The National Association for Outdoor Advertising is alarming that the Sofia Municipal Council is trying to make lobbying changes in Sofia's outdoor advertising behind the back of the mayor of the capital, Vasil Terziev. In this regard, the organization sent a letter to the mayor of Sofia Vasil Terziev, to the chairman of the Sofia Municipal Council, Tsvetomir Petrov, and to arch. Bogdana Panayotova, chief architect of Sofia Municipality.
With the letter, the association expresses its extreme indignation at the implementation of amendments to the regulatory framework regulating the outdoor advertising business, announced on the unified electronic portal of Sofia Municipality, without public and professional debate, as were the previous changes to the Regulation on Relocatable Objects, Advertising, Information and Monumental-Decorative Elements and Advertising Activities on the Territory of Sofia Municipality (NPORIMDERDTSO). The very name of the above-cited regulation implies the existence of two parties, whose object is the regulatory regulation - Sofia Municipality on the one hand, and the business, in its capacity as owner and performer of activities with movable objects and advertising elements, on the other.
Here is what else they write in the letter:
Up to now, with all the amendments undertaken to the NPORIMDERTTSO over the past 20 years, Sofia Municipality has respected the industry organizations representing the business with movable objects and outdoor advertising operators.
We would also like to note that our Association has been a long-standing partner of Sofia Municipality on a number of projects of public importance, providing services to its members when they need information space, specialized and aesthetic fencing of construction sites during the construction of the Sofia Metro, Christmas decorations for the Capital, in informing the population about measures in the event of disasters and accidents, for any needs of campaigning information notification to the population about socially beneficial social activities and activities undertaken by the Sofia Municipality.
Therefore, our bewilderment about the implementation of an act to amend and supplement the regulatory framework, the regulatory basis of our business, without being informed, is, to put it mildly, “huge“! The impression is that the interests of only one advertising company in the capital are OBVIOUSLY being served, which has been a monopolist for decades and manages over 100% of the advertising at bus stops, 70% of the municipal billboards and 50% of the mega-boards on the street, which have ugly overhanging the representative boulevards of our Capital!
The question remains unclear why, after years of Sofia Municipality failing to deal with the most obvious examples of visual chaos in the Capital – illegal advertising elements in the ground floor area, digital elements that have appeared on the main boulevards, illegal branding of shop windows, graffiti on buildings - monuments of culture, etc., a Report on Amendments to the NPORIMDERDTSO is being quietly prepared, which will unconditionally lead to the deletion of certain advertising operators who, contrary to the examples listed, strictly comply with the NPORIMDERDTSO and have a proven contribution to the aestheticization of the urban environment.
The National Agency for the Environment and Tourism insists that the term of the Public Consultations on the adoption of the Regulation on Amendments and Supplements to the Regulation on Relocatable Objects, on Advertising, Information and Monumental-Decorative Elements and on Advertising Activities on the Territory of Sofia Municipality, published on the unified electronic portal of public consultations of Sofia Municipality, be extended and that real public discussions be held! A working group should be formed within which the prepared changes should be discussed, and they should be precise and objective for all outdoor advertising operators. The National Agency for Advertising, for its part, applies its specific, reasoned proposals and remains available for any form of mutual meetings and consultations.
We give just a few examples of where the visual pollution on "Bulgaria" and "Tsarigradsko Shose" Blvd. comes from, which clearly illustrates that the same is not a consequence of the roofs and the walls with advertising:
Dear Ladies and Gentlemen, this way of acting, in itself, creates considerable doubts about the recklessness of the motives that give rise to it. After reading the thus published Report СОА25-ВК66-6877/13.08.2025, our doubts about the presence of lobbying practices have become even stronger. I have in mind the following proposals for change:
1. Art. 16. The advertising format – “illuminated roof sign“ is completely removed, leaving only the possibility of roof advertising on business buildings and residential buildings in which the advertising company carries out its activities. The argument is: “The ban will significantly reduce the risks of causing damage to buildings and passers-by, in cases of poor design and implementation of the structure, as well as in frequent natural events of high intensity (stormy wind, lightning, etc.). It will reduce the risks to road safety and will reduce light pollution……“.
Comment:
The reasons are too unconvincing! Why do the cells of mobile operators not pose a risk to the structure of buildings and residents?
To date, there has been no recorded incident of a roof advertising structure or part of it falling that has endangered the life of a resident or passerby. All roof signs are placed after preparing technical regulations, which are approved by the Expert Council for Territorial Development. Regarding their implementation, the authority that issued the Permit for placement has the full right to apply control to its authorized persons at any time.
With regard to light pollution - in 2019, the National Agency for the Regulation of the Environment and Water Resources provided a Scientific paper on the topic: Rules and standards for the illumination of illuminated advertising in the city of Sofia“, prepared by the “Technical University – Sofia – Technologies“ of the Department of “Architecture and Urban Planning“ in connection with the adoption of regulatory measures for the illumination of roof advertising elements. The goal of the development was to establish clear standards for the illumination of roof signs so that they do not cause any discomfort to the occupants of the building and neighboring buildings. In this regard, to date, there has not been a single registered signal/complaint against the light emission of any roof sign.
This advertising format is one of the most widespread and image-oriented advertising formats, which is used only by established companies and only in extremely central and communicative locations.
It can be said that the modern appearance of all world capitals is associated precisely with the presence of this advertising format, here are a few examples:
2. Art. 16b. Advertising on stone walls and windowless facades is limited to 60m2. The main argument is: “This is done in order to preserve the overall architectural appearance of the buildings“
Comment:
The reduction in the area of the advertising element displayed on a given facade has the opposite effect, namely it creates a kind of “spot“, which was commented on many times at meetings held with representatives of the “Architecture and Urban Planning“ Department.
Stone walls and those without windows are a good example of European practices of advertising that is aesthetically inscribed in the urban environment! It is architecturally unsustainable to limit it to 60m2, when the wall has an area of, for example, 200m2. For advertising elements on facades, individual projects are created, which always correspond to the architectural features of the buildings, and are then approved by the Expert Council for Territorial Planning by architects, engineers and specialists in “public spaces“. The unification of advertising elements up to 60m² for all buildings is absurd.
3. Art. 17a. All megaformats on facades of buildings in the I, II, III, IV and VII zones are removed with the argument: “The Municipality has the right to formulate requirements for the urban environment, with which to limit the use of movable objects and advertising elements in certain types of land properties or on certain types of buildings“!?
Comment:
Someone needs to interpret how the Sofia Municipality determines in which properties and on which buildings to limit the placement of advertising elements. The changes thus implemented actually completely eliminate the advertising format "megaboard on building facades" from all other zones except the periphery, namely the V-th zone - a measure that does not correspond in any way with the policy undertaken by the Sofia Municipality to reduce visual noise. Why?
For years, the NAVR has been signaling the specialized administration of the municipality about the causes of visual noise. In a series of letters (Letter No. СОА20-НД62-168/14.02.2020) with attached examples, we have proven where the highest levels of visual pollution from advertising and information elements are, namely, on the ground floor of residential central buildings. Where there are regulated and unregulated company signs, stickers, pasted announcements, posters, graffiti, etc. The companies that are members of the NAVR have more than once participated free of charge with restoration activities on the facades of central buildings after the gross encroachments on them by graffiti artists. The issue of using the stone walls of the buildings and those that are clean facades without windows has already been discussed with the specialized directorates of the Sofia Municipality, precisely because of the need to aestheticize the urban environment. For the last 20 years, companies-operators of the advertising format “megaboard on buildings“ have restored the facades of a large number of central buildings, especially in the ideal center of Sofia, Zone II! Buildings that already have their established artistic appearance, according to the adopted Regulation on the Urban Environment of the Sofia Municipality, Appendix No. 7! Please note that it is in Appendix 7 that the positions intended for placing advertising elements are shown. The adopted policy regarding advertising in the central part of the city was dictated by the good practices between business and the condominiums of the buildings in recent decades. I enclose a Letter of Support No. СОА18-ГР94-2125/20.04.2018 from 16 central condominiums, which declare that the maintenance of their buildings is carried out solely through the income from advertising activities! This fact is undeniable and can be verified at any time, in this case we illustrate it with attached photos in presentation form!
Here are a few random examples from the central part of European capitals and cities of the use of free facades for advertising:
In this regard, we believe that the prepared changes to the NPORIMDERDTSO directly attack the companies operating with this advertising channel and will definitely lead to their bankruptcy, dismissal of personnel and condominiums without income!
The question remains open why this advertising channel is being deleted without prior dialogue with its operators, in whose favor is this?!
4. It is interesting that the restriction of Art. 27, which prohibits placing an object or element with an unfinished administrative proceeding for violation of the provisions of this regulation, is being removed. This draws attention to certain companies in the industry that would like to “clear their path“ and rehabilitate themselves despite their systematic violations of the NPORIMDERDTSO. A clear lobbying move!
5. Art. 33. “The placement permit is one for all objects and elements within the scope of the mass public transport stop….“.
This text assumes that the Permit for the placement of the stops will also legitimize the advertising elements, which automatically excludes the possibility of a separate competition for the placement and maintenance of new advertising digital elements. The lack of a competitive principle in the distribution of the most appetizing advertising format “stops“ is in favor of their main operator at the moment!
6. All articles concerning the issuance of a Certificate of Commissioning are deleted, which has been controversial since the previous amendments to the Regulation, but the determination with which it is facilitated to obtain permits in this advertising format is entirely in favor of the company that has a monopoly share in it.
Conclusions:
The amendment to the NPORIMDERDTSO is being carried out NON-TRANSPARENTLY and without REAL pre-announced public discussions, without preliminary meetings and comments on the texts to be amended. This, in itself, is a sufficiently compromising fact regarding the transparency of the changes undertaken in the Regulation.
The undertaken Amendment to the NPORIMDERDTSO is made without a clear analysis of the subsequent effects on the outdoor advertising market and a generalized analysis of the economic and social consequences on numerous condominiums and their buildings.
There is no clearly substantiated opinion as to what necessitates the change of these proposed texts, and not others that have been commented on as controversial in previous procedures for amending the regulation.
The proposed changes in Art. 16 and Art. 17 aim to eliminate the two most aesthetically pleasing and unobtrusive advertising channels - "roof advertising" and "advertising on building facades", which will lead to the bankruptcy of certain companies. Respectively, market demand will be directed to other advertising formats, which will benefit a specific company - a monopolist in them! There is a prerequisite for unfair competition and imbalance in the outdoor advertising market and the transformation of the Sofia Municipality into a business regulator!
The question remains unclear why, after years of Sofia Municipality failing to deal with the most obvious examples of visual chaos in the Capital - illegal advertising elements in the ground floor area, digital elements that have appeared on the main boulevards, illegal branding of shop windows, graffiti on buildings - cultural monuments, etc., a Report on Amendments to the NPORIMDERDTSO is being quietly prepared, which will unconditionally lead to the deletion of certain advertising operators who, contrary to the examples listed, strictly comply with the NPORIMDERDTSO and have a proven contribution to the aestheticization of the urban environment.
After everything stated so far, the NAVR insists that the period of Public Consultations on the adoption of an Ordinance on Amendments and Supplements to the Ordinance on Relocatable Objects, on Advertising, Information and Monumental-Decorative Elements and on Advertising Activities on the Territory of Sofia Municipality, published on the unified electronic portal of public consultations of Sofia Municipality, be extended and that real public discussions be held! A working group be formed within which the prepared changes will be discussed, and that they be precise and objective for all outdoor advertising operators. The NAVR, for its part, implements its specific, reasoned proposals and remains available for any form of mutual meetings and consultations.
Sincerely,
TIKHOMIR MLADENOV, CHAIRMAN OF THE NAVR