HomeMy WebLinkAbout04-18-25 Public Comment - A. Moore - UDC Updates - 38.570From:Andy Moore
To:Bozeman Public Comment
Subject:[EXTERNAL]UDC Updates - 38.570
Date:Friday, April 18, 2025 10:19:12 AM
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Good morning,
As a lighting engineer & designer, educator, and mentor in the Gallatin valley for the last 15
years, the conflicting information, complexity, and lack of enforcement of the lightingelements in the UDC are something that needs drastic adjustment.
I do not believe the local jurisdiction should set minimum illuminance and uniformity
requirements within the UDC at all. Especially as the state gets closer to adopting IECC 2024,with more and more restrictions on exterior lighting power allowance (energy). It will likely
be impossible to adhere to both codes, and for good reason. The minimum requirements in theUDC are drastically outdated, and require more light than is necessary for our size &
population.
I think the 'Purpose' section of 38.570 could remain the same, while drastically simplifying therest of the language. I also believe that all of the illuminance tables could be removed, and the
city could indicate 'Refer to Illuminating Engineering Society Lighting Application StandardsCollection for illuminance and uniformity recommendations for all exterior areas and
surfaces.'
This would drastically reduce the liability the city is taking on by creating their ownilluminance guidelines from scratch. I do realize that a well established lighting design firm in
Boulder, CO was hired to do these a long time ago, but standards have been updated manytimes since then.
Graphic examples could be updated to clarify further what is required, in addition to the
specific submission requirements for lighting information. Depending on whether someonefrom the city is reviewing the planning submission, or a 3rd party contractor, you may have 0
or 20 comments on a lighting plan. Most of them do not line up with any requirements in thisUDC section. For instance, that calculation points need to be spaced at 'X' and legible.
I would be glad to rewrite a draft of section 38.570 based on the last 15 years of experience
here, at no cost to the city. I would also be glad to meet with those interested prior to workingon a draft.
Thanks,
Andy
PS - The Armory Hotel is still a horrible example of a developer getting away with non-compliance as it relates to 38.570, and unfortunately gets brought up a lot as a poor example
of enforcement in the design world because it sets a precedent for others.
Andy Moore
PE, IALD, CLD, MIES
Principal
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