the south side of Dandenong Road, the signs will be visible only from selected vantage points, including within the road reserves of Normanby and Balaclava Roads, and the front setback areas of some dwellings. Further, this will be at a distance of some 100 metres and, in part, the views of the signs are obscured by the elevated railway embankment, the associated infrastructure and by vegetation. The acceptability or otherwise of the signs' visibility from this perspective must be considered in the context of their location within a business zone, in an activity centre and on a main road location. I consider that the signs will not appear as visually dominant or intrusive elements when viewed from this residential area.

Will the signs have an unacceptable impact on road safety?

1. Both the Council and VicRoads oppose the grant of a permit on road safety grounds. Their submissions make specific reference to the distracting effects of advertising signs, and the implications of this distraction for the operation of Dandenong Road.
2. The focus of the submissions is on the west-facing sign, rather than the south-facing sign. The latter is parallel to the road and its visibility is restricted to the extent that one could question the effectiveness of the sign. It is not visible to motorists travelling in a south-easterly direction and it will be outside the 'view cone' of north-west bound motorists. Nonetheless, it will be visible from some vantage points, including from the railway reservation, and, on this basis, the applicant is seeking permission for the display of this sign. VicRoads confirmed that it has no issue with the south-facing sign provided images are static for at least 30 seconds. I agree that issues of road safety are more relevant to the west-facing sign, and the following assessment will focus primarily on the effects of this sign.

1. Before proceeding to assess the subject proposal, I feel that something needs to be said about the role of VicRoads in the consideration of applications for the display of animated and electronic roadside signs.
2. A purpose of Clause 52.05 is to ensure that signs do not adversely affect the safety, appearance or efficiency of a road. Clause 52.05-1 requires that an application to display an animated or electronic sign within 60 metres of a freeway or arterial road declared under the Road Management Act 2004 be referred to VicRoads for comment. In this instance, VicRoads' response to the application referral stated:

It is VicRoads policy not to support advertising with animation within close proximity of arterial roads as this could cause unacceptable road safety risks to the motorists.

1. I was not provided with, or referred to, any document which articulates this policy position. There is no explanation of how this policy position was arrived at; what consultation, if any, took place in developing this policy; what factors were considered; whether the policy is based on specific research; or what factors influence how this policy position is implemented on a case-by-case basis. It could almost be interpreted as being tantamount to a blanket opposition to all animated signs which are proximate to arterial roads. There is no evidence in the referral comments that each proposed sign is assessed on its merits or, if so, what criteria are used in undertaking such an assessment. No information is provided to assist decision makers in their task of determining whether approval should be given for the display of any particular sign.
2. This policy does not appear to sit comfortably with the fact that, according to the Planning Scheme, a permit may be granted for the display of animated and electronic signs on land within the Business 2 Zone. This discretion is not constrained or qualified by any specific reference to the position of a sign relative to an arterial road. The proximity of a sign to such a road may be a relevant consideration, but need not always be a determinative consideration. Indeed, as evidenced by existing approvals of electronic signs elsewhere in other municipalities, there are circumstances where the display of this type of sign near an arterial road is considered to be acceptable. In this respect, I also note that VicRoads' referral response states that the proposed sign could cause an 'unacceptable' safety risk. This implies that a sign may in fact result in an 'acceptable' safety risk, but there is no indication of what this may be, or how it would be determined.
3. As noted in VicRoads v Bayside CC [2009] VCAT 2734[10], the 2007 Advisory Committee Report - "Sign provisions in planning schemes - final report" included the following recommendation:

In accordance with the recommendation of the Parliamentary Road Safety Inquiry into Driver Distraction, VicRoads establish a working group to develop a more stringent approach to the installation, use and content of scrolling, moving and video-style advertising within and adjacent to road reserves. This includes standards for signs within moving electronic displays and signs with static electronic displays.

1. The Tribunal in VicRoads (No. 1) was advised that a working group had been formed, but it appeared that little more had been achieved in the two years since the Advisory Committee Report was handed down.
2. VicRoads' submission in respect of this proposal did not make any reference to the working group, nor to any progress the group may have made in developing a policy or guidelines which address the display of animated and electronic signs within and adjacent to road reserves. Given the importance of such information to my consideration of this application, the silence of VicRoads on this issue suggests that no further work has occurred on this project since the time of the VicRoads (No. 1) decision.
3. Based on the submissions at the hearing, I understand that the policy of not supporting the proposed signs is related to VicRoads' broader objective of increasing the safety of the state's road network. VicRoads wishes to minimise the number of distractions to drivers along main roads. As I will refer to later in these reasons, there is currently no conclusive evidence that signs cause a distraction which results in a proven negative effect on road safety. This does not appear to support VicRoads' policy position of not supporting signs solely on the basis that they may distract drivers. In my view, a more strategic and sophisticated approach by VicRoads to the assessment of applications is warranted.
4. The purposes of Clause 52.05 refer not only to safety, but also to the appearance and efficiency of a road. In comparison to conventional static billboard signs, electronic signs have a greater impact on roadside appearance, due to their highly illuminated and dynamic nature. As these types of signs perhaps become more commonplace there is the potential for individual merits-based approvals to, cumulatively, have an undesirable effect on the appearance of roads. They also have a greater potential to affect the efficiency of roads, as drivers may slow down on their approach to a sign in order to view its changing messages.
5. I consider that the assessment of electronic signs presents greater and more complex challenges than that of the standard billboards. Specific policy guidance in the assessment of these types of signs is required. Matters such as location, siting, elevation, luminance, relationships to the natural and built environment (including traffic signals, other signs etc), the extent/ nature of animation, and the effects on the safety, appearance and efficiency of roads should be addressed by the policy.
6. As the State's road authority, and as a referral authority under the Planning Scheme, the views of VicRoads are an important consideration in the assessment of applications to display animated or electronic signs proximate to main roads. VicRoads' views must be considered by decision makers, including the Tribunal, and must be afforded due weight in making a determination. Given this, VicRoads has a key role to play in the development of policy to guide the exercise of discretion in these matters. A well-articulated policy based on relevant research and evidence is required. Further, once developed, the policy should be demonstrably applied within the specific circumstances and context of each proposed sign to assist in the task of determining whether or not the sign is acceptable.
7. It is not the role of the Tribunal to develop such a policy. I can only encourage VicRoads to move forward with the recommendations of the Advisory Committee.

1. The potential impact of electronic signs on road safety was comprehensively addressed by the Tribunal in its determination of VicRoads (No. 1) and VicRoads v Bayside CC [2010] VCAT 564. These decisions relate to the electronic major promotion sign that is displayed at 354 South Road Hampton[11]. In summary, the Tribunal found:
   • No study has yet been undertaken that has definitively and unambiguously established to what extent the display of an advertising sign is a distraction to motorists, such that it will have a proven negative impact on road safety.
   • Relevant research supports the proposition that a driver who glances away from the traffic ahead for more than two seconds significantly increases the likelihood of the driver's chances of a road accident.
   • There is a strong case that signs should not contain images or information which may be mistaken for traffic signals or instructions to drivers. Signs should not display addresses, phone numbers or website details that might lead to drivers attempting to write down such details.
   • How close a sign is to a driver's line of sight at traffic lights is a relevant consideration. A sign that is elevated and at an angle to the road is less likely to cause problems in this respect.
   • Given the changing nature of advertising signs, it is overly restrictive to require any one image displayed to be static for a minimum of 30 seconds.
   • Full animation is not acceptable from a road safety perspective. Any one image shown at the one point in time must be fully static, but there can be a rotating of images provided any one image is displayed for at least two seconds. Images shown for any one product must be displayed for at least 15 seconds.
   • As drivers become accustomed to dynamic signs, the signs will increasingly become part of the visual landscape and (with appropriate checks and balances) the average driver can absorb some degree of display of these signs without causing undue road safety risk.
2. Relevantly, in the more recent case of Tewlen Pty Ltd v Melbourne [2010] VCAT 535, I noted that:
   • The Planning Scheme states that signs that may cause a distraction due to their animation are a safety hazard. What needs to be determined is whether the nature of the hazard is such that a sign should not be displayed at a particular location.
   • There is a body of research which indicates that advertising signs cause distractions but the effects are likely to be small when compared to in-vehicle distractions such as mobile phones and satellite navigation systems.
   • While crash statistics are useful, the degree of weight to be given to them is tempered by the fact that they do not include property damage and minor incidents that are not reported. A further consideration is the possibility that drivers involved in an accident may not admit to being distracted, due to liability issues.
   • Each proposed sign needs to be assessed on its merits and with regard to its particular context.
3. This issue has also been considered in a number of other Tribunal cases[12]. Although previous Tribunal decisions are useful in articulating findings and principles that may be applicable in the assessment and determination of new applications, it is important to always bear in mind that decisions are based on the specific facts and circumstances of each case. In my view, this should act to temper any slavish reliance on previous determinations in support of arguments both for and against a proposal.
4. What is evident in the previous decisions is that the Tribunal had regard to the particular circumstances of the proposed signs in the context of the review sites. Consideration was given to a number of factors. These include the nature of the adjoining roads/intersections; the level of existing illumination in the vicinity of the review site; the position of the sign in relation to the driver's 'view cone'; the relationship of the sign to traffic signals; the level of pedestrian activity in the area; crash statistics; and the available research/data on the distracting effect of signs.
5. These are relevant considerations and equally apply to my assessment of the proposed signs. For reasons which I will outline shortly, I consider that the sign in the VicRoads cases is particularly relevant to this assessment given the similarities in the location adjacent to a multi-lane arterial road, a similar degree of animation, the elevated nature, position at an oblique angle to the road, and relationship to traffic signals.
6. Several of the previous Tribunal cases involved the consideration of available research into the effects of advertising signs on road safety. The Tribunal has found that there is no conclusive evidence on this issue.
7. This case is no different. Both parties referred to studies which have examined the impacts of advertising signs on driver's behaviour. I have considered this material and, in my view, it does not include any new evidence that would cause me to depart from the findings of the Tribunal in both the VicRoads cases and Tewlen that there is currently no definitive body of research which concludes that the display of an advertising sign, of itself, results in an increase in traffic accidents.
8. VicRoads submitted details of recent studies which examined the distracting effect of roadside advertising[13]. These studies found that advertising signs can distract drivers. Mr O'Brien referred to recent overseas studies of the relationship between the digital billboards and traffic safety[14]. These studies concluded that the advertising signs have no statistically significant relationship with the occurrence of accidents. This is consistent with the findings of Mr O'Brien's analysis of crash data for locations in Melbourne where electronic signs are, or were, displayed.
9. Notwithstanding the emergence of new data and evidence, I feel that they do not add anything to the analysis that has already been undertaken by the Tribunal in its previous determinations. The Young and Chattington studies are qualified by the fact that further work needs to be undertaken to determine the resultant effects of the distraction caused by roadside advertising signs. The Tantala study only examines crash data and, as noted above, this has its own limitations which temper its reliability as an indicator of whether animated advertising signs have an impact on road safety.
10. In light of this, I consider that a contextual analysis of the proposal, on its own merits, is required. Consideration must be given to a number of relevant factors including the location relative to the road; the complexity of the intersection; the spatial relationship to traffic signals; the elevation the sign; and the extent of animation. These are matters which have been articulated in previous decisions and are relevant to the consideration of this proposal.
11. In VicRoads (No. 1), the Tribunal gave weight to the position of the sign at an oblique angle to the road. It assists in avoiding confusion between the images from the sign and the operation of the traffic lights. I agree that this is an important consideration. The same is applicable here. The west-facing sign is elevated and at an angle to Dandenong Road. It is not positioned behind the traffic lights and will not conflict with the operation of the traffic signals or create confusion for motorists approaching the intersection. The overhead signals are clearly visible on the approach along Dandenong Road and at no time will the sign form a background or backdrop to these signals.
12. Being positioned obliquely to the road alignment, in conjunction with the existence of other intervening elements such as buildings and vegetation, the visibility of the west-facing sign is relatively confined. Based on the evidence of Mr O'Brien, it is only visible for a distance of approximately 100 metres on the approach to the intersection. Significantly, for the whole of this distance, the sign is either within the driver's peripheral vision or beyond. The sign does not enter the driver's 'primary view cone'. This reduces the distracting effect of the sign.
13. It is also relevant that the sign is elevated. In this respect I note the comments of the Tribunal in both VicRoads (No. 1) and Tewlen, and the comments of the NSW Land and Environment Court in Octopus Media Pty Ltd v Canada Bay City Council [2006] NSWLEC 580[15], that advertisements at street level, as compared to those that are elevated, are likely to have a greater visual effect. Conversely, an elevated sign is likely to have a lesser visual effect (and, therefore, be less distracting) than one that is positioned closer to street level.
14. In VicRoads (No. 1), the Tribunal found that a typical driver approaching the intersection in a green light situation is likely to be concentrating on the road ahead and checking whether the lights are changing. A driver will be most aware of the sign when they are required to stop at the traffic lights and are provided with the opportunity to look up and view the sign. This is also the case with the proposed west-facing sign. The sign does not enter the driver's primary field of vision and is therefore not an element that drivers will concentrate on as they approach the intersection. They are likely to be most aware of the sign when they are stopped at the intersection. Even then, the fact that the sign will not be fully animated should act to restrict the extent to which it will distract drivers from their observation of the traffic signals. This is also relevant to the consideration of the sign's impact on the efficiency of the road as drivers are potentially less likely to slow down as they approach the intersection in order to view the advertisements.
15. Dandenong Road is a major metropolitan arterial road. Tooronga Road, although of a lower order, also carries a notable traffic volume. Despite this, the intersection is neither confusing, nor do I consider it to be one that requires a higher level of concentration than would be the case at any other intersection. The only choice that drivers are faced with as they approach the intersection from the north-west along Dandenong Road is whether to proceed straight ahead or turn left into Tooronga Road. In my view, it is not a complex intersection and this is a factor that supports the display of the proposed sign. This is in contrast to the City Road/Power Street intersection in Tewlen where motorists are faced with several advisory signs conveying various forms of information, multiple turning lanes, and merging manoeuvres necessary to access the required lane in order to reach the desired destination. Within that context, I formed a view that the proposed sign in that case would represent an unacceptable traffic hazard.
16. A further consideration is whether this intersection is a high pedestrian volume intersection. The evidence of Mr O'Brien, which was not contradicted, is that the Dandenong Road/Tooronga Road intersection does not display a high volume of pedestrian activity, except perhaps at times coinciding with drop-off and pick-up at a nearby primary school. The evidence states that the number of pedestrians observed is 'low'. I accept that this is not a highly pedestrianised environment, and is a further factor that supports the display of the signs in this location.
17. This brings me to the matter of what degree of animation is acceptable. This issue was addressed in length by the Tribunal in VicRoads (No. 1). The Tribunal found that no particular road safety risk arises from an electronic sign that uses:
    • a series of static images where the whole image keeps rotating (similar to presenting slides using a slide projector); or
    • a fixed background image but with text that changes at intervals, along the lines of a powerpoint presentation

1. Significantly, the Tribunal found that, given the rapidly changing nature of advertising signs in the community in recent times, it would be overly restrictive to require images to be static for 30 seconds, or other extended period.
2. In approving the sign in that case, the Tribunal included conditions that require images at any one time to be fully static, but allow a series of images to rotate provided any image is kept on the screen for at least two seconds. The conditions also require that images shown for any one product last for at least 15 seconds in order to avoid the distraction arising from a situation where the product being promoted keeps changing.
3. Noting the similarities between the South Road sign and that proposed here in terms of elevation, angle to the road alignment, relationship to traffic signals and siting relative to a driver's cone of vision, I do not consider that I should depart from the findings of the Tribunal in the VicRoads cases on the issue of animation. Specific consideration was given to whether the level of animation should be reduced from the approved 'dwell time' of 30 seconds per image. The Tribunal found that it would be overly restrictive to require images to be static for "an extended period" such as this. The Tribunal found that an image should be static for at least 2 seconds. I infer from this that the Tribunal accepted that there is a greater chance of a traffic accident if a driver glances away from the traffic ahead for more than two seconds, and used this as a basis for nominating this minimum 'dwell time' for images.
4. I do not support the Applicant's request that each product being promoted be permitted to be displayed for at least 10 seconds, rather than at least 15 seconds as required by the Tribunal in VicRoads. This figure was arrived at by the Tribunal after careful analysis of the submissions and evidence, and the observations undertaken during its inspection of the sign. The Applicant suggested that the critical figure is the 2 second changeover and that there is 'no magic' to the 15 second 'dwell time' specified by the Tribunal. I consider that 15 seconds is a reasonable period. It represents an intermediate point between the 30 seconds which the Tribunal found to be overly restrictive, and the full animation which it found to cause an unacceptable road safety hazard. I am not persuaded to further reduce this 'dwell time', and I consider it plays an important role in restricting the distracting effect of the sign's animation.
5. As part of my consideration and assessment, I inspected other existing operational signs[16], each displaying varying degrees of animation. Assisted by these inspections, I am persuaded that the animation displayed by the sign in South Road, which was the subject of the VicRoads cases, is an acceptable outcome for the review site. As found in VicRoads (No. 1), this allows the sign to be dynamic to some extent, while restricting the animation to a level which will not present an unacceptable safety risk.
6. I consider that similar conditions to those specified by the Tribunal in VicRoads cases should be applied in this instance. I do so on the basis of the similarities between the sign in VicRoads and those proposed here - similarities which I have outlined earlier in these reasons.

1. For these reasons, I have been unable to conclude that the display of the advertising signs will represent an unacceptable planning outcome from either a visual amenity or road safety perspective. I will therefore set aside the decision of the Responsible Authority and direct that a permit be issued.

The display of two (2) electronic major promotion signs in accordance with the endorsed plans.

1. The plans to be endorsed and which will then form part of the permit are the plans submitted with the application (identified as Drawing S1 Revision B and Drawing S2 Revision C, Project No. A09/0585 prepared by AML Consultants).
2. The location, details and associated structures of the signs shown on the endorsed plans must not be altered without the written consent of the Responsible Authority.
3. The signs must be located wholly within the boundary of the land.
4. The signs must be constructed and maintained to the satisfaction of the Responsible Authority.
5. In relation to the images displayed on the signs:

(a) any one image must be presented in a completely static manner, but there can be a change of such static images, provided that such change cannot be quicker than one new image per two seconds;

(b) in relation to any one product or item being promoted by the signs, the images associated with that one product or item must as a group run for at least 15 seconds;

(c) the signs must not display advertising or messages which contain fully animated or video/movie style advertising or messages; and

(d) the signs must not be used for any live television, satellite, internet or similar broadcast.

(a) dazzle or distract drivers due to their colouring;

(b) be able to be mistaken for a traffic signal because they have, for example, red, amber or green circles, octagons, crosses or triangles;

(c) be able to be mistaken as an instruction to drivers.

(a) images using an unreasonably high intensity of light in the signs, to the satisfaction of the Responsible Authority;

(c) advertising or messages which contain any repeated directional motion, flicker or flashing content; or

1. Each character or digit displayed must be a minimum of 250mm high.
2. No more than five (5) lines of text must be displayed on a screen at any one time.
3. The signs must be fitted with automatic ambient light conditions sensors to control light intensity output / luminance, to the satisfaction of the Responsible Authority and VicRoads.
4. The light intensity output / luminance of the signs must be to the satisfaction of the Responsible Authority and VicRoads.
5. The face of the west-facing sign must be recessed 75mm into the housing to prevent the emission of light at 90 degrees towards John Street.
6. This permit will expire if the signs are not displayed within two years of the date of this permit. The Responsible Authority may extend this period if a request is made in writing before the permit expires or within three months afterwards.
7. This permit expires 15 years from the date of issue.

[1] I have considered all submissions presented by the parties although I do not recite all of the contents in these reasons.

[9] See for example Clauses 11.01-2 and 11.04-2

[10] I will refer to this case as VicRoads (No. 1).

[11] This sign was the subject of a previous Tribunal determination (Octopus Media Pty Ltd v Bayside CC [2004] VCAT 2304)

[12] Octopus Media Pty Ltd v Port Phillip CC [2005] VCAT 2786; Octopus Media v Boroondara CC [2007] VCAT 507; Octupus Media v Boroondara CC [2008] VCAT 650 [sic].

[13] Young, M. S., et al "Conflicts of interest: The implications of roadside advertising for driver attention". Transportation Research Part F (2009), doi:10.1016/j.trf.2009.05.004. M Chattington et al "Investigating Driver Distraction - the Effects of Video and Static Advertising", published report for the London Road Safety Unit, Transport for London.

[14] Tantala Associates, LLC Consulting Engineers "An update of a study of the relationship between digital billboards and traffic safety in Cuyahoga County, Ohio" (November 18, 2009). Tantala Associates, LLC Consulting Engineers, "A study of the relationship between digital billboards and traffic safety in the Greater Reading Area, Berks County, Pennslyvania" [sic] (2 August 2010).

[16] 354 South Road, Hampton; 99 High Street, Kew; 8-12 Punt Road, Windsor; and 1226 Glen Huntly Glen Huntly.