A more attractive, orderly Terézváros streetscape is a shared interest. Townscape requirements serve that goal when they are clear, proportionate, and practical for condominiums, owners, and businesses. I therefore prepared detailed management and operational proposals on the published draft amendment.
The document published for consultation is a draft amendment to Municipal Ordinance 33/2017 (XII. 21.) on townscape protection. The related public consultation announcement is available on the municipality’s website. This article presents my professional position on that draft, and the comments refer to the cited draft wording.
Below are my detailed comments and practical proposals on the draft ordinance.
1. Clarify the Restriction on Storefront Displays
Section 4 of the draft would prohibit advertising and also “naturalistic images, photographs, or photorealistic depictions” within one meter of the inside surface of a storefront window.
This wording is extremely broad. It could affect food and product photos, portfolio images, real estate listings, photographs showing service results, cultural materials, and even purely decorative pictures.
Please clarify:
- what qualifies as advertising;
- under what conditions a product or service may be presented;
- which informational, cultural, artistic, or decorative materials are exempt;
- how actual products displayed in the window are treated.
Sections 4 and 5 partly regulate the same restriction but with different wording. Aligning them would support clear enforcement.
2. Resolve the Contradiction on Advertising Installations
Section 7 of the draft states:
“Advertising may not be placed on an advertising installation.”
Taken alone, this is difficult to interpret because an advertising installation’s basic purpose is to display advertising. Other draft provisions nevertheless allow advertising on certain street furniture, such as advertising columns.
Please identify precisely which installations may and may not display advertising.
3. Distinguish Business Names, Store Identification, and Advertising
The draft would prohibit advertising on terrace furniture, including shade structures. It does not clearly establish whether advertising includes:
- the store’s name;
- the company logo;
- the name of a hospitality business;
- opening hours;
- a simple description of the service offered.
Without clear distinctions, the same wording could be treated differently in separate proceedings.
4. Define Transitional Provisions
The draft does not sufficiently address advertising and installations that were lawfully placed before the change.
Please specify:
- how long existing lawful installations may remain;
- the time allowed for modification or removal;
- how long existing townscape decisions remain valid;
- the grace period for affected owners and businesses.
Given the potentially substantial fines, the ordinance should not create noncompliance overnight.
5. Simplify the Five-Year Renewal Procedure
The draft makes decisions authorizing an advertising installation valid for five years. At least 30 days before expiration, a new townscape procedure must be initiated or a declaration made that the installation will be removed by the expiration date.
If location, size, technical design, and appearance remain unchanged, requiring full new design documentation, renderings, site plans, and structural plans would be disproportionate.
I propose a simplified renewal for unchanged installations. The relationship between municipal townscape procedures and district-office acknowledgment procedures should also be defined to avoid duplicate administration.
6. Clarify Condominiums’ and Property Owners’ Responsibilities
Under the draft, both the property owner and the advertising installation’s owner could be ordered to act and fined.
In a condominium, this could make the entire community responsible for advertising placed by a commercial unit’s owner or tenant even when the community did not know about it, did not consent, or could not directly remove it.
Please establish a clear order of responsibility. The person placing the advertisement, the installation’s owner, and the user of the premises should be primarily responsible. A condominium should face sanctions only if it demonstrably knew of the breach, consented to it, or failed to take reasonably expected action after notice.
7. Proportionate Legal Consequences
Rules should distinguish a minor administrative omission, a small deviation, and an unauthorized installation with a substantial townscape impact.
The proposed Section 31, introduced by Section 14 of the draft, already provides for warnings, compliance deadlines, and criteria for assessing fines. My proposal concerns their clear, proportionate, consistent application and coherence across procedural situations.
Where noncompliance can be corrected voluntarily and promptly, a clear notice and reasonable deadline should precede a fine. Cooperation and voluntary correction should materially affect the consequence imposed.
8. Correct Drafting Errors
The proposed Section 31(6), introduced by Section 14, repeats item “b),” making the numbering incorrect. In the Hungarian text, “23. §-al” should read “23. §-sal.” The phrase “jogsértő állapot megszünteti” also needs correction.
Alongside clearer wording, I highlight two practical areas: consistent inspections and the operating conditions for public-space greening.
The Need for Consistent Inspections
The district has numerous townscape violations visible from public streets, including replacement street-facing windows and other facade alterations inconsistent with the building’s original appearance.
Parking enforcement is not the objection. The problem is that municipal employees working in public areas regularly pass obvious, persistent townscape violations without a reporting system that brings them to the appropriate department.
Introducing substantial new fines is hard to justify while detection of breaches of existing rules remains inconsistent.
I therefore propose:
- regular, area-based surveys of violations visible from public spaces;
- a simple internal reporting system for municipal staff working in public areas;
- publication of inspection criteria and priorities;
- initial information for owners and reasonable compliance deadlines;
- procedures initiated by the authority itself as well as in response to residents’ reports.
Operational Considerations for Public-Space Greening
Public-space greening is an important goal, but interventions should first be assessed for cost-effectiveness, sustainability, operating consequences, and genuine resident support.
From an operational perspective, removing pavement and parking spaces is costly and difficult to reverse, so alternatives should be compared beforehand. In many locations, movable planters could create greener streets more quickly, at lower cost, and with greater flexibility.
Planters and street furniture immediately against condominium walls are not a suitable solution. Building management must organize cleaning and winter ice removal outside the building under applicable public-space rules and responsibilities. Objects placed beside the facade can:
- obstruct effective cleaning and ice removal;
- reduce usable walking space;
- make facade maintenance harder;
- create additional operating and liability problems.
Planters or other street furniture should therefore not be placed immediately in front of a condominium facade without first consulting the community.
For these projects, I propose always ensuring:
- an accessible pedestrian route of adequate width;
- a clear strip beside the facade that can be cleaned;
- advance consultation with the affected condominium;
- clear maintenance, cleaning, and responsibility arrangements;
- advance comparison of costs and expected results.
A more livable, orderly Terézváros serves everyone. It requires clear, proportionate, workable rules, consistent implementation, and meaningful consideration of condominiums’ practical operating experience.
Sources
Published Draft Amendment to Townscape Ordinance 33/2017 (XII. 21.). References to Sections 4, 5, 7, 12, and 14 in this article refer to the amending draft’s sections.
Terézváros Municipality: Public Consultation on Amending the Townscape Ordinance.
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