CITY COUNCIL MEETING SUPPLEMENTAL

Deficiencies in the Submitted Lighting Study The applicant’s Lighting Report (Exhibit B – Project Plans) is incomplete and unreliable for determining compliance with City standards (see Exhibit A). 1. Incomplete Methodology – Missing photometric data (IES files, BUG ratings, reflectance assumptions, receptor plane height). 2. No Glare or Luminance Analysis – Only horizontal foot-candles shown; glare not addressed. 3. No Receptor Measurements – No readings several feet beyond property lines or at window height. 4. Lack of Certification – Report is unsigned and not certified by a licensed lighting engineer. 5. Inconsistent with Setback Standards – The plan intensifies, rather than mitigates, a setback violation. 6. Risk of Visual Glare – Even with shields, 15-foot, high-output LEDs create visible brightness from neighboring homes. Finding: The report does not substantiate the claim of “no glare or spillover.” Its omissions prevent any credible finding of compliance with Pleasanton’s zoning, lighting, or design review standards. Summary The project, as proposed, violates Pleasanton’s zoning regulations, fails the legal test for variance, relies on invalid precedent, and poses clear visual and privacy impacts on adjacent properties. The submitted lighting study does not meet professional or municipal standards for demonstrating compliance. Conclusion For the reasons set forth above, Application P25-0236 must be denied. The proposal: • Violates PMC §18.84.090 governing permitted structures within setbacks; • Fails to meet State and City variance criteria; • Introduces commercial-scale lighting incompatible with residential zoning; and • Lacks a technically valid lighting analysis demonstrating compliance. Approval would undermine the City’s long-standing principles of neighborhood compatibility, fairness, and consistent code enforcement. Therefore, it is strongly recommended that the City Council deny the application in its entirety. Respectfully submitted, Alan and Crista Shapiro