New York City at the turn of the century had no laws protecting the physical fabric of the City. By the 1870s, large billboard advertising signs dotted the urban landscape.12 There were some nascent efforts to control billboard signage. In 1896, for instance, the Parks Commissioner passed a law removing billboards from public parks.13 However, by 1911, New York City was reported to have 3.8 million square feet of billboard advertisements.14 Art societies, including the Municipal Art Society and the American Scenic and Historic Preservation Society, began to use billboard regulation as a way to beautify the City. The Municipal Art Society, along with Albert Bard, worked on legislative measures to regulate the billboard placement in the City.15 In 1913, the Mayor set up a commission to find methods for billboard regulation called the Mayor's Billboard Advertising Commission of the City of New York. Robert G. Cooke, head of the commission, claimed that the advertisements "rob the people of their rightful heritage of natural beauty."16 Eventually the 1916 zoning resolution, which divided the City into specific areas or zones, worked to set up rules for billboard signage on public property