July 8, 2005
Douglas E. Noble, P.E., PTOE
Associate Director
Government of the District of Columbia
District Department of Transportation
Traffic Services Administration
Frank D. Reeves Municipal Center
2000 14th Street, NW
6th Floor
Washington, DC 20009
Dear Mr. Noble:
This letter follows up on the June 9, 2005 public meeting regarding the Spring Valley Lighting Project. As the ANC Commissioner from Spring Valley (ANC3D03), I am writing on behalf of the very large number of Spring Valley residents concerned about the new street lights your agency has proposed installing in our community. To date, more than 50% of the households in the affected area have expressed concern about the DDOT proposal.
We appreciated your careful discussion of the program with us at the community meeting on June 9, and we were encouraged by your indication that you will consider options that would make the new lights acceptable to the residents.
Color of lights: As we understand it, you are examining the possibility of using metal halide (white) illumination rather than high pressure sodium, which produces an unattractive orange light that would radically change the appearance of our neighborhood streets. You indicated that the metal halide technology may be somewhat more expensive, but the community members made clear at the meeting that the rather small difference in cost cannot possibly justify a sacrifice in the attractiveness of the neighborhood, which is responsible for high property values and high tax collections by the City.
I understood you to indicate that you would see about installing metal halide bulbs on Rockwood Parkway to see how the neighborhood likes them and whether they are feasible technology.
Brightness level: We were less encouraged by your comments regarding the level of illumination to be provided by the new lighting program. Our understanding is that the proposed program would result in increasing the level by two to four hundred percent. As our community members have made clear, there is simply no need for any increase in lighting. One of the attractive features of our neighborhood is the quiet, serene quality that would be destroyed by bright
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July 8, 2005
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lights. An administrative decision to take action for which there is no demonstrated public safety need, that degrades our neighborhood, and that is opposed by the residents cannot be justified as a matter of public policy. It would also seem to be very bad politics.
There was some reference in the comments of you and your colleague to a need for greater brightness to avoid legal liability for accidents. We question whether there is anything in tort law that would make the City liable for accidents in a place where it is maintaining a lighting level that has been in place for years and is fully supported by the members of the community. If you feel legal requirements are constraining you to increase the level of illumination, we would appreciate an opportunity to meet with the lawyers and discuss the basis for this conclusion and the options available.
You indicated that you would explore the possibility of lower wattage bulbs--which meet the AASHTO standards--the only difference being that the bulbs would have to be changed every 3 years instead of 6. The advantage is that the light at the outset would be much lower (although still compliant with standards--i.e., you would not need to build in the degradation factor over 6 years.) This approach would help alleviate one part of the problem: excessive brightness during the initial years following installation of new bulbs. But it is of course important, as we have indicated above, that the brightness level (even after allowing for degradation) not exceed the present level on our streets.
Collector Streets: You also reported that the illumination level must be even higher on Glenbrook Road and Rockwood Parkway Ð higher even than the level the neighbors find objectionable on their other streets. As we understood you, these streets are classified as Òcollector streets.Ó These are two of Spring ValleyÕs loveliest streets, with gracious homes on large lots, dating from the 1920s when the neighborhood was first developed. Here, too, there is no demonstrated need for an increase in illumination. The nighttime traffic is minimal. Brighter lights in fact are likely to increase the speed of cars by signaling to the drivers that they are on a street set up for quantities of fast-moving traffic.
We recommend that the necessary steps be taken to establish the standard for regular neighborhood streets on Glenbrook Road, Rockwood Parkway, and 49th Street even though they have been listed as Òcollector streets.Ó We will be happy to assist in documenting the case for treating these streets like the other residential streets in the neighborhood. The fact that federal reimbursement may be available for lighting on collector streets cannot be a reason for taking action that degrades the neighborhood.
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July 8, 2005
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Prismatic Lenses: You indicated that you would let us know the feasibility and timing of availability of prismatic globes, which would focus more light on the streets, less in the eyes of drivers and pedestrians, and less on the houses and yards fronting the street. These lenses were specified by the lighting committee as a way to reduce glare in residential neighborhoods. We are happy to have this and any other options considered on an exploratory basis; however, the use of these lenses should not be an excuse for increasing the brightness level. As mentioned above, there is no demonstrated need for higher illumination of the streets themselves; brighter streets may lead to faster driving; and the brighter streets themselves may impair the quiet residential quality of the community.
Lighting Standards: We understand that you will explore alternative lighting standards, including those adopted by ISEE (electrical engineering group of equal stature to AASHTO), and that the ISEE standards might result in more appropriate neighborhood lighting. We look forward to learning more about that standard. And we also urge you and other responsible DC officials to consider using as a standard the lighting level that has been used for decades in our community.
* * * * * * * *
You heard at the meeting the deep concern of our residents that the widely-recognized beauty of their neighborhood not be diminished by street lighting changes that are inappropriate and unnecessary. And the problem is one of broader concern, since the impaired property values that would result from the proposed changes would reduce the CityÕs very substantial property tax collections in this neighborhood.
As was made clear at the meeting, the neighbors wish to have access to all materials considered by the city officials in making decisions on the street lighting in Spring Valley, and they wish to have an opportunity to consider these materials and consult with the officials before decisions are taken. As was made clear in the ANC resolution adopted in last month, we continue to oppose any further action to implement the lighting replacement program, including release of a RFP, until the issues we have discussed with you have been resolved. We recall your mention at the meeting that the installation schedule would be deferred until March 2006.
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July 8, 2005
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We look forward to the opportunity to meet with you in the near future to discuss these matters.
Sincerely yours,
Jill A. Stern
ANC Commissioner, 3D03
4846 Glenbrook Road, NW
Washington, DC 20016
(202) 362-6587