Advertisement consent reason for refusal - Public forum - Planning Advisory Service (PAS)

Given that LPAs can only determine advert consent applications in the interests of amenity and public safety, should the reason for refusal refer to Section 3 of the Town and Country Planning (Control of Advertisements) (England) Regulations 2007 (as amended)? Or Section 220 of the Town and Country Planning Act 1990 (as amended)? Our reasons for refusal currently refer to Local Plan policy and the NPPF which I understand are only material considerations. Any help to clarify the situation would be greatly appreciated - thanks!