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Expert Testimony; CCC Staff Report
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Expert Testimony Submitted to the CCC to protect Golden Gate Park and Ocean Beach from inappropriate development

Click here to read or download Prof. Longcore and Catherine Rich's report.

The California Coastal Commission (CCC) completely  ignored the expert testimony of Professor Travis Longcore, the pre-eminent national expert on the negative effects of artificial light on wildlife.  Professor Longcore and Ms. Rich have written the book on this -- literally, the book is  "Ecological consequences of artificial night lighting."    Their report was given to the Commissioners weeks before the hearing;  information was also presented during the May 9th hearing by John P. Dumbacher, Curator of Ornithology and Mammalogy at the California Academy of Sciences. 

 There was NO discussion during the hearing of this report or of the negative  impacts of lighting on Golden Gate Park,  on Ocean Beach, on birds and other wildlife!  When you read the report, you will see the reason -- if they had actually considered this information, the CCC would have had to eliminate or severely curtail the sports lights. 

Longcore's report is worth reading not only for the easy-to-understand introduction to the basics of lighting but also for the description of the birds and other wildlife that currently live in the western end of Golden Gate Park and at Ocean Beach.   Their lives will be forever altered by this project.

 Here is an excerpt from the report: 

"The project proposal and analysis set forth in the [Beach Chalet Environmental Impact Report] does not adequately describe the extent of light pollution that would occur from the new sports field lighting, nor does it take into account the exacerbating effects of the unique weather conditions on the western side of San Francisco and the project site’s location 450 feet from the beach.  "

 "[The EIR ]  improperly discounts the potential impacts to biological resources including nesting birds in the park, migratory birds, seabirds, shorebirds, bats, and any other species currently living in the vicinity of the sports fields."

 "The EIR for the proposed project is far too optimistic that mitigation measures such as lamp design will limit any adverse impacts, especially since the EIR for the project fails to exhibit knowledge of the basic physical properties of light or the different ways in which light affects animal species, including humans."

 "In short . . . the proposed project would create a luminous dome of bright white light where it is currently darker than the surrounding city. This dome, especially under foggy conditions (which occur at least one third of the year), would be the defining visual feature of the nighttime environment in the National Park to the west, and would increase ambient illumination over a wide area to levels that are ecologically disruptive."

Click below to request a copy of the full report.

Click here to download the letter by Eddie Bartley on Avian impacts and toxics in SBR rubber.

Click here to download the CCC Staff Report (pdf).

FROM THE INTRODUCTION TO THE REPORT (emphasis in bold added):

Staff recommends that the Commission find that the appeals raise substantial LCP conformance issues and that the Commission take jurisdiction over the CDP application. Staff further recommends that the Commission approve a CDP for a modified renovation project to address LCP requirements for the site.

The LCP requires that development “emphasize the naturalistic landscape qualities of the western end of the park for visitor use”.  LCP certification documents indicate that the intent and goal of the LCP was to ensure protection of the unique pastoral landscape character of the Park.   The City-approved project will modify the existing Beach Chalet fields area in a way that will alter its naturalistic character, including through the introduction of project elements that would significantly change its spatial organization and setting (e.g., artificial turf, field lights, seating areas, fending, concrete paths, etc.).   The City found that the project would cause significant and unavoidable adverse impacts to the fields area in this respect, including in light of Golden Gate Park’s significant historic status (i.e., it is on the National and California Registers of Historic Places as a historic district), but approved the project via a statement of overriding considerations.

There are likely many different alternative project variations that could address the LCP policy to emphasize naturalistic landscape qualities, but it is clear that any proposal that seeks to renovate the Beach Chalet athletic fields facility consistent with the LCP must emphasize the naturalistic pastoral landscape, including by keeping hardscape and engineered elements to a minimum and making sure they are subordinate to the pastoral landscape character.   Within this context, there are a range of potential project elements that may be appropriate to meet City objectives of increasing the field’s recreational usage while also meeting LCP requirements that protect the naturalistic landscape.   It is within this context (i.e., whether a proposed element increases recreational access and whether it emphasizes the field’s pastoral, non-structured landscape qualities) that project alternatives must be analyzed.   Fundamentally, project elements that break up the overall grassy area are problematic in this respect (such as the proposed 30-foot wide linear concrete area with seating that would bisect the fields entirely), as are significant project elements that significantly frame the field areas in a linear and/or regular fashion (e.g., perimeter fencing).   Other project elements that introduce significant hardscape and ‘engineered’ elements also take away from the naturalistic character of the area.   For other project elements, however, there is some judgment involved as to what tips the scales to not appropriately emphasizing the naturalistic landscape qualities of the site.   For example, some field lighting that doesn't break up the overall grassy area and some linear form seating areas that are integrated into landscape areas could be consistent with that LCP policy.

To bring the project into conformance with the LCP, staff recommends that the Commission approve a revised project that addresses the naturalistic setting and character of the Park and that would include:

 Redoing the natural turf fields with natural grass (including with enhanced foundation and drainage) and maximizing revegetation efforts with an eye towards emphasizing naturalistic spatial organization for the fields area (e.g., curvilinear as opposed to linear)

 Eliminating and/or reducing field lighting (and limiting lighting otherwise to that necessary for public safety)

 Modifying fencing (including because existing fencing which has altered the character of the site is currently unpermitted)

 Modifying seating to be informal bench seating (e.g., intermittent benches) and/or more limited linear seating forms integrated with perimeter paths and landscaping

 Modifying paths to be decomposed granite or equivalent as opposed to concrete

 Providing enhanced signage and path connections between the fields and Ocean Beach, as well as interpretive signing

Such a project would be a significant improvement to the Beach Chalet fields area that would both enhance its pastoral naturalistic character and its utility for recreation consistent with the LCP.    
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