1. Lighting will have significant impacts on wildlife
Golden Gate Audubon Society
“The project proposal and analysis set forth in the EIR 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 . . “

2. EIR severely underestimates increased illumination
Golden Gate Audubon Society
Assuming 20% reflectance from the surface
“The project proposal and analysis set forth in the EIR 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 . . “
And this does not account for light that directly illuminates surrounding woodland habitat
Proposed sports field lights Existing Great Highway streetlights

3. EIR severely underestimates increased illumination
EIR does not account for unique weather of SF
Golden Gate Audubon Society
EIR severely underestimates increased illumination
Fog and moisture additionally scatter light
Marine cloud layer reflect light back toward ground and surrounding area
Fog is present in SF more than 100 days a year, and fog or low marine layer are even more prevalent in the western end of the city.
Much more than 20% of reflected light escapes
Fog increases night glow up to 6 fold, and clouds up to 4 fold.

4. Lights at the Beach Chalet Will Be Visible from Space
5-6 times more light reflected upward from soccer fields than from the Great Highway
“The Beach Chalet project would be a significant new addition to light on the western end of the park and would be visible from space.” (Longcore & Rich 2013)

5. The Project would create a luminous dome of light…
Golden Gate Audubon Society
“ 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.”
Longcore/Rich letter to CCC, March

6. “[The Beach Chalet EIR] discounts potential impacts to biological resources . . .”
“ [The Beach Chalet 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. . .”
Longcore/Rich letter to CCC, March
Sports fields are the second
Photo © 2012, Joseph Moss,

7. Artificial turf will destroy important habitat
Golden Gate Audubon Society

8. Golden Gate Audubon Society
64 Bird Species Have Been Observed Using the Site by Just One Volunteer
Golden Gate Audubon Society
Canada Goose
Turkey Vulture
Osprey
Cooper's Hawk
Sharp-shinned Hawk
Red-tailed Hawk *
Red-shouldered Hawk *
Peregrine Falcon
Merlin
Mew Gull
Ring-billed Gull
California Gull
Western Gull
Glaucous-winged Gull
Mourning Dove*
Rock Pigeon
Anna's Hummingbird*
Allen's Hummingbird*
Say's Phoebe
Black Phoebe*
Pac-slope Flycatcher
Olive-sided Flycatcher
Northern Flicker
Downy Woodpecker*
Hairy Woodpecker*
Hutton's Vireo* Warbling Vireo Common Raven* American Crow* Western Scrub Jay* Steller's Jay* Barn Swallow * Tree Swallow Violet-green Swallow Pygmy Nuthatch * Northern Mockingbird * Gray Catbird x Ruby-crowned Kinglet Bushtit* Chestnut-backed Chickadee * Cedar Waxwing Hermit Thrush American Robin * Orange-crowned Warbler Townsend's Warbler
Yellow-rumped Warbler Palm Warbler x Northern Waterthrush x California Towhee * Fox Sparrow White-crowned Sparrow * Golden-crowned Sparrow Clay-colored Sparrow x Song Sparrow * Lincoln's Sparrow Dark-eyed Junco * Black-headed Grosbeak Western Tanager House Finch * Purple Finch American Goldfinch * Lesser Goldfinch
Killdeer
European Starling
Brewer's Blackbird *
Red-winged Blackbird
Brown-headed Cowbird
(*= likely breeding in or near the athletic fields; x= rare or uncommon migrant)
Additional species have been observed, including shorebirds during big storm events at Ocean Beach

9. The Project Will Affect Snowy Plovers and Other Wildlife Species
Golden Gate Audubon Society
Recorded observations of the federally-listed threatened Snowy Plover (above) and Red-shouldered Hawk (right) at and around the project site.
(Source: eBird; from Longcore & Rich 2013)

10. “A cursory review of eBird data reveals the presence of Western Snowy Plover quite close to the project site The proposed project would significantly increase the ambient illumination on the beach that is used by this threatened species, which could have adverse impacts by increasing predation.”
Longcore/Rich letter to CCC, March
Snowy plover habitat just 450ft from the fields

11. Increased lighting will
Downy Woodpecker, Red-tailed Hawk, Great-horned Owl [c] Walter Kindutu. Dark-eyed Junco [c] Steven Streit

12. The Project conflicts with the California Coastal Act
Golden Gate Audubon Society
The Project, as proposed
diminishes the coastal values
Will harm wildlife and habitat
Reduce aesthetic value of the site
Impose consequences on surrounding coastal areas
Viable alternatives exist, and have been recommended:
Fields can be improved with safer, cleaner natural grass
Costly, wasteful, and pollution-causing lighting is not necessary