CITY COUNCIL MEETING SUPPLEMENTAL

EXHIBIT A The lighting report provided with the application P25-0236 (Exhibit B – Project Plans), does not demonstrate compliance with Pleasanton’s zoning, lighting, and design standards. While the report includes fixture layouts, cut sheets, and photometric diagrams, several critical deficiencies and omissions prevent it from supporting a finding of “no glare or light spill.” 1. Incomplete Photometric Methodology and Missing Technical Data The report does not identify the photometric inputs used to generate its “0.00 foot-candle” claims at property lines. Key information is missing, including: • the IES photometric files (.ies) for each luminaire, • BUG (Backlight–Uplight–Glare) ratings required under IES TM-15, • ground reflectance and measurement plane height assumptions, and • whether obstructions such as fences or trees were included in the model. Without these parameters, the reported “zero foot-candle” values cannot be independently verified and may result from incomplete or unrealistic modeling. 2. No Analysis of Glare or Luminance The report evaluates horizontal illuminance (foot-candles) only. However, glare—light intensity visible directly from the luminaire—is governed by luminance and the viewer’s line of sight, not by ground-plane foot-candles. The Illuminating Engineering Society (IES TM-15) and Federal Highway Administration (FHWA) Lighting Handbook both recognize that high-output LEDs mounted at elevated heights can cause perceptible glare even when measured spillover is low. Because the fixtures are 15 feet tall and each produces roughly 37,000 lumens, the report’s omission of a luminance/glare analysis is a significant deficiency. 3. No Verification at Sensitive Receptor Points Pleasanton’s Design Review Submittal Requirements mandate that photometric drawings show foot-candle measurements several feet beyond property lines to demonstrate compliance. The report does not provide measurements at realistic receptor locations, such as adjacent patios or window heights on neighboring properties. The absence of these data means the City cannot verify that lighting levels remain below the typical residential threshold of 0.1–0.5 foot-candles at property boundaries adopted in comparable California jurisdictions. 4. Inconsistent with Setback and Compatibility Standards The subject tennis court encroaches into the required side-yard setback, and the proposed 15-foot poles would intensify that nonconformity. Pleasanton’s zoning code (PMC §18.32.010 and §18.84.090) is intended to preserve adequate light, air, and privacy between residences.