Loading...
HomeMy WebLinkAboutLighting rev1a FINAL - jkPage | Lighting - 1 Rev1a LIGHTING IMPACTS The DEIS has not adequately or properly addressed the impacts of new lighting proposed as part of the Project. The DEIS limits its discussion of lighting impacts that would be created by the Project to a few paragraphs 1 and sentences, portions of which are repeated throughout the DEIS: “The proposed site lighting would consist of light poles and building fixtures. Specifically, as indicated on the Details sheet (see Appendix C), the proposed action includes three 14-foot lamp poles with LED fixtures (two at the above ground tanks between Buildings 7 and 10 and one south of Building 8 at the retaining wall); 38[2] wall scones at 14-feet above grade around the eastern and southern sides of Building 10 and the northern, eastern, and southern sides of Building 9, and western sides of Buildings 7 and 8; and 13[3] wall lights along the northern and western sides of Building 10 and along the western side of Building 9. Each lamp pole would include a shielded fixture such that all light would be directed downwards with no upward glare. To mitigate light trespass and glare, all lighting would be shielded and directed downwards at an intensity compliant with Chapter 172 of the Town Code (Outdoor Lighting). The proposed lighting would comply with the lighting standards set forth in §172-5 and would be subject to the review and approval of the Town of Southold Building Department” (p.163, 234; see also pp. Table 30, p.173, 234). The DEIS also states that “[T]o mitigate light trespass and glare, all lighting will be shielded and directed downwards at an intensity compliant with Chapter 172 of the Town Code (Outdoor Lighting)” (pp. xxxvii, 12, 163, 240). This implies that conformance to the Town Code equates with “no impact” and “mitigation.” It does not. The DEIS does not indicate if the proposed lighting will operate from dusk to dawn, or will equipped with motion detectors. Contrary to claims in the DEIS, no photometric analysis has been performed. The DEIS also states that the “photometric analysis illustrated on the Details sheet (see Appendix C) demonstrates that the proposed design would not result in any off-site or trespass ligh�ng. As such, the 1 A subsection of DEIS Section 1.2.4 is entitled “Site Lighting” (p.11). A subsection of DEIS Section 3.1.2 (Potential Impacts) is entitled “Proposed Site Lighting” (p.163). The sections are identical, except that the latter reference contains a second paragraph having nothing to do with lighting. 2 Only 35 wall sconces are shown on Project site plans (DEIS Appendix C, Sheet 2 of 13 [Alignment Plan]; Sheet 4 of 13 [Utility Plan]). 3 No Building 13 is mentioned among the existing buildings at the site (DEIS p. 2) or called-out on Project site plans. Page | Lighting - 2 Rev1a proposed ac�on would be consistent with this goal from the 2020 Comprehensive Plan” (Table 30, p.173, 234). In fact, no meaningful photometric analysis has been performed. A true photometric analysis focuses on how the light from the fixture surrounds the area of coverage.4 In addi�on to the informa�on referenced in fn4 (below), the por�ons of the Details sheet in Appendix C dealing with ligh�ng include only a ligh�ng schedule which indicates the number of each type of ligh�ng fixture planned for the Project, their lumen 5 ra�ng, profile drawings for the two types of pole mounted fixtures proposed (COMMENT FIGURE L-1). Nothing on the Details sheet “demonstrates that the proposed design would not result in any off-site or trespass ligh�ng.” The DEIS claims that “Addi�onally, the proposed site ligh�ng has been designed to illuminate the subject property in an efficient manner that would minimize nuisances from light intensity, glare and light trespass” (emphasis added) (p.234)”. Note the use of the word “minimize.” This would seem to directly conflict with the previous statement that the Project “would not result in any off-site or trespass ligh�ng.” In fact, the Applicant stated in his April 6, 2023 version of the Project fact sheet (and earlier versions) posted on his website that “Impacts to ecological habitat in Mill Road Preserve, such as increased light in the forest, may occur.”6 That statement was removed from the current version of the fact sheet dated April 23, 2023. The analysis of ligh�ng impacts is especially important because exis�ng light levels on the Project site cannot be compared to post-construc�on light levels. This is because the new ligh�ng will be installed at a lower eleva�on than the exis�ng ground surface. In addi�on, no atempt has been made to measure exis�ng ar�ficial light levels. The amount of new ligh�ng to be installed as part of the Project is considerably greater than exis�ng ligh�ng. No exis�ng ligh�ng is shown on the site plans included in DEIS Appendix C. The DEIS has not considered the following: Will an increase in light levels be visible from adjacent properties and other properties within the Project’s undefined viewshed? This is of special concern for proper�es on North Drive and at 5106 West Mill Road. All of the ligh�ng proposed along the south side of proposed Storage Building 2 (Bldg. 9) will 4 This can be done through creation of an isolux contour diagram which shows areas of equal illuminance. Illuminance measures how much of the incident light (or luminous intensity) illuminates a surface. The unit of measure of illuminance is the lux. This contrasts with luminance, the measure of direct light emitted from a source. Luminance is measured in lumens. The lighting plan shown on Sheet 7 of the Site Development Plans (DEIS Appendix C) indicates estimated post-construction light levels (lumens, lux?) around the Project site, but by virtue of scale and the failure to present this data as isolux contours makes it very difficult to interpret. 5 The amount of light emitted by each fixture. 6 https://strongsmarine.com/assets/images/pdf/4.6.22%20SYC%20building%20project%20fact%20sheet.pdf. (Accessed April 15, 2023). Page | Lighting - 3 Rev1a be less than 200 feet from the former. All of the ligh�ng proposed along the north side of proposed Storage Building 1 (Bldg. 10) will be less than 200 feet from the later. Although the new ligh�ng will be at a lower eleva�on than the nearby proper�es, the possibility that light reflected from the metallic walls of the new storage structures will be visible from these proper�es should have been evaluated in the DEIS. To what extent will sky glow be increased by the new/additional lighting associated with the Project? Sky glow is the brightening of the night sky caused by outdoor ligh�ng and natural atmospheric and celes�al factors. Outdoor ligh�ng contributes to sky glow by producing light that is either emited directly upward by luminaires or reflected from the ground. This light is then scatered by dust and gas molecules in the atmosphere, producing a luminous background. This is the most pervasive form of light pollu�on and can affect areas many miles from the original light source. Will residences with views towards the Project (including those on the east side of Mattituck Inlet) have night-time views of the new storage buildings, or changed views of existing marina facilities as a result of the new lighting? The DEIS has not adequately addressed potential lighting impacts to wildlife. DEIS Appendix N (Ecological Survey) concludes that “no adverse impacts to wildlife or wildlife habitat are expected to result from new outdoor lighting associated with the proposed action” (DEIS Appendix N p.33). The identical conclusion is included in the DEIS (pp. xiii, 140, 174). This conclusion is apparently based entirely on the fact that the “proposed lighting shall be dark skies-compliant” and the unsupported claim that “downward directed lighting [will result] in no increase in light levels beyond the limit of the proposed buildings, access roads, and parking surfaces” (DEIS pp. xiii, 140, 174; Appendix N p. 33). It is unclear whether the “no adverse impact” conclusion is based on the opinion of the Applicant’s ecology consultant, or the Applicant’s Project engineer. Who is quoting whom? Which party is relying on the other? In any case, the lighting levels shown on the detail sheet in DEIS Appendix C, do not include post-construction lighting levels beyond the limits of the Project area. All of the new ligh�ng proposed for the Project will be LED fixtures. Some of the characteristics of LEDs can influence the effect of artificial light on wildlife. White LEDs generally contain short wavelength blue light. Short wavelength light scatters more readily than long wavelength light, contributing more to sky glow. Most wildlife is sensitive to blue light.7 7 Although it not noted in the DEIS, the specific lighting fixtures identified on the Details sheet in Appendix C, come in different color temperatures. https://www.lsicorp.com/wp-content/uploads/2020/05/xpws3-specification-features.pdf Page | Lighting - 4 Rev1a COMMENT FIGURE L-1 Lighting information included on the Details sheet (sheet 7 of 15 in DEIS Appendix C).