By Thomas K. Pendergast

Neighbors living around St. Ignatius College Preparatory School on 37th Avenue responded to a court-ordered Draft Environmental Impact Report (DEIR) recently published by the San Francisco Planning Department, pointing out what they see as flaws and inconsistencies in it.

This is the latest round in a struggle that began in 2018, when the school initiated plans to install new LED field lights at J.B. Murphy Field on lighting standards 90-feet-tall, so they could have more evening sporting events.

In 2020, the department determined that the lighting proposal was “categorically exempt” from the California Environmental Quality Act (CEQA) which meant that no Environmental Impact Report (EIR) would be required.

The St. Ignatius Neighborhood Association (SINA) appealed the decision, but in 2021 a Superior Court judge upheld the exemption.

The school went ahead and installed the lights and began operating them. It was estimated that they would be utilized until 9:30 p.m. on 135 evenings, with egress lights off by 10 p.m. On up to 15 evenings, lights would operate until 10 p.m. with egress lighting off by 10:45 p.m.

In November 2022, the California Court of Appeals determined that the project did not qualify for the categorical exemptions and reversed the Superior Court’s decision.

In September 2023, a final judgement was issued consistent with that ruling, which voided the project approvals and meant that an EIR would be necessary.

The judgement also incorporated an agreement allowing limited operation of the field lighting while environmental review was being completed.

At the Planning Commission’s most recent meeting this summer, neighbor Helmut Schmidt described what living across the street during night games was like.

“When St. Ignatius turns on their football field lights, they shine into our bedrooms. Even with blackout shades our windows glow at night,” Schmidt said. “When St. Ignatius turns on their sound system, it can clearly be heard inside our homes, even with the doors and windows closed.

“The homes along 39th Avenue and Rivera Street are disproportionally affected by St. Ignatius’ proposal to have their lights on at night,” he said. “If approved, these lights will shine into our homes for decades.

“Our blocks are being forced to give up 135 nights each year, year after year, in perpetuity. What may be good for St. Ignatius is not necessarily good for the neighbors of the Sunset.”

One major discrepancy is whether or not the lights will actually be on for 135 nights a year, or 150 nights or 214.

When addressing the Commission, the department’s Senior Environmental Planner Don Lewis said the project proposes “up to 150 evenings during the school year.”

But as SINA pointed out in their response to the DEIR, the total number of 214 nights also appears.

“On page S-1 and in other places in the DEIR … it is stated: ‘The proposed field use and lighting program for J.B. Murphy Field and the upper practice field would allow field lighting on up to 150 evenings during the school year. … Yet, (later pages) indicate a proposed 103 games and practices at 100% light level plus another 111 games and practices at 60% light level. … In total, this schedule would result in 214 occurrences.

“It is inconceivable that such basic information about the proposed project is stated inconsistently and obviously incorrectly in some places. …If the proposed project entails 214 … games and practices under J.B. Murphy Stadium lighting, then it is even more significant than the 150 nights specified in the updated project application submitted in 2023,” Lewis said.

In the DEIR, it clearly states “in total, this schedule would result in 214 occurrences where glare would exceed thresholds when lights are viewed directly from field-view locations.”

“Back when they first proposed the lights, we were very much against them, but we lost, so now we’re just trying to make the lights livable; we’re trying to mitigate all the impacts,” said Deborah Brown of SINA. “There’s still too much noise, too much light pollution. They don’t have any sort of functional event management plan, so there’s no traffic (monitors) helping to get 5,000 attendees out of here,” Brown said. “We’re not trying to stop them from using the lights or playing sports. The neighborhood has come to the realization that these lights are here to stay. We just need to minimize the impacts.”

The letter from SINA to the department concludes that “there are myriad errors and inconsistencies in the most basic project information and data. … Some baseline conditions are also incorrect or mischaracterized, leading to erroneous comparisons of the baseline with the proposed project sufficient to support them.

“All identified impacts are characterized as short-term or temporary and are dismissed as being less than significant based on insufficient or flawed analysis. While the impacts may be intermittent (i.e., at evening events that last a few hours at a time), they are not temporary – they are permanent changes that will occur with known frequency on a known schedule.

“Given all of the problems the St. Ignatius Neighborhood Association (SINA) has identified in the DEIR,” the SINA response letter stated, “We have no confidence in the integrity and validity of these results,”

“Additional studies need to be conducted to fully assess public safety impacts due to traffic and circulation as well as lighting and noise impacts on biological resources. The studies on lighting and noise impacts also need to be redone to evaluate the project under the proper standards. The DEIR should then be recirculated as a second draft for public comment.”

Within the DEIR, however, the department states that existing streetlights along 39th Avenue and Rivera Street are a “notable contributor to nighttime glare levels under baseline conditions. These 25-foot-tall streetlights are positioned closer to second-story residential windows and more directly in residents’ sightlines than the 90-foot-tall field lights and 65-foot-tall egress lights.

“Given the existing conditions, the potential for direct glare from neighborhood streetlights is already greater than that from the proposed field lighting, which is positioned well above eye level,” The DEIR report stated. “Since these streetlights are a permanent feature of the neighborhood’s nighttime environment, the limited threshold exceedances associated with the proposed lighting would not constitute a substantial additional source of glare or result in a significant adverse visual effect.”