The title of this article was created by Cafe Admin. Please note that it appears that non-subcommittee members of the P&Z Commission crashed the subcommittee meeting for which the minutes are disclosed below this article. It is our opinion that a gang on the P&ZC is working out a way to get any and all types of lighting they want on behalf of the Woodstock Academy football field and program. Basically they want to light the field up to Hollywood ‘Friday Night Lights’ standards. Cafe Admin.
To the Planning and Zoning Commission:
What is the danger of weak, non-measurable or confusing regulations? Effectively there are NO regulations.
Regulations should be understandable, measurable, and simple to apply.
Referring to the proposed Wheeler/South Windsor regulations, measurements of lighting levels appears to be any thing but “understandable, measurable, and simple”. For example:
Regarding Illumination Standards (Sec. 6.3.2 C, D)
“maintain horizontal illuminance recommendations” set by the Illumination Engineering Society of North America … Note: The Illumination Engineering Society of North America did not support this technique in the released Model Lighting Ordinance.
Appendix B shows a chart in which illuminance in foot-candles (ft-cd) are compared against a subjective “levels of activity”.
There are several issues here:
1. What’s the difference between “Major Cultural or Civic Centers” (HIGH activity) and Cultural, Civic or Recreational Events” (MEDIUM activity)?
2. Measurement of light in ft-cd, (or Lumens per sq-ft) is problematic. There are meters calibrated for ft-cd measurements but the problem is not the meter, per say, but how it is used. If used to measure light falling on (reflecting from) a property line, then the meter is placed above the area at a specific distance to the surface and the measurement is recorded. This is only one measurement. For regulatory reasons, measurements must be made at “many” points on the property line.
Below, is a list of instructions on how to make “horizontal illuminance measurements” (courtesy of Pacific, Gas, & Electric). This is an example of measurements taken indoors but the principal is the same as for outdoors:
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Regarding Light Pole and Fixture Standards (Sec. 6.3.3 A3)
“Lighting shall not shed more than .25 foot-candle over a property line.”
This is similar to the situation as described above for Sec. 6.3.2 and there is the same issue of exactly how to make this measurement. The difference is that a maximum level is sought along the property line. Is an engineer needed to make and certify this measurement?
Regarding Recreational Facility Lighting (Sec. 6.3.4 A1)
“…The applicant must meet the guidelines established by the current Electrical Institute of Engineers for recreational lighting, and all the requirements of these regulations.”
I have made an effort to find the reference above without success. Perhaps this is the Illumination Engineering Society from the previous reference. If so, the “horizontal illuminance” limits of “Major League Athletic Events” or perhaps, “Recreational Events” would apply. Again, measurement methods are the issue as only the parking lot is covered. This could mean that there is no limit to the illumination level onto the field itself – a clearly unacceptable situation.
The reference also could be the American Institute of Electrical Engineers, which was renamed in 1963 to the Institute of Electrical and Electronic Engineers. However, I was still not able to confirm the reference regarding recreational lighting.
I was able to find this from the International Dark Sky Association (IDA):
The Joint IDA-IDS Model Lighting Ordinance references the Illumination Engineering Society (IES) Recommended Practice for Sports and Recreational Area Lighting RP-6. A description of RP-6 is shown below (Class III and IV would probably apply to any sports field in Woodstock):
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Missing from Sec. 6.3.4 is the requirement that recreational lighting requires a “special permit” (with the exception of pole heights beyond the regulation’s maximum). An example of special permit wording in this regard, is from the Model Lighting Ordinance and shown below (italicization added for emphasis):
VI. LIGHTING BY SPECIAL PERMIT ONLY – Ordinance Text below
B. Complex and Non-Conforming Uses
Upon special permit issued by the Authority, lighting not complying with the technical requirements of this ordinance but consistent with its intent may be installed for complex sites or uses or special uses including, but not limited to, the following applications:
1. Sports facilities, including but not limited to unconditioned rinks, open courts, fields, and stadiums.
2. Construction lighting.
3. Lighting for industrial sites having special requirements, such as petrochemical manufacturing or storage, shipping piers, etc.
4. Parking structures.
5. Urban parks
6. Ornamental and architectural lighting of bridges, public monuments, statuary and public buildings.
7. Theme and amusement parks.
8. Correctional facilities.
To obtain such a permit, applicants shall demonstrate that the proposed lighting installation:
a. Has sustained every reasonable effort to mitigate the effects of light on the environment and surrounding properties, supported by a signed statement describing the mitigation measures. Such statement shall be accompanied by the calculations required for the Performance Method.
b. Employs lighting controls to reduce lighting at a Project Specific Curfew (“Curfew”) time to be established in the Permit.
c. Complies with the Performance Method after Curfew.
d. The Authority shall review each such application. A permit may be granted if, upon review, the Authority believes that the proposed lighting will not create unwarranted glare, sky glow, or light trespass.
Regarding Lighting-Related Definitions (Sec. 6.3.7)
RE: Full Cutoff Light “…above a 75 degree horizontal plane…” This is not the accepted definition of Full Cutoff Light.
RE: Glare “ …great enough to reduce a viewer’s ability to see…” This definition is subjective and has no measured limit.
RE: Partial Cutoff Luminaire “…does not allow any light…to shine above 90 degree horizontal…” This is not the accepted definition of Partial Cutoff Luminaire.
The requirement to have a professional conduct the design for compliant lighting should be the exception and not the rule for meeting lighting regulations. Proposed non-residential lighting regulations should be simple to understand and relatively easy to implement. The IDA-IES MLO can be the guide to meet this goal.
The danger of weak, non-measurable or confusing regulations is obvious; there are effectively no regulations.