Such lighting also violates Lake Elsinore's commendable municipal code on lighting:
All outdoor lighting fixtures in excess of 60 watts shall be oriented and shielded to prevent direct illumination above the horizontal plane passing through the luminaire and prevent any glare or direct illumination on adjacent properties or streets. Due to the City’s proximity to the Mount Palomar Observatory, the use of low pressure sodium lighting shall be encouraged. [Ord. 853 § 1, 1989; Ord. 772 § 17.38.040, 1986. Code 1987 § 17.38.040]. (See http://www.codepublishing.com/CA/lakeelsinore/.)
I like having a motocross track. I can hear it from my home, and though I'd prefer not to hear it in the evening, I'm ok with the extended hours if it meets a demand from our community. I do however, vehemently object to the choice of light fixture and that lighting mitigation was not considered in the initial study.
Not only is the fixture the most egregious light polluter available, due to glare, it is a poor choice in any application where motorists and pedestrians mix. Motocross patrons, the nearby communities and economic development areas, and the astronomical research community need a better solution.
I'm grateful to The City of Lake Elsinore for the opportunity to comment. Below the comments I submitted:
I believe the Initial Study for a Mitigated Negative Declaration for the Lake Elsinore Motocross Facility Change in Operations (herein referred to The Declaration) is deficient in not addressing the following potential impacts of artificial lighting:
- Impact on aesthetic enjoyment of the night sky by nearby communities
- Degradation of a critical resource used in professional research
- Creation of safety hazards from glare
- Degradation of economic development recovery measures from light clutter
It is imperative that these effects be considered because the choice of lighting described within The Declaration has the greatest potential to maximize the above problems:
…the proposed project would result in the use of portable, diesel-generator powered lighting. Lighting features proposed would consist of up to 30 lighting units, with each unit consisting of four 1,000 watt fixtures. The portable lighting fixtures will be mounted on standards measuring up to 30 feet in height. As needed, lighting would be provided between the hours of 5:00 p.m. and 10:00 p.m. during November through March; 6:00 p.m. and 10:00 p.m. during the months of April through May, and October; and 7:00 p.m. and 10:00 p.m. during June through September. With the addition of nighttime lighting, the number of hours in which the facility could operate would increase. Depending on the time of year, the amount of hours added to daily operations will vary from several hours in the winter months, to no more than two hours during the summer. (From pages 7-8 from The Declaration; bold text is my emphasis)
From the description in The Declaration it is possible the lighting described is the same type of lighting typically used at construction sites for temporary lighting. These lights lack proper shielding and their nearly horizontal aim guarantees that the motocross lighting will be a community eyesore and hazard where visibility is concerned. The photograph below shows a hillside being lit by one portable light, similar to those described in The Declaration. Note that the background is an 800-foot slope being lit by light spilled beyond the lighting target. You can even see shadows of trees near the light projected onto the hillside
Why Lighting Impacts should be considered the The Declaration:
- Impact on aesthetic enjoyment of the night sky by nearby communities: The boundaries of Lake Elsinore and Wildomar are interlocked, similar to the shape of jigsaw pieces. Unshielded light disperses in a radial pattern, and therefore, does not constrain itself to city boundaries. Light from Lake Elsinore dominates nighttime views to the north and toward the zenith as seen from Wildomar. What Lake Elsinore does or fails to do with lighting affects Wildomar. See Figures 1 and 2.
- Degradation of a critical resource used in professional research: Lake Elsinore and the Motocross Facility are located inside a 45-mile radius from Palomar Observatory, which is recognized under Riverside County Ordinance 655 as subject to regulation of light pollution for the protection of the observatory. Though Lake Elsinore has not adopted this or a compatible ordinance (Note: my error: I learned of Lake Elsinore's ordinance after submitting my comments later), artificial lighting still affects research opportunities a Palomar Observatory. What Lake Elsinore does or fails to do with lighting affects state-of-the-art scientific research being conducted locally. See Figure 3.
- Creation of safety hazards from glare: Flood lighting that lacks proper shielding can create glare that interferes with motorists', bicyclists' and pedestrians' ability to see obstacles and each other. This can create traffic and personal safety issues. See Figures 10 and 11.
- Degradation of economic development recovery measures from light clutter: The Motocross Facility is located next to an economic recovery area called the Lakeland Village/Wildomar Redevelopment Project Area (RDA). The lighting guidelines for the area are intended to reduce an affect called lighting clutter. Unshielded, bright lights will undermine their efforts. (Full disclosure, John Garrett is on the RDA committee and has been the primary influence on the lighting guidelines). See Figures 4 and 5.
Mitigation Issues to Consider
All of the potential lighting impacts can be resolved with a "Less Than Significant With Mitigation Incorporation" rating if the following measures are taken:
- Identify lighting tasks as Class I (Color rendition required), Class II (area, walkways, parking, and security while area is not occupied), or Class III (decorative).
- For Class I, it is assumed that white light sources will be used. These should have full cutoff light fixtures. An exception may be for stadium style lighting, assuming that such lights have visors that greatly reduce the spillage of light beyond the target area. Note: Musco Lighting is a leader in this type of light fixture. See Figures 7 and 8.
- For Class II and III, use full cut off fixtures where possible and narrow spectrum light sources, such as low-pressure sodium lamps (yellow-orange in color) or high-pressure sodium lamps (amber color). Some new LED lighting in amber colors is also a suitable alternative. See Figure 6.
- Use downward lighting for all signs. See Figure 9.