LIGHT POLLUTION
Though special technology can help limit light spill, it cannot eliminate glare and skyglow. Skyglow is of significant concern; glare is an issue for a wide range of residents due to the topography of the area. This concern extends to wildlife as well, as circadian rhythms are often disrupted by such powerful light sources. Using new lighting technology or not, the four 80-foot tall light tower structures would be unsightly and would illuminate a large swath of Ross Valley. Views toward and from Mt. Tam would be degraded or eliminated many nights a year, a condition consistent with an urban setting but inappropriate for Marin County. More on lights
NOISE
Imagine the long term effects of 514 lighted events per year in Marin Catholic’s stadium.
Neighbors of MC already experience practice and game noise during the daytime all week. Lights would cause unlimited night-time usage of the stadium.
These planned 514 events would essentially mean that the lights would be on continuously from late August through the late Spring every year.
The disruption to peaceful evenings is unwarranted and simply unfair, and the residents shouldn’t be asked to tolerate the transformation of the area. The crowd noise emanating from nighttime games is not limited to cheers and boos of course, but includes noise from stomping feet on aluminum bleachers, air horns, and crackling announcements from the PA system.
Specific Issues Concerning the Marin Catholic Noise Study
There are numerous defects with the Noise Study submitted by MC that render it incomplete for assessing the impacts of the proposed project. In discussing MC’s submission, it is important also to discuss the 2014 report generated by Alan Rosen. Alan Rosen was selected by the CDA to perform compliance tests for the 2014 stadium renovation project. As such, the Alan Rosen results can be viewed as objective tests.
- The Noise Study contains no measurements of noise from MC’s band at football games. As neighbors are well aware, the band is a much more substantial source of noise for neighbors of the campus than the PA system. MC’s band is not a “voice” source of sound but rather a percussive source of noise, which has a different impact as compared to “voice” sources of noise. MC has known of this issue since it received comments on its 2012 application for stadium lights. This should have been measured during actual games.
- Percussive sound is also different from “voice” sound. The noise from percussive sound is often not dampened by traveling into a building. While closing a window may reduce the sound from voice sources, it does not mitigate sound from percussive sources to the same extent.
- The Noise Study provides no baseline measurements of noise from MC’s crowd at football games. As neighbors well know, the crowd is a much more substantial source of noise for neighbors of the campus than the PA system. MC has been well aware of this issue since it received comments on its 2012 application for stadium lights. This should have been analyzed during actual games.
- The Noise Study contains no mention of measurements of game whistles, horns or other sources of noise. This should have been analyzed during actual games.
- The Noise Study contains no analysis of the combined or cumulative noise that would be emitted with the proposed change of use. Again, rigorous testing of actual games should be required.
- The Noise Study alleges that an “adjustment” in measurement levels could be made for difference in weather. As there are no baseline measurements in the Noise Study for crowd or band noise or combined or cumulative noise, this alleged “adjustment” has no meaning in assessing the primary sources of noise from the proposed project. The Noise Study also provides no scientific basis for the alleged adjustment or error ranges around the alleged adjustment. We understand this type of adjustment relies on various assumptions that may not hold in this area. Given the unique amphitheater aspects of the subject property and its neighbors, a more rigorous empirical analysis is necessary rather than speculative theoretical adjustments. As such, this entire discussion is conjecture and not a reliable basis for assessing whether the project would have significant impacts or not.
- The Noise Study alleges that an “adjustment” in measurement levels could be made for difference in the size of the crowd. As there are no baseline measurements in the Noise Study for crowd, this alleged “adjustment” has no meaning in assessing the primary sources of noise from the proposed project. There is also no systematic data available to establish baseline levels of noise for various sizes of crowd in different weather conditions. Given the unique amphitheater aspects of the subject property and its neighbors, a more rigorous empirical analysis is necessary rather than speculative theoretical adjustments. As such, this entire discussion is guesswork and not a reliable basis for assessing whether the project would have significant impacts or not.
- The Noise Study is vague in terms of the precise location of the various sound measurements made at each property location and therefore is incomplete for this reason. The Noise Study provides a table purportedly comparing noise readings at five locations taken during the 2014 season. The table appears on the bottom half of page 3 of the Noise Study.
- The table shows results taken by Rosen et al on October 11 and October 18, 2014. Members of Preserve Ross Valley (PRV) were present for these measurements along with GPOA Board President Jack Valinoti. All of these tests occurred on private property and in each case the homeowner granted access to the property for purposes of the testing. At 172 Vista Grande, the test location was an upstairs deck facing MC only available from the interior of the house. At 130 Corte Balboa, testing occurred at a backyard deck facing MC available only from the home. At 100 Corte Elena, testing occurred on a backyard deck facing MC only available through a backyard gate. At 15 Almenar testing occurred on a front porch.
o For 100 Corte Elena, 130 Corte Balboa, and 172 Vista Grande, the test locations used by Rosen faced MC as opposed to the front yard or street, where the physical structure would have dampened sound being emitted from MC. This is in contrast to locations along the street at these addresses, where the building structure would dampen the sound, making any measures here of little use. - Grzebik compares tests for MC games on September 6, 2014, November 15, 2015, and November 28, 2015. PRV representatives have confirmed with the homeowners of 172 Vista Grande, 100 Corte Elena, and 130 Corte Balboa that Grzebik did not have access to the same testing locations on their private property. Grzebik does not state from where precisely he made these measurements, whether from the public street or some other location. Without such information, there is no way to assess if this information is comparable or not.
- The following graphs compare the noise tests of Rosen from the appropriate testing locations at these properties and Grzebik’s undisclosed testing locations. The bars show the measurement of sound at each location. Each reports the dBA slow test results, which we understand are a primary metric in the Marin County Sound Element Guidelines for assessing noise from a proposed project. When there was a range, the blue shows the minimum while the red area indicates the range to the maximum. The data clearly show that Rosen systematically measured much higher noise levels than Grzebik.
- Without a clarification regarding the precise locations that Grzebik selected when he took his measurements, the application should be deemed incomplete as this data may be measuring two different locations from an acoustic perspective.
- The Noise Study also claims to test the noise emitted from a “night” setting on the MC sound system tested on November 25, 2015. These tests suffer from the same vagueness issues as the other tests because the precise testing locations at each property are not disclosed.
- There is no systematic information regarding ambient noise levels at any of these locations during proposed night time usage of the proposed project. As such, there is no information to assess if there are significant impacts at the new proposed time of day for use of the proposed project.
- MC’s noise testing does not assess other locations. We understand that there are concerns with noise emitting to other locations. More rigorous sound testing should be done in actual game settings at a more diverse set of locations.
- The noise study does not identify or assess relevant standards for making an assessment of the potential significant impacts of this proposed change of use.
- The application should be deemed incomplete until a complete acoustical report has been submitted. Please note the attached letter from acoustical engineer James Reyff of Illingsworth & Rodkin that describes the need for more meaningful analysis before an assessment of the project compliance with the County’s regulations as well as CEQA analysis.
- MC should be required to pay for sound testing by Alan Rosen for noise to establish meaningful baseline noise levels during actual football games during the 2016 football season. MC should be required to work with the GPOA and other neighborhood groups as well as the Audubon Society and Friends of Corte Madera Creek to establish appropriate testing protocols. This testing, at a minimum, should:
o Be conducted by a qualified and independent acoustical engineer. - Test for all types of noise emitted by the proposed project, including crowd and drum/band noise, whistles, etc., not just PA system noise. There should also be an assessment of cumulative effects from all sources associated with the project.
- Include an empirically-based, rather than theoretical, assessment in how noise changes could occur with changes in crowd size and atmospheric conditions.
- Be geographically comprehensive to test all locations that may be subject to not only significant impacts from noise but also significant cumulative effects of noise, traffic, lights, and increased human activity. This includes not only testing in neighboring residential areas but also testing in neighboring wildlife areas.
Acoustical Engineer James Reyff of Illingsworth & Rodkin, letter describing need for more meaningful analysis before an assessment of the project compliance with the County’s regulations as well as CEQA analysis: Marin Catholic Stadium Lights IR Review 0201161