Letter from Carl Crow to Commissioner of Public Works. Shanghai, December 28, 1933. Source: SMA (SMC), U1-14-3267 (1157).  

Sometime ago we were supplied with a copy of "Special Regulations" with respect to Advertisement structures and boards" dated December 30, 1930.

Paragraph 4 of these regulations reads in part as follows: "No portion of any advertisement structure other than a skeleton sky sign shall be at any point more than 20 feet above the ground, etc."

At the time this regulation come into effect, we rebuilt our outdoor advertising plant to conform and we have since then so far as I know erected no advertising signs contrary to this regulation.

However, I notice that a great many advertising signs in the International Settlement are more than 20 feet in height, in fact it is our impression that we are the only advertising concern that is living up to the regulations. If there have been any changes in the regulations, will kindly advise us?  

Extract from Municipal Gazette - Municipal Notification No. 4428 - Advertisements. Shanghai, December 29, 1933. Source: SMA (SMC), U1-14-3267 (1159).

With reference to Municipal Notification No. 4255 dated June 30, 1932, notice is hereby given that the following revised scale of fees has been approved and will be enforced from July 1, 1934 [See Excel Sheet in the "Table Section"]

Six calendar's months notice by publication in the Municipal Gazette will be given of any change in the above fees.

By order, J.R. Jones, Secretary. Council Chamber, Shanghai, December 28, 1932. 

Commissioner of Public Works to Secretary - "Advertising Hoardings - Letter from Carl Crow Inc of 28/12/1933". Shanghai, January 16, 1934. Source: SMA (SMC), U1-14-3267 (1160).

No alterations have been made to the Regulations with respect to Advertising Hoardings since the original draft was agreed upon by the Council and a committee of advertising contractors, Messrs. Carl Crow Inc, included.

There are a number of signs in the Settlement which sere in existence before the Regulations were applied and so far as this Department is aware, there has only been one infringement of the new regulations and the necessary department action is being taken. 

Letter to Carl Crow from Deputy Secretary. Shanghai, January 16, 1934. Source: SMA (SMC), U1-14-3267 (1161).

In reply to your letter of December 28, I have to inform you that no alterations have been made to the Regulations with respect to Advertising Hoardings since the original draft was agreed by the Council and a committee of advertising contractors, including your own firm.

There are a number of signs in the Settlement which were in existence before the Regulations were applied and so far as the Council is aware, there has only been one infringement of the new regulations and the necessary department action is being taken. I have, however, to thank you for your letter and to inform you that your observations will be given due attention.  

Letter from  Carl Crow to Deputy Secretary. Shanghai, January 23, 1934. Source: SMA (SMC), U1-14-3267 (1162).

I am obliged to you for your favour of January 16 and in reply have to say that either we entirely misunderstand the regulations or that the Council is misinformed as to their enforcement. I beg to call your attention to the following locations:

• Bubbling Well Road ad Chengtu Roads 22 1/2 feet high 
• Kiangse and Foochow Roads : 26 feet high ; 
• Avenue Edward VII and Mohawk Roads 23 1/2  feet high 
• Nanking Road at old entrance to Louza Police Station 25  feet high.

 
All of these locations have been erected since the regulations were put into effect, some within the past four months. 

I submit to you that it is most unfair not to enforce these regulations strictly. By raising the height of the advertising structures the revenue is increased at very little additional expense, enabling those who do not observe the regulations to undersell those who do. May I ask you to give the matter your further consideration?  

Deputy Secretary to Commissioner of Public Works to Secretary - Enquiring for comments on the subjet of "Carl Crow re Advertising Hoardings". Shanghai, February 6, 1934. Source: SMA (SMC), U1-14-3267 (1163).

Will you be so kind as to favour me with your comment on the above matter. If you have no comment to make, or if you find you are unable to comment at present, will ou be so good as to endorse this note accordingly and return same to me.  

Commissioner of Public Works to Deputy Secretary -"Advertisement Hoardings - Letter from Mr. Carl Crow dated 23rd January 1934 - Reference M13/4". Shanghai, February 8, 1934. Source: SMA (SMC), U1-14-3267 (1164).

I find upon further investigation that Mr. Crow is correct in his statement that there were four infringments of the Regulations as enumerated in his letter. Of these, the board has been removed in one case, one structure was originally erected before the new Regulations came into force, but in this, and in the two remaining cases, the Advertising Contractors have undertaken to make the necessary alteration.  

Letter to Carl Crow from Deputy Secretary. Shanghai, February 9, 1934. Source: SMA (SMC), U1-14-3267 (1165).

I reply to your letter of January 23 (1934) it has been found upon further investigation that  your are correct in your statements as to a number of infringements of the Regulations with respect to Advertisement Hoardings.

Of these four infringements, the board has been removed in one case, one structure was originally erected before the nex Regulations came into force, but in this, and in the two remaining cases, the Advertising Contractors have undertaken to make the necessary alterations.  

Letter from Millington, Carl Crow , Mercury Press and Consolidated National Advertising Co. to Commissioner of Public Works. Shanghai, February 9, 1934. Source: SMA (SMC), U1-14-3267 (1166-1167).

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 doubt boards were being displayed but since then, due to increase rentals and taxation, it has been found not only expedient but absolutely necessary to double-bank boards in certain locations.

Now a standard 32-standard sheet poster covers a space 10' in heigth and if one is placed directly on top of aonther, they cover a space 20' high on the poster board.

Naturally, certain amount of margin between the posters and allowing for say 1,5' below and above, this would make the total height of the double display 23 feet.

I order, therefore, that advantage may be taken of placing one poster on top of another withtout infringement of regulations, we would like to suggest that the Council's rulgin of 20 feet maximum heigt be changed to 23 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 reglulations issued  by the Council delaing 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 over 20 feet, above crown land. As the object in view when this regulation was drafted was primarily to insure safety of the advertising structure and as no signs can be more secure and safer than one actually erected against the wall, we would suggest that the ruling of hte Council in the matter be amended to exclude signs erected against wall spaces from these limitations.

Signed: Millington, Limited (F.C. Millington, Managing Director), Carl Crow, Incorporated (Signed : Carl Crow, President), The Mercury Press, (G.E. Bruce, General Manager)?  

Carl Crow to Deputy Secretary. Shanghai, February 12, 1934. Source: SMA (SMC), U1-14-3267 (1168).

I am obliged to your for your favor of February 9, and in reply beg to point out that I did not in my letter of January 23 pretend to give you a complete list of infringements of the regulations with respect to advertising hoardings, nor do I propose to do so. The inspection of these hoardings should be the duty of the Municipal Council and I do not wish to be put in the position of making trouble for my competitors. I gave your four instances of violation merely to show tat I was correct in my original contention but there are many more. In fact, one hoarding in violation of the regulations has been erected since writing you.

I am sorry to note that the Shanghai Municipal Council does not consider this matter of enough importance to give it serious consideration.

Commissioner of Public Works to Deputy Secretary -"Advertisement Hoardings - Letter from Mr. Carl Crow dated 12th February  1934 - Reference M13/4". Shanghai, February 21, 1934. Source: SMA (SMC), U1-14-3267 (1169-1170).

Prior to the receipt of the above letter from Mr. Carl Crow a large number of advertisement hoardings were inspected, and of these, a few were found to be higher than the limit of 20 feet allowed by the Regulations. Action was deferred, however, on account of the receipt by this Department of a joint letter, dated the 9th inst. (February), from several Advertising Agencies, including Messrs. Carl Crow, Incorporated, requesting an amendment of Regulation No. 4 with respect to allowable height of hoardings.

The question has been considered and I am forwarding a report on the matter today.

The co-operation of various Advertising Agencies was invited in formulation the Regulations and without co-operation on the part of the firms in carrying them out the control of advertisement hoardings is not easy. Many of the smaller srtuctures are erected very speedily, and are completed before they can be inspected and measured. In numerous cases hoardings which complied with the regulations when erected are subsequently raised or added to without obtaining a permit and it is a difficult matter, with a very limited staff, to continually inspect all hoardings the the Settlement in ordre to ensure (p. 2/2) that enfringements of the Regulations do not take place.

The instance mentioned by Mr. Crow of a hoarding having been erected since receipt of his letter presumably refers to one in Bubbling Well Road, which was erected just prior to the Spring holidays without a permit, and with respect to which action was already being taken.  

Commissioner of Public Works to Deputy Secretary -"Special Regulations with respect to Advertisement Structures and Boards". Shanghai, February 21, 1934. Source: SMA (SMC), U1-14-3267 (1171-1173).

See Archive ID 967

Letter to Carl Crow from Secretary. Shanghai, February 25, 1934. Source: SMA (SMC), U1-4-3815 (0169).

I am directed to acknowledge receipt of your letter of February 12, and in reply, to inform you that as a consequence of a letter received from several Advertising Agencies, including yourselves, the question is at present under consideration. 

Copy of Minute of Works Committee Meeting - Held on Tuesday - the 27th February 1934. Shanghai, February 27, 1934. Source: SMA (SMC), U1-14-3267 (1174).

See Archive ID 967

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).

See Archive ID 967

Commissioner of Public Works to Carl Crow, "Regulations with respect to Advertisement Structures and Boards". Shanghai, March 20, 1934. Source: SMA (SMC), U1-14-3267 (1178).

Commissioner of Public Works to Consolidated National Advertising Company, "Regulations with respect to Advertisement Structures and Boards". Shanghai, March 20, 1934. Source: SMA (SMC), U1-14-3267 (1179)

Commissioner of Public Works to Mercury Press, "Regulations with respect to Advertisement Structures and Boards". Shanghai, March 20, 1934. Source: SMA (SMC), U1-14-3267 (1180)

Commissioner of Public Works to Millington, Ltd., "Regulations with respect to Advertisement Structures and Boards". Shanghai, March 20, 1934. Source: SMA (SMC), U1-14-3267 (1180)

With reference to the letter of the 9th ult. (February 1934), from yourselves and other advertising agencies, I have the pleasure to inform you that the Council has approved the following modifications of the Sepctial Regulations with respect to Advertisment Structures and Boards, viz

• (a) An increase in allowable height of ground hoardings to a maximum of 24 feet. The allowable height of roof signs remains unchanged.
• (b) Boards erected on walls may be of any height provided they are fixed close against the wall and do not project above or bayond the wall to which they are affixed.

I send you herewith a copy of the amended Regulations in which the above points are incorporated, and would at the same time draw your attention to the inclusion of an additional Regulation No.12, which has been added. These amended Regulations will be put into force from today's date. 

Special Regulations with Respect to Advertisement Structures and Boards - enclosed with letters to the companies. Shanghai, March 20, 1934. Source: SMA (SMC), U1-14-3267 (1180).

See Archive ID 369

Millington, Limited to Commissioner of Public Works, "Regulations with respect to Advertisement Structures and Boards". Shanghai, March 26, 1934. Source: SMA (SMC), U1-14-3267 (1186). 
 
Receipt is ackowledged with thanks, of your letter of he 20th March, from which we are gratified to learn that the Council has approved our suggestion to increase the maximum height of hoardings to 24 feet. 

We thank you also for the copy of the amended Regulations in which the above point has been incorporated and have made a note of additional Regulation No.12 as requested.