Letter from Millington, Limited and other advertising agencies (Carl Crow, Inc, United National Advertising Company, The Mercury Press) to Commissioner of Public Works , dated February 9th, 1934. Source: SMA (SMC), U1-4-3817 (0227).

With reference to the question of hoardings in the Settlement, some four years ago the Council, on the recommendations of the various Advertising Agencies in Shanghai, decided that 20 feet would be the maximum height permitted boards erected in the city. At that time, no double boards were being displayed, but since then, due to increased rentals and taxation, it has been found not only expedient but absolutely necessary to double bank boards in certain locations. 

Now, a standard 22 sheet poster covers a space 10' in height, and if one is placed directly on top of anther, they cover a space 20' high on the poster board. Naturally, in order to make the display effective, there should be a certain amount of margin between the posters and allowing for say 1 1/2 below and above, this would make the total height of the double display 23 feet. 

In order, therefore, that advantage may be taken of placing one poster on top of another without infringement of regulations, we would like to suggest that the Council's ruling of 20 feet maximum height be changed to 25 feet, which would enable us to give the posters a satisfactory display and remain within the height permitted. 

We should also like to point out that point 4 of the regulations issued by the Council dealing with this matter has been interpreted by the officials of the P.W.D. as excluding the erection of signs affixed against wall spaces at a height of over 20 feet above crown land. As the object in safety of this advertising structure and as no sign can be more secure and safer than one actually erected against the wall, we would suggest that the ruling of the Council in the matter be amended to exclude signs erected against wall spaces from these limitations.  

Commissioner of Public Works to Secretary. Shanghai, February 21, 1934. Source: SMA (SMC), U1-4-3817 (0220-0226).

I forward a joint letter from Messrs. Millington, Limited and other advertising agencies, which has been received by this Department, requesting that two modifications be made in the Special Regulations with respect to Advertisement Structures and Boards, viz., 

• (a) that the maximum permissible height of hoardings given in Regulation No.4 be increased from 20 feet to 25 feet, and 
• (b) that this limitation of height be not made applicable to advertisement signs erected against wall space. 

With regard to (a) at the time the Regulations were formulated, the question of heigth in relation to standard size of posters was not considered. The point now raised, however, appears to be a reasonable one, and I recommend that advertisement structures erected on the ground be permitted of a height not exceeding 24 feet above the ground. (This also be the limit imposed under the 1931 New York Code of Ordinances). For Structural reasons, however, I do not feel disposed to recommend any allowable increase in height in the case of roof signs. 

With regard to (b) I have no objection to advertisement boards erected on walls of buildings being excluded from the limitation of height referred to in Regulation No. 4 provided they are fixed close against the wall and do not project above or beyond the wall to which they are affixed. 

(p.2/3) Should my recommendation be approved, the following amendments should be made to the existing Regulations: Regulation No.4 should be altered to read as follows:

"4 - No portion of any advertisement structure other that a skeleton sky sign shall be at any point more that 24 foot above the ground, or 20 feet above the level of the roof immediately below such structure and the lowest par of all  such structures shall be at least 18 inches above the level of the roof immediately below such structure. The intervening space below such structure shall be kept open or filled in only with approved lattice work. 

Skeleton sky signs may be of such height depedent upon the circumstances of each case as may be approved by the Commissioner of Public Works. 

Advertisement signs erected on walls of buildings shall be exempt from the height limitations of this Regulation provided

• (a) that the signs are fixed close against the walls, and
• (b) that no portion of the signs project above or beyond the walls to which they are affixed. 

Regulation No.8 should be amended as follows :

"8. Advertisements painted on walls or roofs shall not be restricted as to height, but otherwise shall be subject to all the conditions of the permit and these regulations in so far as the said conditions and regulations are applicable. 

I recommend also that an additional clause be added to the Regulations, to read as follows :

(p.3/3) 
"12. Should any advertisement structure or board, either during erection or at any time after completion, be found to contravene there Regulations, the holder of the permit shall upon notice trom the Commissioner of Public Works alter such structure or board to comply with these Regulations, or alternatively to remove the same, and should such not be altered to his statisfaction within the time specified in such notice the Commissioner of Public Works may cause such structure or board to be forthwith removed, and all fees whatever which may have been paid in respect of such structure or board shall be liable to be forfeited. 

Should these amendments be approved that they be put into force forthwith. 

Special Regulations with Respect to Advertisement Structures & Boards. Shanghai, December 1930. Source: SMA (SMC), U1-4-3817 (0217-0218).

Municipal Notification No. - Advertisement Hoardings. Shanghai, December 1930. Source: SMA (SMC), U1-4-3817 (0216).

Extracts from Works Committee Minutes dated February 27, 1934 - Advertising Structures and Boards - Special Regulations. Shanghai, February 27, 1934. Source: SMA (SMC), U1-4-3817 (0215).

Advertising Structures & Boards - Special Regulations - With a report submitted the Commissioner of Public Works forwards a joint letter from Messrs. Millington, Limited, and other advertising agencies, requesting that two modifications be made in the Special Regulations with respect to Advertisement Structures and Boards, viz., 

• (a) that the maximum permissible height of hoardings given in Regulation No. 4 be increased from 20 feet to 23 feet and 
• (b) that the limitation of height be set made applicable to advertisement signs erected against wall space. 

With regard to (a) Mr. Harpur states that at the time the Regulations were formulated, the question of Height in relation to standard size of posters was not considered. The point now raised, however, appears to be a reasonable one, and he recommends that advertisement structures erected on the ground be permitted of a height not exceeding 24 feet above the ground. For structural reasons, however, he does not feel disposed to recommend any allowable increase in height in the case of roof signs erected on walls of buildings being excluded from the limitation of height referred to in Regulations No.4, provided they are fixed close against the wall and do not project above or beyond the wall to which they are affixed. 

Should this recommendation be approved amendements to existing Regulations No. 4 and 6, as outlined in his report, will become necessary. He also proposed inclusion of an additional Regulation (No.12).

After discussion, it is RECOMMENDED that the application submitted by Messrs. Millington, Limited, and other advertising agencies for two modifications to the Special Regulations governing Advertisement Structures and Boards be approved and the amendements and addition thereto proposed by the Commissioner of Public Works be authorized.  

Secretary to Commissioner of Public Works - Special Regulations with respect to Advertisement Structures and Boards. Shanghai, March 8, 1934. Source: SMA (SMC), U1-4-3817 (0214).

The recommendation contained in your report of February 21, relative to the amendment of Regulations Nos. 4 and 8 and the inclusion of an additional Regulation to be numbered 12 to be put into force forthwith, have received the Council's approval. 

Report by Commissioner of Public Works, "Advertising Structures and Boards - The Modifications Made in Special Regulations." Shanghai, March 9, 1934. Source: SMA (SMC), U1-4-3817 (0211-0213).

Extract from Municipal Gazette - Advertising Structures and Boards - Two Modifications Made in Special Regulations. Shanghai, March 16, 1934. Source: SMA (SMC), U1-14-3267 (1177).​​​​​​​

ADVERTISING STRUCTURES AND BOARDS - TWO MODIFICATIONS MADE IN SPECIAL REGULATIONS - The Council has acceded to the request of advertising agencies for two modifications of the Special Regulations Governing Advertisement Structures and Boards, thus permitting an increase in the height of hoardings. 

At a meeting of the Works Committee on February 27 the commissioner of Publix Works submitted a report with a joint letter from Messrs. Millington, Limited and other advertising agencies requesting that the two modifications be made in the Special Regulations with respect to Advertisement Structures and Boards, viz. 

• (a) that the maximum permissible height of hoardings given in Regulation No. 4 be increased from 20 feet to 23 feet and 
• (b) that this limitation of height be not made applicable to advertisement signs erected against wall space. 

With regard to (a) the Commissioner stated that at the time the regulations were formulated the question of height in relation to standard size of posters was not considered. The point now rased, however, appeard to be a reasonable one, and he recommended that advertisement sutrctures erected on the ground be permitted to a height not exceeding 24 feet above the ground. For structural reasons, however, he did not feel disposed to recommend any allowable increase in height in the case of roof signs. 

With regard to (b) he had no objection to advertisement boards erected on wall of buildings being excluded from the limitation of height referred to in Regulation No.4, provided they were fixed close against the wall and did not project above or beond tehe wall to which they were affixed. Should his recommendation be approved amendments to existing Regulation Nos. 4 & 8 as outlined in his report, would become necessary. He also proposed inclusion of an additional Regulation (No.12).

After discussion, the Committee recommended to the Council that the application be approved and that the amendments and additions thereto proposed by the Commissioner of Public Works be subscribed. The Council concurred.