project risks serious nighttime lighting impacts in neighborhood
Example of unshielded car wash lighting fixtures
One of the IS-MND’s most egregious deficiencies relates to the document’s analysis of impacts to nighttime views. Dark skies are a very valuable commodity and in Mt. Shasta are worthy of preservation. Maintaining dark skies is of critical importance in our community for both local and tourist enjoyment. Because cities are fraught with light pollution, our community is one of the dwindling number of locations where one is able to gaze at stars. In Mt. Shasta, the experience of darkness at night and seeing the stars above is still possible on cloudless nights. Preservation of this resource not only benefits the visitors and residents alike but also the wildlife. Reducing light pollution in this Project site’s neighborhood is especially critical here given that there is little existing development at this northern part of the City adjacent to undeveloped Spring Hill.
The Project would introduce new light sources on several acres that currently have no existing light sources. These new sources of light, wall-mounted fixtures attached high on buildings would be clearly visible from surrounding areas yet the IS-MND concludes that the Project would not be a significant source of light. This conclusion defies both common sense and the small amount of evidence in the IS-MND. The Project’s security lighting on all building walls is illustrated in the Project application and is designed to shine outwards to illumine the entire site, not only directly downward. It would certainly cause additional lighting of the dark sky above and neighboring properties, either directly or indirectly. This lighting impact would be even greater during winter nights when the ground is covered with white snow that reflects light upward and outward. Despite this potential lighting impact, the IS-MND fails to undertake the comprehensive analysis that CEQA requires.
The IS-MND also fails to comply with the city’s own municipal code related to disclosing new project lighting information. The information required by the city is to be provided to the Planning Commission during its discretionary review of the Project application. That implies that this lighting information must also be made available to the public during review of the IS-MND. What is required but is missing from the IS-MND includes a lighting report that describes in detail how outdoor lighting will be designed to minimize its impacts. Manufacturer specification sheets are missing. Illuminance levels for the light fixtures, photometric data, and color of all lamps are missing. Specifications showing that lights will be full “cut-off” fixtures capable of shielding all direct light from bleeding onto adjacent properties or roadways are missing. Lighting levels in footcandles both on the Project site and even beyond the property lines are required by the City but are missing in the IS-MND.
Instead, the IS-MND impermissibly allows the applicant to hide that information from the Planning Commission and public, then later submit it after the Project is approved but just to City’s building inspector without any public review. Such deferred mitigation violates the California Environmental Quality Act because it deprives the public of its right to participate in reviewing project impacts. It also violates CEQA by delegating to city staff the discretionary review authority that the Planning Commission is supposed to exercise.
The IS-MND admits the Project’s lighting impacts will be potentially significant unless mitigated. But its proposed mitigation does not specify how bright Project lighting may be, or how much the lighting will spread onto neighboring properties. It is not enough that Project lighting be “shielded so that light would directed downward.” The amount of shielding or its cutoff angle is entirely unspecified. A lighting fixture pointed downward might still emit substantial amounts of light in a horizontal direction and onto public rights of way and directly onto neighbors’ properties. The proposed mitigation does not even include any performance standards as to limit the lighting fixtures' lumens or footcandles.
The IS-MND does not include photo-simulations that show the Project’s impacts on the night skies, particularly on night-glow. The IS-MND does not require the lighting be “fully shielded” to prevent any light rays from emitting from the fixtures at angles above the horizontal plane. The IS-MND fails to provide any detail about the Project’s shielding of light sources. The IS-MND fails to address the type of light spectrum that would be implemented with the Project. Using yellow light sources, such as PC-amber LEDs, can reduce sky glow by 70% when compared to white sources such as LEDs. The IS-MND never analyzes the lighting spectrum of the Project lighting sources.
An EIR is therefore required which would provide this analysis and provide additional mitigation measures to ensure that the scenic beauty and night skies of the Project area are protected.
Examples of self-storage units' wall-mounted, unshielded lighting fixtures:
Here is an approximation of nighttime lighting glare that may result from this project's downward-facing wall pack security lighting. If it is to be secure, it must illuminate the grounds. It will be placed high on these buildings and will not be hidden behind any solid fencing. Such lighting is undefined as to manufacturer and model and to its color spectrum, and is unregulated with no mitigation measure being proposed in the project's IS-MND to limit its brightness. There are adjacent residences and public streets where this lighting will be plainly visible and annoying all night long.
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