Santa Monica City Council
December 16, 2025

Third Street Promenade and Santa Monica
Place Digital Display District
Lighting Study
Santa Monica, California
December 8, 2025
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 2

1. INTRODUCTION--------------------------------------------------------------------------------------------------------------------------------3

2. SUMMARY OF LIGHT TRESPASS AND GLARE------------------------------------------------------------------------------------------3

2.1 Light Trespass-------------------------------------------------------------------------------------------------------------------------------4

2.2 Glare -------------------------------------------------------------------------------------------------------------------------------------------4

3. PROJECT DESCRIPTION ----------------------------------------------------------------------------------------------------------------------5

4. REVIEW OF LIGHTING REGULATIONS AND REFERENCE STANDARDS----------------------------------------------------------7

4.1 Santa Monica Municipal Code----------------------------------------------------------------------------------------------------------7

4.2 California Code of Regulations, Title 24 (California Building Standards Code) --------------------------------------------8

4.3 California Vehicle Code, Division 11. Rules of the Road--------------------------------------------------------------------------9

4.4 IESNA Recommended Practices --------------------------------------------------------------------------------------------------------9

5. SIGNIFICANCE THRESHOLD--------------------------------------------------------------------------------------------------------------- 10

6. METHODOLOGY ----------------------------------------------------------------------------------------------------------------------------- 11

6.1 Existing Conditions Procedures------------------------------------------------------------------------------------------------------- 11

6.2 Analysis Method-------------------------------------------------------------------------------------------------------------------------- 17

7. Project Existing Conditions--------------------------------------------------------------------------------------------------------------- 21

7.1 Sign Visibility Analysis------------------------------------------------------------------------------------------------------------------- 21

7.2 Monitoring Site Night Survey Data -------------------------------------------------------------------------------------------------- 24

7.3 Monitoring Site Data-------------------------------------------------------------------------------------------------------------------- 28

8. LIGHTING ANALYSIS ------------------------------------------------------------------------------------------------------------------------ 59

8.1 Light Trespass Analysis ----------------------------------------------------------------------------------------------------------------- 59

8.2 Glare Analysis at Residential Properties ------------------------------------------------------------------------------------------- 76

8.3 Glare Analysis for Roadways, California Vehicle Code ------------------------------------------------------------------------- 78

9. CONCLUSIONS ------------------------------------------------------------------------------------------------------------------------------- 80

10. LIGHTING GLOSSARY----------------------------------------------------------------------------------------------------------------------- 81 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 3

1. INTRODUCTION
This Lighting Study (Study) was prepared by Francis Krahe & Associates Inc. for the City of Santa Monica, California to analyze the proposed Third Street Promenade and Santa Monica Place Digital Display District Ordinance’s potential lighting, glare, and driver distraction impacts to nearby sensitive uses. For a worst case (conservative analysis), the Study analyzes all proposed and potentially future illuminated signs that could be installed in the District.

The proposed Third Street Promenade and Santa Monica Place Digital Display District Ordinance (hereinafter, the Ordinance or the Project) is located in the highly urbanized Downtown area of Santa Monica– which is predominantly commercial in nature. The Project would allow for the potential for the installation of new digital displays within a proposed District (Project area) comprised of the Third Street Promenade and the Santa Monica Place Shopping Center.

The Third Street Promenade area is bound by Wilshire Boulevard on the north, Broadway on the south, Third Court on the east, and Second Court on the west. The Santa Monica Shopping Center is bound by Broadway on the north, Colorado Avenue on the south, Fourth Street on the east, and Second Street on the west.

Conservatively, this Study assumes buildout of up to 16 illuminated digital displays (Project Signs) wrapping the corners of the Third Street Promenade and on the facades of the Santa Monica Place Shopping Center, as illustrated in the Conceptual District Signage Buildout Plan attached herein as Appendix A.

This Study reviews the parameters that affect light trespass and glare (each as defined below), reviews the applicable lighting metrics and regulations pertaining to artificial lighting, examines the existing lighting conditions within and surrounding the Project Area, and evaluates future buildout of proposed and new illuminated signs within the Conceptual District Signage Buildout Plan to identify the Project’s potential lighting and glare environmental impacts on sensitive uses.

The methods of analysis utilized for this Study are based upon the recommended practices established by the Illuminating Engineering Society of North America (IESNA) for the practice of illumination engineering design and application, and the actual measurements of light sources and illuminated surfaces. IESNA reference publications include: American National Standards Institute (ANSI)/Illuminating Engineering Society (IES) OL-IM-01 Lighting Fundamentals, Metrics and Calculations; ANSI/IES OL-IM-02 Lighting Design, Engineering, and Specifications; ANSI/IES OL-IM-03 Lighting Design Criteria and Illumination Recommendations; and ANSI/IES OL-IM-04 Lighting Equipment Testing Procedures and Measurements. The ANSI/IES Standards replace the IESNA 10th Edition Handbook, which superseded the 9th Edition IESNA Handbook and various Recommended Practice (RP) References published by IESNA prior to 2011.

2. SUMMARY OF LIGHT TRESPASS AND GLARE
This Study evaluates potential environmental light, glare and driver distraction impacts from the Project due to the installation of illuminated digital signs identified within the Conceptual District Signage Buildout Plan (Appendix A). The Lighting Study evaluates existing lighting conditions in the Project area and analyzes light from proposed and future digital Project Signs that may affect existing sensitive uses.

For this Study, light effects from the potential full buildout of digital signage for the Project (worst case) is analyzed at existing sensitive use properties, with the Signs operating in all white mode at maximum permitted luminance.

However, the Signs will not normally operate in all white mode, therefore, this Study presents a conservative analysis of the potential for light trespass or glare impacts.

Sensitive use properties include residential uses. It should be noted that the Project Area is commercially zoned and is the City’s main economic activity center, and therefore, existing lighting levels experienced by residential uses are 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 4

higher than residential uses in residential zoned areas. Commercial use properties such as office buildings, restaurants, or retail stores are not considered sensitive use properties since these types of uses require higher illumination for their normal business operations. The illuminance from outdoor lighting such as the Project will be substantially less than the required illuminance of a commercial use property. Environmental impacts from the Project at sensitive use properties are evaluated with respect to light trespass and glare. These two technical terms are defined as follows:
• Light Trespass is the artificial light produced on a property that falls on a property. Light trespass is measured in terms of illuminance (foot-candles or metric units lux), and can be measured at any point and in any direction.

Where light trespass is evaluated, the illuminance is measured perpendicular to the source of light, toward the source of light, at the property line, or the location where light would cause an issue, such as a residential window or balcony. Light trespass is evaluated at night.
• Glare occurs when either the luminance is too high or the range of brightness in a visual field is too large. A bright light source, such as a flood light or streetlight, viewed against a dark sky may be uncomfortable to look at, and may create a temporary sensation of blindness, which is referred to as disability glare. Glare is evaluated by measuring the luminance (footlamberts or metric units candelas per square meter) at the source of light, such as a digital display, in comparison to the surrounding adjacent luminance. Contrast ratios define the extent of glare within the visual field at any observer position. The contrast ratio is determined by the variation of luminance within the field of view. “High,” “Medium,” and “Low” contrast ratios are the comparison of peak measured luminance to the average luminance within a visual field: contrast ratios greater than 30:1 are “High”; contract ratios between 30:1 to 10:1 are “Medium”; and contract ratios below 10:1 are “Low.” Contrast ratios greater than 30:1 is generally uncomfortable for the human eye to perceive. Glare is evaluated during the day and night.

2.1 Light Trespass
Regarding light trespass, this Study utilizes light trespass and glare regulations consistant with other regulations, such as the Los Angeles Municipal Code Section 14.4.4.e1 to provide a conservative analysis of the potential for the Project to create a new source of light trespass at the closest existing sensitive uses to the District. More distant residential uses will receive far less light from the Signs than the locations analyzed in detail in this Study due to the exponential reduction in light energy relative to distance.

This Study concludes that the Project will not create a new source of light trespass at sensitive uses outside and within the District. While there are a small number of sensitive residential uses located on the Third Street Promenade within the District, these residential uses are located on commercially zoned properties. The Project would limit light trespass on sensitive residential uses to no more than 3.0 footcandles which is consistant with the Los Angeles Municipal Code and other sign use districts such as the Los Angeles Sports & Entertainment District (LASED). Additionally, the residential uses on the Promenade that would experience the greatest lighting effects are part of the Project (i.e., the residential uses are located on sites that are also potential Project sign locations), and therefore, are not considered sensitive uses that would be significantly impacted by the Project.

2.2 Glare
This Study analyzes the Project’s potential to create glare (i.e., a new high contrast condition) visible at nearby residentially zoned properties or at adjacent roadways. This Study analyzes the contrast ratio, which compares the 1 Los Angeles Municipal Code Section 14.4.4(E): “No sign shall be arranged and illuminated in a manner that will produce a light intensity of greater than three foot candles above ambient lighting, as measured at the property line of the nearest residentially zoned property.”
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 5

maximum Project luminance to the existing average luminance measured at monitoring sites in proximity to the Project Site. The analysis determined that contrast ratio will be less than 30:1 at each of these sites. Contrast ratios less than 30:1 indicate there is no glare impact from the Project. Therefore, the Project will not create a new glare condition at adjacent sensitive use or residential properties.

The glare visible to drivers at roadways is evaluated with respect to the standards identified by the California Vehicle Code (CVC) § 21466.5, which defines maximum permissible luminance within drivers’ field of view during the day and during periods of low sun intensity such as overcast sky conditions, twilight, or at night. This Study confirms that the Project’s buildout would not exceed the maximum luminance defined by the CVC during the day, or during periods of low sun intensity such as overcast sky conditions, or twilight, or at night.

3. PROJECT DESCRIPTION
The Project would establish a new Digital Display District that would permit illuminated, large format digital signs at the following locations, subject to regulatory requirements:
• On corner buildings located on the Third Street Promenade with a maximum of 1 display wrapping the corner of each building
• On the facades of the Santa Monica Place Shopping Center with a maximum of 4 digital displays.

Based on these permitted locations, up to 16 potential displays could be located in the District.

The Project would limit maximum signage area to:
• The total sign area of a new digital display on a building shall not exceed 1,000 square feet.

Based on the permitted display locations (i.e., signs at every street corner of the Promenade as well as 4 signs at Santa Monica Place Shopping Center), up to 16 digital displays could be installed and operated in the District. For the purposes of this Study, the full buildout of the Project are analyzed for a worst case analysis, as illustrated in Figure 1.

The Ordinance contemplates a total of sixteen (16) signs, even though at the time of this writing, only seven digital signs have been formally proposed by applicants as listed below in the Conceptual District Signage Plan (Appendix A). • 395 Santa Monica Place - 4 digital displays
• 301 Arizona Ave – 1 digital display
• 1202 Third Street Promenade – 1 digital display
• 1310 3rd St Promenade – 1 digital display
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 6

Figure 1 indicates the location of the Sign District (shaded green), the locations of the proposed Signs (blue), and the locations of existing adjacent and nearby residentially zoned properties (red shade), and residential use properties within the commercial zones of the Bayside Conservation District and the Transit Adjacent District of the Santa Monica Downtown Community Plan (yellow shade).

The Project (Section 9.61.205(H) of the Ordinance) will require that new digital signs in the District adhere to the following illumination standards and include design features with respect to lighting:
• Sign light trespass illuminance must not exceed 3.0 footcandles (fc) at the property lines of nearby residential use properties within the District
• Signs will not exceed the daytime maximum luminance of 6,000 candelas per square meter (cd/m2 ) during the
day, from 45 minutes after sunrise until 45 minutes before sunset. • Signs will transition gradually over a period of no less than 45 minutes from off to the daytime luminance in the morning, and from daytime luminance to the evening luminance before sunset. • Signs will not exceed the evening maximum luminance of 300 candelas per square meter (cd/m2 ) during the
Figure 1: District, Sign Locations, Residential Properties 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 7

evening, from sunset until 10:00 pm.
• Signs will not exceed the nighttime maximum luminance of 200 candelas per square meter (cd/m2 ) at night
from 10:00 pm until 1:00 am.
• Signs will include photosensor controls that automatically adjusts the Sign luminance to less than 300 cd/m2 when ambient sun light conditions are less than 100 footcandles. • Signs will be off, from 1:00 am until sunrise.
• Signs will be controlled with a dimmer that provides the ability to automatically reduce power by a minimum of 65 percent.
• Signs will be designed and operated with systems and monitoring in place to either turn the display off or show-full black screen in the event of a malfunction.
• Signs will not simulate or imitate any directional, warning, danger, or information sign, or any other display likely to be mistaken for any permitted sign intended or likely to be construed as giving warning or direction to traffic, for example using such words or phrases as "stop" or "slow down." • Signs will not display any red or blinking or intermittent lighting that may be mistaken for warning or danger signals nor shall the displays' illumination impair the vision of drivers on the adjacent roadways. • Each static image displayed on a digital display shall not be refreshed more often than once every 8 seconds. • Each image displayed on a digital display (i.e., each individual advertisement or artwork) shall fade in from the previous image over no less than one (1) second, and shall fade out over no less than one (1) second to the image of the immediately succeeding content
• Signs will not use stroboscopic of flashing images which rapidly change direction, oscillate, flash or reverse in contrast.
• Signs must be light emitting diodes (LEDs) that have a power supply efficiency of 80 percent or greater. • A photometric report prepared by a lighting professional shall be submitted to the Director upon installation prior to issuance of a certificate of occupancy or commercial operation of the display, and at two-year intervals thereafter to confirm conformance with the lighting requirements above.

4. REVIEW OF LIGHTING REGULATIONS AND REFERENCE STANDARDS Exterior lighting is regulated throughout California by local municipal codes and the California energy and building codes. Pertinent lighting sections are summarized and discussed for the City of Santa Monica Municipal Code (SMMC), the California Vehicle Code, the California Green Building Standards Code (CalGreen), and the California Energy Code (CEC). Reference standards include model lighting ordinances provided by the Illuminating Engineering Society of North America (IESNA) and the International Dark Sky Organization. Various aspects of these reference standards are included in local regulations to improve the outcomes of any approved project and avoid future disputes or legal challenges to proposed lighted signs. The lighting standards summarized below balance the requirements of property owners for sufficient brightness and flexibility for the use of the signs, with minimizing the off-site negative effects of light trespass,glare, and safety.

4.1 Santa Monica Municipal Code
The SMMC regulates signs within Chapter 9 PLANNING AND ZONING. The SMMC exempts Sign Lighting from the requirements in Section 9.21.080 Lighting, and is silent with respect to light trespass from signs (i.e., the spillover of light onto light-sensitive properties located in proximity).

9.21.080 Lighting
A. Applicability. The standards of this Section shall apply to the following:
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 8

1. New Lighting. All new exterior lighting, including lighting fixtures attached to buildings, structures, poles, or selfsupporting structures. Exterior lighting may be found on parking lots, walkways, building entrances, outdoor sales areas, landscaping, recreational fields, and building faces….

B. Exemptions. The following specific types of lighting are exempt from the requirements of this Section:….

4. Sign lighting (See Chapter 9.61, Signs).

Section 9.61.200 of the SMMC regulates smaller scale, animated signage on the Third Street Promenade, per the below standards:

F. Animated signs permitted pursuant to this Section are allowed on the following conditions:

1. Sign must be located only on a façade facing the Third Street Promenade.

2. Maximum allowable sign area shall be the area above the storefront up to 5'0" in height for the width of the tenant space. The sign may be placed anywhere on the building façade so long as the sign does not project above the roofline and the maximum allowable sign area is not exceeded.

3. Signs may not cover windows.

4. Sign lighting shall not be of an intensity or brightness that will create a nuisance for properties in direct line of sight to the sign. Illumination is limited to 0.3 foot candles above ambient lighting at the property line, and a maximum brightness of 300 candelas per square meter at night (from sunset to sunrise), and 5,000 candelas per square meter during the day (sunrise to sunset).

5. Signs must be dimmable.

6. The sign luminance contrast ratio shall not exceed 30:1.

7. The City may require a sign illumination plan in accordance with any adopted administrative regulations pursuant to this Section as part of the application process to demonstrate compliance with all applicable standards.

8. Animated sign faces shall operate only between the hours of 6:00 a.m. and 2:00 a.m., and shall be turned off between the hours of 2:00 a.m. and 6:00 a.m.

9. Signs are not eligible for a sign adjustment under Section 9.61.130.

The SMMC regulations referenced above do not regulate or permit the larger format, digital signs that are being proposed by the Project. As such, this Study does not rely on existing Section 9.61.200 of the SMMC for analyzing impacts to sensitive uses. Rather, this Study analyzes the potential for the Project Signs to create signifcant adverse light trespass and glare impacts at sensitive use properties based on the maximum light trespass and glare standards established by the Project (District Ordinance).

4.2 California Code of Regulations, Title 24 (California Building Standards Code) Title 24 of the California Code of Regulations (CCR), also known as the California Building Standards Code, includes the California Building Code, CALGreen and the CEC, among others. CALGreen Section 5.106.8 and CEC Section 140.7 limit light trespass and glare at any building property line or center line of adjacent transportation right of way according to 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 9

the outdoor lighting zones established by the CEC. However, the CEC provides exceptions for signs that comply with the energy use and lighting controls requirements within CEC Sections 130.3 and 140.8.

The Project would require new digital signs to include energy use and lighting control systems that comply with CEC Sections 130.3 and 140.8(b) and that are included as Project Design Features within this Study. Specfically, Project Signs will comply with the following requirements:
• Project Signs will be controlled with a photocontrol in addition to an automatic time-switch control, or an astronomical time-switch control.
• Project Signs when illuminated at night and for more than 1 hour during daylight hours will be controlled with a dimmer that provides the ability to automatically reduce Project Sign power by a minimum of 65 percent during nighttime hours.
• Project Sign light emitting diodes (LEDs) must have a power supply efficiency of 80 percent or greater.

Each of the above performance requirements are satisfied by the electronic control system which is included as a proposed Project Design Feature in the Conceptual Sign Plan. Therefore, the Project will satisfy the exceptions to CEC Section 140.7(a). Accordingly, Project Signs are not subject to the light trespass and glare requirement of CALGreen Section 5.106.8.

4.3 California Vehicle Code, Division 11. Rules of the Road Chapter 2, Article 3 of the California Vehicle Code (CVC) Division 11 Rules of the Road stipulates limits to the location of light sources that may cause glare and impair the vision of drivers. CVC Section 21466.5. provides in relevant part:
“No person shall place or maintain or display, upon or in view of any highway, any light of any color of such brilliance as to impair the vision of drivers upon the highway. A light source shall be considered vision impairing when its brilliance exceeds the values listed below.

The brightness reading of an objectionable light source shall be measured with a 11/2-degree photoelectric brightness meter placed at the driver’s point of view. The maximum measured brightness of the light source within 10 degrees from the driver’s normal line of sight shall not be more than 1,000 times the minimum measured brightness in the driver’s field of view, except that when the minimum measured brightness in the field of view is 10 foot-lamberts or less, the measured brightness of the light source in foot-lambert shall not exceed 500 plus 100 times the angle, in degrees, between the driver’s line of sight and the light source.” This Study analyzes the standard set forth in CVC Section 21466.5 as it applies to Project Signs on drivers within adjacent streets.

4.4 IESNA Recommended Practices
The Illuminating Engineering Society of North America (IESNA) recommends illumination standards for a wide range of building and development types. These recommendations are widely recognized and accepted as best practices and are therefore a consistent predictor of the type and direction of illumination for any given building type. For all areas not governed by the regulatory building code, municipal code or specifically defined requirements, the IESNA standards are used as the basis for establishing the amount and direction of outdoor building lighting recommended for the Project.
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 10

The IESNA Standards define Outdoor Lighting Zones relative to a range of human activity versus natural habitat. LP-11- 20, Environmental Considerations for Outdoor Lighting pages 10 &11, included in Appendix C of this Study, establishes the Zone designation for a range of existing lighting conditions, from low or no existing lighting to high light levels in urban areas. These lighting zone definitions are referenced by the CEC as noted above in relation to allowable energy use for outdoor lighting. In addition, the IESNA standards define recommended light trespass limits in RP-8-22 Table 4- 2, included in Appendix D hereto, relative to the Outdoor Lighting Zones. The recommended light trespass illuminance limits define the maximum light trespass values in Lux and footcandles at the location where trespass is under review.

The IESNA recommendations listed above are not a regulatory requirement, do not address sign illuminance, and are overriden by the applicable Sign District requirements for light trespass.

5. SIGNIFICANCE THRESHOLD
Appendix G of the California Environmental Quality Act (CEQA) Guidelines (14 California Code of Regulations, Sections 15000–15387) provides a set of sample questions to evaluate impacts with regard to aesthetics, including light and glare. For the purposes of this Study, the City of Santa Monica provides an analysis of impacts based on the CEQA Guidelines Appendix G “questions”. The question that pertains to light trespass and glare is as follows:

Would the project create a new source of substantial light and glare which would adversely affect day or nighttime views in the area?
In the context of this question from the CEQA Guidelines, the determination of significance in this Study takes into account the following factors:
• The change in ambient nighttime levels as a result of Project lighting sources; and • The extent to which light from the Project would spill off the Project Site and affect nearby residentially zoned properties.

Specifically, the Project Sign would create a significant impact with regard to artificial light or glare if:
• Light trespass illuminance from the Project exceeds 3.0 fc at nearby residential use properties within the District and therefore adversely changes the ambient light level. • Light trespass illuminance from the Project exceeds 1.4 fc at residential use properties outside the District , and therefore adversely changes the ambient light level. • Or, the Project creates glare with new high contrast conditions, with contrast ratio greater than 30:1, visible from a field of view from a residential use property.
• Or, the Project Sign creates glare effects on drivers of motor vehicles by exceeding the maximum luminance standards established by Section 21466.5 of the California Vehicle Code, where maximum brightness of the Project Sign within 10 degrees from the driver’s normal field of view is greater than 1,000 times the minimum measured brightness in the driver’s field of view, or when the minimum measured brightness in the field of view is 10 footlamberts or less, the measured brightness of the light source in footlambert exceeds 500 plus 100 times the angle, in degrees, between the driver’s field of view and the light source.2 2 The driver’s field of view from the center of the roadway plus 10 degrees. 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 11

6. METHODOLOGY

6.1 Existing Conditions Procedures
Existing lighting conditions are measured and documented at existing nearby properties (which include existing sensitive residential use properties), and this survey data is presented below in Section 7, Existing Conditions. The locations where the existing lighting is measured are identified as the Monitoring Sites illustrated in Figure 3 below.

Light trespass illuminance and Glare from the Signs are evaluated at the Monitoring Sites listed above, located at the existing nearby sensitive use properties
Existing conditions lighting observations were conducted following recommended practice procedures defined by the IESNA in RP-33-00 Lighting for Outdoor Environments, TM-10-00 Addressing Obtrusive Light (Urban Sky Glow and Light trespass) in Conjunction with Roadway Lighting,
and TM-11-00 Light trespass: Research, Results
and Recommendations. Field illuminance and
luminance measurements were conducted to
accurately document all existing incident and
visible light at each Monitoring Site location.

Incident light can be understood as a vector of
luminous flux moving through space. As the
vector (light) is incident upon a surface, the
intensity of the resulting illuminance will vary
depending upon the relative orientation of the
vector to the surface. The greatest illuminance
will result when the surface and vector are
perpendicular. The least illuminance will result
when the surface and vector are parallel. In the
field conditions, where there are multiple
sources of light originating from varied positions,
illuminance measurements are recorded
horizontally with the photosensor facing up at 3 feet above grade, and vertically with the photosensor facing the Project as per IESNA standards. These measurements document the total horizontal illuminance received at a Monitoring Site as well as the direction and intensity of light converging on the Monitoring Site from the direction of the Project Site. Since most of the surrounding sensitive sites are located at distances from the Project Site greater than 90 feet, as noted in Section 7 below, the vertical illuminance represents a plane perpendicular to the light sources.

Under these conditions, there is little difference between the vertical and perpendicular plane, and the vertical plane analysis that is conducted in this Study would be equal to or greater than the measured luminance from a precisely perpendicular plane analysis. Therefore, this Study utilizes a vertical illuminance analysis. The existing Illuminance is measured with a Minolta Illuminance meter.

The existing luminance is measured from a Monitoring Site to light sources and surfaces within the field of view toward the Project Site from that Monitoring Site. This existing conditions luminance data is measured with a Minolta LS-100 Luminance meter with procedures consistent with best practices for field measurement of luminance as per IESNA standards. The LS-100 Luminance meter utilized by Francis Krahe & Associates, Inc. reports luminance data in either candelas per square meter (cd/m2
) or footlamberts (fL). All existing luminance data measured and reported in this Study are recorded as cd/m2
.

Figure 2: Minolta LS-100 meter
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 12

a. Existing Conditions Monitoring Sites
Monitoring Sites are utilized to describe and evaluate the existing lighting conditions at and surrounding the Project Area to determine the maximum potential impacts that may result from light or glare onto the nearest existing sensitive use properties. All Monitoring Site locations are within the District or located in proximity of the District and would have views of the Project Sign(s). Several Monitoring Sites are also potential future Project Sign locations.

Monitoring Sites are located within the public right of way at existing residential use properties or are directly adjacent to existing residential properties.

The following criteria were used to select the Monitoring Sites:

Project Light Visibility – Monitoring Sites were analyzed that provide direct view of the Signs or direct view of the areas of greatest light intensity from the Project.

Proximity – Monitoring Sites that are closest to the proposed and future Project Sign(s) are analyzed. These locations are selected because light intensity decreases exponentially with distance. Locations at a greater distance will experience less light intensity than nearby locations.

Monitoring Sites were selected for observation and field lighting measurements to evaluate the views to the Project from adjacent properties and to determine the extent and intensity of existing light sources within and surrounding the District. The Monitoring Sites are measured from within the public right of way, adjacent to or in proximity of existing residential uses. The Monitoring Sites are representative of the view to the Project Sign(s) from nearby properties surrounding the Project to the south, east, north, and west. Figure 4 shows the Project Area, the Monitoring Sites, and the properties surrounding the Project.
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 13

Monitoring Site M-E01 This site is located at 1201 3rd Street, the southeast corner of 3rd St. Promenade and Wilshire Ave. This site evaluates potential impacts from the proposed sign to the west at M-W04. This monitoring site location is also a potential future sign location under the Project.

Monitoring Site M-E02: This site is located at 301 Arizona St, northeast corner of 3rd St. Promenade and Arizona Avenue. This site evaluates potential impacts from the 3 proposed signs at the northwest (MW05), southwest (M-W06), and southeast (M-E03) corners of 3rd St. Promenade and Arizona Ave. This site is also a proposed sign location.

Monitoring Site M-E03: This site is located at 1311 3rd St. Promenade/301 Arizona Avenue (Victoria Secret/Criterion Promenade Apartments), southeast corner of the 3rd St. Promenade and Arizona Avenue.

Figure 3: Sign District, Resident Properties, Monitoring Site Locations 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 14

This site evaluates potential impacts of the 3 proposed signs at the northwest (M-W05), southwest (M-W06), and northeast (M-E02). This monitoring site is a mixed-use property, with ground level commercial and upper second and third level residential uses. This site is also a potential future sign location within the Project.

Monitoring Site M-E04: This site is located at 301 Santa Monica Blvd, the northeast corner of 3rd St. and Santa Monica Blvd. This site evaluates potential impacts of the 3 proposed signs at the northwest (M-W07), southwest (M-W08), and southeast (M-E05) corners of 3rd St. Promenade and Santa Monica Blvd. This site is also a proposed sign location.

Monitoring Site M-E05 This site is located at 1401 3rd St. Promenade, southeast corner of 3rd St. and Santa Monica Blvd. This site evaluates potential impacts of the 3 proposed signs at the northwest (M-W07), southwest (M-W08), and northeast (M-E04) corners of 3rd St. Promenade and Santa Monica Blvd. This site is also a proposed sign location.

Monitoring Site M-E06: This site is located at 1453 3rd St. Promenade (Promenade Gateway), northeast corner of 3rd St. and Broadway. This site evaluates potential lighting impacts of the proposed sign at the northwest corner (M-W09) of 3rd and Broadway and the proposed sign to the south at the Santa Monica Place Shopping Center. This Monitoring Site is a mixed-use property, with ground level commercial and upper second and third level residential uses that are stepped back. This site is a potential future sign location under the Project Monitoring Site M-E07: This site is located at 401 4th St. and is northwest of the proposed sign location at the southwest corner of 4th Street and Broadway at Santa Monica Place shopping center. This site evaluates the potential impacts of the proposed sign on the residential uses at this monitoring site.

Monitoring Site M-E08: This site is located at the southeast corner of 4th and Broadway, and is directly east of the proposed sign location at the southwest corner of 4th and Boadway at Santa Monica Place shopping center. This site evaluates the potential impacts of the proposed sign on the commercial uses located at this monitoring site.

Monitoring Site M-E09: This site is located at 1539 4th St. (Arrive Apartments), and is southeast of the proposed sign location at the southwest corner of 4th Street and Broadway and northeast of the proposed sign location at the southern Colorado Avenue façade at the Santa Monica Place shopping center. This site evaluates the potential impacts of the two proposed signs at Santa Monica Place on residential uses located at this monitoring site.

Monitoring Site M-E10: This site is located at 425 Broadway and is approximately 270 feet northwest of the proposed sign location at the southwest corner of 4th Street and Broadway at the Santa Monica Place shopping center. This site evaluates potential lighting impacts of the proposed sign on residential uses located at this monitoring site.

Monitoring Site M-E11: This site is located behind 1530 5th St. (Salvation Army Residence) and is southeast of the proposed sign location at the southwest corner of 4th Street and Broadway at the Santa Monica Place shopping center. This site evaluates potential impacts of the proposed sign on the residential uses at this site.
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 15

Monitoring Site M-E12: This site is located at 502 Colorado and is approximately 517 feet east of the proposed sign location at the corner of 4th St, and Colorado Ave at Santa Monica Place shopping center. This site evaluates the potential impacts of the proposed sign on the residential uses at this site.

Monitoring Site M-N01: This site is located at the northwest corner of the surface parking lot at 101 Wilshire Blvd. (Fairmont Miramar Hotel and Bungalows) northwest of the proposed sign locations at 1202 3rd St. Promenade (John Reed Fitness) and at 1201 3rd St. Promenade. This site evaluates the potential impacts of the two proposed signs on nearby residentially zoned properties to the northwest.

Monitoring Site M-N02: This site is located at 1111 2nd Court, northeast corner of the (Huntley Hotel). This site is northwest of the proposed sign locations at 1202 3rd St. Promenade (John Reed Fitness) and at 1201 3rd St. Promenade. This site evaluates the potential impacts of the two proposed signs on nearby residentially zoned properties to the northwest.

Monitoring Site M-N03: This site is located at the southeast corner of 1118 3rd St. and is north of the proposed sign locations at 1202 3rd St. Promenade (John Reed Fitness) and at 1201 3rd St. Promenade. This site evaluates the potential impacts of the two proposed signs on nearby residentially zoned properties to the north.

Monitoring Site M-N04: This site is located at 1148 4th street, and is north of the proposed sign locations at 1202 3rd St. Promenade (John Reed Fitness) and at 1201 3rd St. Promenade. This site evaluates the potential impacts of the two proposed signs on nearby residential properties to the northeast.

Monitoring Site M-W01: This site is located behind 1221 Ocean Ave, west of the proposed sign locations at 1202 3rd St. Promenade (John Reed Fitness) and at 1201 3rd St. Promenade. This site evaluates the potential impacts of the Project on nearby residential properties to the southwest.

Monitoring Site M-W02: This site is located at 1318 2nd St, southwest of the proposed sign locations at 3rd Street Promenade and Arizona Avenue. This site evaluates the potential impacts of the Project on nearby residential properties to the southwest.

Monitoring Site M-W03: This site is located behind 1431 Ocean Ave, west of the proposed sign locations at the corner of 3rd St. Promenade and Broadway. This site evaluates the potential impacts of the Project on nearby residential properties to the west.

Monitoring Site M-W04: This site is located at 1202 3rd St. Promenade, northwest corner of 3rd St. Promenade and Wilshire Blvd. This site evaluates potential impacts from the proposed sign to the east at ME-01. This site is a proposed sign location.

Monitoring Site M-W05: This site is located at 231 Arizona Ave (Gyu-Kaku), northwest corner of 3rd St. and Arizona Avenue. This site evaluates the potential impacts of the proposed signs at the northeast (ME02), southwest (M-W06), and southeast (M-E03) corners of 3rd St. Promenade and Arizona Ave,. This site is also a proposed sign location.
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 16

Monitoring Site M-W06: This site is located at 1310 3rd Street Promenade (AMC Theater), southwest of 3rd St.

Promenade and Arizona Avenue. This site evaluates potential impacts of the proposed signs at the northeast (M-E02), northwest (M-W05), and southeast (M-E03) corners of 3rd St.

Promenade and Arizona Ave. This site is also a proposed sign location.

Monitoring Site M-W07: This site is located at 1352 3rd St Promenade, the northwest corner of 3rd St. Promenade and Santa Monica. This site evaluates potential impacts of the proposed signs at the southeast (M-E05), southwest (M-W08), and northeast (M-E04) corners of 3rd St. Promenade and Santa Monica Blvd, to evaluate the other 3 corner elevations from nearby properties directly northwest of the proposed sign locations. This site is also a proposed sign location.

Monitoring Site M-W08: This site is located at 1402 3rd St. Promenade, the southwest corner of 3rd St. Promenade and Santa Monica. This site evaluates the potential impacts of the proposed signs at the southeast (M-E05), northwest (M-W07), and northeast (M-E04) corners of 3rd St. Promenade and Santa Monica Blvd. This site is also a proposed sign location.

Monitoring Site M-W09: This site is located at 1460 3rd St. Promenade (Google Store), northwest corner of the 3rd St Promenade and Broadway. This site evaluates potential impacts of the proposed sign at the 1453 3rd Street and the proposed north-facing sign at 3rd St and Broadway at the Santa Monica Place shopping center. This site is a proposed sign location.

Monitoring Site M-S01: This site is located at 1705 Olympic Dr, southwest of the proposed sign at the corner of 4th St. and Colorado Ave at the Santa Monica Place shopping center. This site evaluates potential impacts on nearby residential properties to the south of the proposed sign location.

Monitoring Site M-S02: This site is located at the southwest corner of 4th St. and Colorado Ave. This site evaluates potential impacts of the proposed south-facing sign at the Santa Monica Place shopping center on nearby commercial properties directly to the south of the proposed sign location. b. Monitoring Criteria
The table below identifies the criteria, metric, and procedure used to assess the existing conditions at each Monitoring Site:

Table 1. Existing Conditions Lighting Criteria
Criteria Metric Procedure
Light Trespass -
Illuminance
Measured illuminance
(footcandle) documented at
each Monitoring Site
Measured illuminance recorded at each Monitoring Site
with Minolta illuminance meter.
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 17

Criteria Metric Procedure
Glare –
Contrast Ratio
Measured luminance candelas
per meter squared,
documented at each
Monitoring Site.

Observed existing conditions
Measured luminance recorded at each Monitoring Site
with Minolta luminance meter.

Day and night photograph to record the evaluation of the view to the Project Site from the Monitoring Site in terms of Project visibility and prominent light sources, lighted surfaces, and illuminated signs.

6.2 Analysis Method
This analysis evaluates potential light trespass impacts at the nearest existing sensitive uses to the Project Area, and an evaluation of whether future Signs would introduce a new source of glare at sensitive use properties or at adjacent roadway. Sensitive use properties include residential uses. It should be noted that the Project Area is commercially zoned and is the City’s main economic activity center, and therefore, existing lighting levels experienced by residential uses are higher as compared to a residential use in a residential zoned area. Commercial use properties such as office buildings restaurants, or retail stores are not considered sensitive use properties due to the relatively high illuminance required for the operation of a businesses at night. The illuminance from outdoor lighting such as the Project will be substantially less than the required illuminance of a commercial use property. This Study presents a conservative analysis with respect to potential light trespass and glare impacts as described below. The Project is evaluated with each Project Sign operating at the maximum permissible light intensity within the limits defined by the Project as discussed in Section 1.2 above. This Study evaluates the proposed Signs with buildout of up to 16 signs, as identified in the Conceptual Sign Plan in Appendix A.
a. Light Trespass Analysis
Light trespass illuminance is calculated at the location where lighting is under review through the illumination modeling software program AGI32. This software utilizes the 3-dimensional architectural computer model, including the Sign locations, orientation, dimensions, and luminous specifications (as defined herein within Appendix A) to generate an accurate prediction of future illuminance from the Sign at nearby existing sensitive use properties. Light trespass illuminance is evaluated with respect to vertical illuminance at the locations where lighting is under review.

Light trespass is the artificial light produced from the Project that falls on a nearby property. Light trespass is measured in terms of illuminance (footcandles or metric units lux), and can be measured at any point and in any direction.

Where light trespass is evaluated, the illuminance is measured perpendicular to the source of light, toward the source of light, at the property line, or the location where light would cause an issue, such as a residential window or balcony.

Light trespass illuminance from the Project is evaluated in this Study relative to a maximum illuminance threshold of

3.0 fc at existing residential uses within the District. The 3.0 fc corresponds to the maximum permitted illuminance from signs by the City of Los Angeles Municipal Code, and is appropriate given that the Project Area is an urban downtown, is predominantly commercial in nature, and is a designated nighttime entertainment district. The lighting within District is anticipated to function in a manner similar to the Los Angeles Sports and Entertainment District which supports night time activity. Light trespass illuminance at existing residential uses outside of the District is evaluated against a maximum 1.4 fc – a threshold that takes into account residential uses that are interspersed amongst predominantly commercial uses.

Light trespass is analyzed by calculations of the illuminance (footcandles (fc)) from the Project at the potential sensitive use locations illustrated in Figure 4. The calculations simulate light meters at a vertical surface at the property line of the sensitive use properties, extending from above the height of ground floor commercial use spaces (approximately 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 18

15 feet above grade) to the height of the Signs, or to the maximum elevation of the occupied areas within any adjecent residential use properties, whichever is greater. The vertical planes are used to capture the lighting effects that new Project Signs may have on nearby residential use properties. The properties within and adjacent to the District include residential occupancy at various elevations above grade. Figure 4 illustrates the vertical plane locations where light trespass is analyzed. Table 2 summarizes the height of each vertical plane used in the calculations of light trespass illuminance.

The Signs analyzed are as defined in and as illustrated in the Conceptual Sign Plan (Appendix A). The Signs are analyzed operating at maximum luminance of 300 cd/m2 and 200 cd/m2 , all white during the evening hours and nighttime hours, respectively. The Signs will not operate in an all white mode in practice. However, this analysis with the Signs operating in all white mode presents a conservative (maximum) evaluation of the Project’s potential for offsite light trespass illuminance. These methods are utilized to generate the Sign light trespass illuminance data summarized in Tables 7, 8, 9 and 10 below at the vertical plane locations illustrated in Figure 5 below.

Table 2. Vertical Calculation Plane Heights
Table 3. Vertical Calculation Plane Heights
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 19

Table 2. Vertical Calculation Plane Heights
Vertical
Plane
Height
(ft)
Vertical
Plane
Height
(ft)
Vertical
Plane
Height
(ft)
VP-E1 60 VP-W1 60 VP-S1 75
VP-E2 60 VP-W2 60 VP-S2 75
VP-E3 45 VP-W3 45 VP-S3 75
VP-E4 45 VP-W4 45 VP-N1 75
VP-E5 45 VP-W5 45 VP-N2 75
VP-E6 45 VP-W6 45 VP-N3 75
VP-E7 55 VP-W7 55 VP-N4 60
VP-E8 55 VP-W8 55 VP-N5 60
Figure 4: District, Residential Properties, and Calculation Planes 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 20

VP-E9 55 VP-W9 55
VP-E10 55 VP-W10 55
VP-E11 75 VP-W11 75
VP-E12 75 VP-W12 75
VP-E13 55 VP-W13 220
VP-E14 55 VP-W14 220
VP-E15 75 VP-W15 50
VP-E16 75 VP-W16 50
VP-E17 75 VP-W17 30
VP-E18 75 VP-W18 30
VP-W19 220
VP-W20 220
Signs are further analyzed to determine the distance where the illuminance from the Sign is 0.3 fc or less, or less than 10% of the maximum illuminance permitted for Signs within the District at 3.0 fc. Incident light (fc) from a source degrades in proportion to the inverse square of the distance from the source to the location where lighting is analyzed, which in this Study is at residential use properties. The vertical illuminance Ev (fc) incident at any given distance D (ft) from an illuminated surface S (ft2
) with uniform surface luminance of L (cd/m2) is calculated by the following formula:

Ev = L x S

10.76 x D2
This formula illustrates the reduction in illuminance at any location as the distance increases from a source surface. The Project Signs are identified in Appendix A, based on the Project Sign Plan. The largest signs produce the greatest distance from the Project where the illuminance will be equal to or greater than 0.3 footcandles.

The distance from the Project Sign to the location where the Sign Illuminance equals 0.3 footcandles is calculated utilizing the formula above and solving for D.

Signs Distance (D ) to Ev = 0.3 fc,
D = 𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠 𝑟𝑟𝑟𝑟𝑟𝑟 (𝐿𝐿 𝑥𝑥 𝑆𝑆)

10.76 𝑥𝑥 𝐸𝐸𝐸𝐸
b. Glare Analysis
Glare from the Project is evaluated during the evening and at night at nearby sensitive use properties and for drivers on adjacent streets. The glare from the Project is determined by the contrast ratio, which equals the maximum Sign luminance divided by the measured average existing luminance within the visual field at the Monitoring Sites to the Project as identified in the field survey of existing conditions (see Section 8 below). Contrast ratios greater than 30:1 are considered “High” and significant glare conditions.

Light from the Project that may impact drivers is analyzed with respect to compliance with the CVC regulations for both night and day conditions at adjacent roadways. According to CVC Section 21466.5, the Project Sign would have a significant impact with regard to artificial light or glare if:
• The maximum measured brightness of a light source within 10 degrees from a driver’s normal line of sight exceeds 1,000 times the minimum measured brightness in the driver’s field of view when the minimum values in the field of view are 10 footlamberts (fL) or more.
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 21

• Or, when the minimum luminance in the driver’s field of view is less than 10 footlamberts (fL) the source brightness exceeds 500 fL plus 100 times the angle, in degrees, between the driver’s line of sight and the light source.

The analysis of glare impacts includes evaluation of all view angles from the driver’s line of sight to the Sign, to determine the visibility of the Sign, and an assessment of the maximum luminance permitted by the CVC at any angle of view.

7. PROJECT EXISTING CONDITIONS
The existing lighting conditions within the Project Area are defined by the observed and measured existing conditions summarized below. The Existing Conditions Analysis includes an evaluation of the visibility of Project Sign(s) from each Monitoring Site, with photographs of the view from the Monitoring Sites to the Project Sign(s) during the day and at night. Existing illuminance at each Monitoring Site is measured with the illuminance meter aimed toward the Sign(s). Existing luminance is measured within the field of view from the Monitoring Site to the Project Sign(s).

7.1 Sign Visibility Analysis
The visibility of the Project Signs at each Monitoring Site is evaluated during field surveys during the day and at night.

Field survey visibility data is presented in Table 3, which summarizes the distance from the Monitoring Site to the nearest Project Sign(s), and the visibility of the Sign(s) within the viewshed looking from the Monitoring Site toward the Sign locations.

All Monitoring Sites are located within the District or at residential use properties surrounding the District. Monitoring Sites M-E01, M-E02, M-E03, M-E04, M-E05, M-E06, M-E07, M-E08, M-W04, M-W05, M-W06, M-W07, M-W08, M-W09, and M-S02 will have full direct view of one or more nearby Project Signs. Monitoring Sites M-E09, M-E10, M-E11, ME12, M-W01, M-W02, M-N03, M-N04 and M-S01 will have partial or oblique views of one nearby Sign. Monitoring Sites M-N01, M-N02, and M-W03 will have no views of the Signs. Further analysis is presented below to evaluate the Sign potential for light trespass and glare at these Monitoring sites, which are adjacent to the Project or have clear visibility of Project Signs.

Table 4. Visibility Analysis
Monitoring
Site Location
Distance to
Proposed Sign
(ft) Visibility from Monitoring Site
M-E01 1201 3rd St.

Promenade 84 proposed sign at the southwest corner will be in full view from the Monitoring Site.

M-E02
1253 3rd St.

Promenade 89, 84, 104 proposed signs for the northwest, southwest, and southeast corner locations will be in full view from the Monitoring Site.

M-E03
southeast
corner of 1311
3rd St.

Promenade
89, 84, 104 proposed signs for the northeast, southwest, and northwest corner locations will be in full view from the Monitoring Site. 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 22

Monitoring
Site Location
Distance to
Proposed Sign
(ft) Visibility from Monitoring Site
M-E04
301 Santa
Monica Blvd,
northeast
corner of 3rd
St. / Santa
Monica Blvd
66, 107, 80 proposed signs for the northwest, southwest, and southeast corner locations will be in full view from the Monitoring Site.

M-E05
1401 3rd St.

Promenade 66, 107, 80 proposed signs for the northeast, southwest, and northwest corner locations will be in full view from the Monitoring Site.

M-E06
1453 3rd St.

Promenade 84 proposed signs for the northwest corner location will be in full view from the Monitoring Site.

M-E07 401 4th St. 114 proposed signs for the southwest corner location will be in full view from the Monitoring Site.

M-E08
southeast
corner of 4th
St / Broadway
79 proposed signs for the southwest corner location will be in full view from the Monitoring Site.

M-E09 1539 4th St 400
proposed signs for the southwest corner of 4th St. and
Broadway location will have a very limited view from the Monitoring Site.

M-E10 425 Broadway 270 proposed signs for the southwest corner location will be partially visible from the Monitoring Site.

M-E11 1530 5th St. 390
proposed signs for the southwest corner of 4th St. and
Broadway location will have a very limited view from the Monitoring Site.

M-E12 502 Colorado 517
proposed signs for the southwest corner of 4th St. and
Colorado location will have a very limited view from the Monitoring Site.

M-N01
northwest
corner of 101
Wilshire Blvd.
461
proposed sign for the northwest location is not visible from the Monitoring Site. Residential properties are to the
Northwest of the site but have no view of this sign.

M-N02 1111 2nd Court 517
proposed sign for the northwest location is not visible from the Monitoring Site. Residential properties to the northwest have no view of the sign as the multi-story office building at the southeast corner of Wilshire and 3rd street block the view of the sign.
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 23

Monitoring
Site Location
Distance to
Proposed Sign
(ft) Visibility from Monitoring Site
M-N03 1118 3rd St. 349
proposed sign on the northwest location has limited visibility from the Monitoring Site. Residential properties to the north have no view of the sign as the multi-story office building at the southeast corner of Wilshire and 3rd street blocks the view of the sign.

M-N04 1148 4th street 378,305
proposed sign for the southeast, northwest corner location has a limited partial view from the Monitoring Site.

Residential properties in the adjacent vicinity have a limited view of the proposed sign.

M-W01
1221 Ocean
Ave
616
proposed sign for the southwest corner location at 3rd St.

Promenade and Wilshire Ave, will not be visible from the Monitoring Site. The sign location at the southeast corner of 3rd and Wilshire will be partially visible from apartments on upper floors at the Monitoring site.

M-W02 1318 2nd St 451
proposed sign for the northwest corner wall location at 3rd St.

Promenade and Arizona will be in partially visible from apartments on upper floors at the Monitoring Site.

M-W03
1431 Ocean
Ave
608
proposed sign for the southwest corner location 3rd St.

Promenade and Broadway will not be visible from the
Monitoring Site.

M-W04
1202 3rd St.

Promenade 84 proposed sign for the southeast corner location will be fully visible from the Monitoring Site.

M-W05
231 Arizona
Ave 89, 84, 104 proposed signs for the northeast, southwest, and southeast corner locations will be in full view from the Monitoring Site.

M-W06
1301 3rd St
Promenade 89, 84, 104 proposed signs for the northeast, northwest, and southeast corner locations will be in full view from the Monitoring Site.

M-W07
1352 3rd St
Promenade 66, 107, 80 proposed signs for the northeast, southwest, and southeast corner locations will be in full view from the Monitoring Site.

M-W08
1402 3rd St
Promenade 66, 107, 80 proposed signs for the northwest, northeast, and southeast corner locations will be in full view from the Monitoring Site.

M-W09
1460 3rd St.

Promenade 84 proposed signs for the northeast corner location will be in full view from the Monitoring Site.

M-S01 1705 Olympic
Dr
1105 proposed sign for the southwest corner location at Colorado and 4th has a limited view from the Monitoring Site.
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 24

Monitoring
Site Location
Distance to
Proposed Sign
(ft) Visibility from Monitoring Site
M-S02
southwest
corner of 4th
St. / Colorado
Ave
70 proposed sign for the southwest corner wall location at Colorado and 4th will be in full view from the Monitoring Site.

7.2 Monitoring Site Night Survey Data
The existing lighting conditions within and surrounding the District include streetlights within the adjacent public right of way, pole mounted lights along the Promenade, overhead decorative string lighting, landscape and architectural lighting, exterior surface mounted building lighting utilized for security and safety, commercial illuminated signs, and store front window display lighting. Vehicle headlights also contribute to the overall nighttime lighting. The observations and measurement at each Monitoring Site of existing lighting conditions within and surrounding the District are summarized below in relation to the evaluation factors established in Section 6, Significance Threshold:
a. Measured Existing Illuminance:

The Illuminance data listed in Table 4 and 5, below, summarize the measured Illuminance at each Monitoring Site. For the monitoring sites within the District, measured illuminance greater than 3.0 fc is evaluated as high illuminance, from

3.0 fc to 1.4 fc is evaluated as medium illuminance, and less than 1.4 fc is evaluated as low illuminance. At the Monitoring Sites located outside of the District, measured illuminance greater than 1.4 fc is evaluated as high illuminance, from 1.4 fc to 0.74 fc is evaluated as medium illuminance, and less than 0.74 fc is evaluated as low illuminance.

Table 5. Measured Illuminance (fc) at Monitoring Sites within the District Monitoring Site
Illuminance (fc) Evaluation (3.0 fc)
Horizontal Vertical Horizontal Vertical
M-E01 0.68 1.59 Low Medium
M-E02 1.27 1.4 Low Medium
M-E03 3.06 1.27 High Low
M-E04 3.81 2.63 High Medium
M-E05 0.91 1.16 Low Low
M-E06 3.42 3.07 High High
M-E07 11.77 1.79 High Medium
M-E08 0.88 1.25 Low Medium
M-E09 4.69 0.63 High Low
M-W04 4.78 0.72 High Low
M-W05 0.84 0.16 Low Low
M-W06 2.36 2.15 Medium Medium
M-W07 1.77 3.19 Medium High
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 25

M-W08 1.27 1.36 Low Low
M-W09 2.9 1.22 Medium Low
The measured existing horizontal illuminance at Monitoring Sites within the District vary from 11.77 fc at M-E07 to 0.68 fc at M-E01. The measured existing vertical illuminance at Monitoring Sties within the District vary from 3.19 fc maximum to 0.63 fc minimum. The measured existing illuminance is High, greater than 3.0 fc, at Monitoring Sites ME03, M-E04, M-E06, M-E07, M-E09, M-W04 and M-W07, 7 of the 15 sites measured along 3rd Street Promenade.

The District is highly developed with a lively mix of uses and currently includes various lighting for the commercial uses on the Promenade and at Santa Monica Place Shopping Center.

The measured illuminance is consistent with an urban, dense environment, with medium to high illuminance at the street and sidewalk within the public right of way and within nearby commercial properties, and lower illuminance within the residential properties, but sufficient light for safety and security.

The average existing illumunance at Monitoring Sites outside the District vary from 3.0 fc at M-W03 to 0.21 fc at MS01.

Table 6. Measured Illuminance (fc) at Monitoring Sites outside the District Monitoring Site Illuminance (fc) Evaluation (1.4 fc)
Horizontal Vertical Horizontal Vertical
M-E10 3.34 0.31 High Low
M-E11 1.15 2.39 Medium High
M-E12 2.10 1.39 High Medium
M-N01 0.28 0.33 Low Low
M-N02 0.42 0.22 Low Low
M-N03 0.30 0.47 Low Low
M-N04 1.18 1.37 Medium Medium
M-W01 0.45 0.64 Low Low
M-W02 1.64 1.19 High Medium
M-W03 3.00 4.14 High High
M-S01 0.21 0.37 Low Low
M-S02 1.58 0.96 High Medium
b. Measured Existing Luminance:

The measured existing luminance data at the Monitoring Sites is presented in Table 6. For this Study, the following luminance criteria are applied to measured and calculated luminance: luminance below 10 cd/m2 is evaluated as low luminance; luminance greater than 10 cd/m2 and less than 300 cd/m2 is evaluated as medium luminance; luminance greater than 300 cd/m2 is evaluated as high luminance.
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 26

The visual evaluation of High, Medium, and Low Contrast describes the perception of how bright a visible object appears to the surrounding objects within any given field of view and context. High Contrast indicates a potential glare condition for residential properties nearby. Contrast is the ratio of one surface luminance to a second surface luminance or to the luminance within the field of view. Contrast exceeding 30 to 1 is usually deemed uncomfortable and evaluated as high; less than 30 to 1 to greater than 10:1 is medium contrast; 10 to 1 is clearly visible and evaluated as low.

Table 6 includes an evaluation of the luminance (High, Medium, or Low) and an evaluation of the calculated contrast ratio (High, Medium, or Low). The measured luminance recorded at the Monitoring Sites within the view to the Project includes prominent, high brightness light sources and illuminated surfaces (such as streetlights, illuminated signs, and flood lighted buildings), as well as lower brightness surfaces such as sidewalks, parking lots, and un-illuminated walls or landscape areas. The measured Average Luminance is High at 9 Monitoring Sites: M-E2, M-E3, M-E7, M-E8, M-E9, ME10, M-E11, M-W8, and M-W9. The remaining 17 Monitoring Sites are Medium luminance. The maximum measured luminance is High at all 26 Monitoring Sites. The ratio of High maximum to Medium or High Average luminance results in Medium exisitng contrast ratios. This measurement data indicates a relatively bright existing environment along the 3rd Street Promenade and surrounding the Santa Monica Place Mall. There are numerous bright light sources throughout the District, but these sources are situated within a relatively bright overall space. Therefore, the contrast is not High or uncomfortable.

Table 7. Measured Luminance, (cd/m2
) at Monitoring Sites
Monitoring Site
Luminance (cd/m2) Evaluation
Contrast
Ratio (Max
/ Average)
Evaluation
Average Maximum
Avg
Luminance
Max
Luminance Contrast
M-E1 139 1515 Medium High 11:01 Medium
M-E2 537 7636 High High 14:01 Medium
M-E3 563 9905 High High 18:01 Medium
M-E4 226 2230 Medium High 10:01 Medium
M-E5 196 4365 Medium High 22:01 Medium
M-E6 237 4432 Medium High 19:01 Medium
M-E7 313 4882 High High 16:01 Medium
M-E8 458 9642 High High 21:01 Medium
M-E9 491 8652 High High 18:01 Medium
M-E10 328 5036 High High 15:01 Medium
M-E11 449 8537 High High 19:01 Medium
M-E12 150 1930 Medium High 13:01 Medium
M-N1 94 1168 Medium High 12:01 Medium
M-N2 112 1907 Medium High 17:01 Medium
M-N3 133 2858 Medium High 22:01 Medium
M-N4 94 1168 Medium High 12:01 Medium
M-S1 112 1907 Medium High 17:01 Medium
M-S2 133 2858 Medium High 22:01 Medium
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 27

M-W1 179 3648 Medium High 20:01 Medium
M-W2 113 1226 Medium High 11:01 Medium
M-W3 169 3939 Medium High 23:01 Medium
M-W4 92 744.7 Medium High 8:01 Medium
N-W5 108 1382 Medium High 13:01 Medium
M-W6 246 4065 Medium High 17:01 Medium
M-W7 232 3616 Medium High 16:01 Medium
M-W8 396 7604 High High 12:01 Medium
M-W9 410 5317 High High 13:01 Medium
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 28

7.3 Monitoring Site Data
a. Monitoring Site M-E01:

The existing lighting conditions at M-E01 are Medium horizontal and High vertical illumination from Project exterior lighting located to the west of Monitoring Site. Prominent light sources visible in the field of view from M-E01 to the east side of the Project site include exterior building lighting, signage lighting, and street lighting.

Figure 5: M-E01- 09/25/205, 2:17 pm
Figure 6: M-E01- 09/26/205, 7:58 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 29

b. Monitoring Site M-E02:

The existing lighting conditions at M-E02 are High horizontal and High vertical illumination from Project exterior lighting located to the northwest, southwest and southeast of Monitoring Site. Prominent light sources visible in the field of view from M-E02 to the northwest, southwest and southeast side of the Project site include exterior building lighting, sign lighting, walkway lighting, promenade overhead string lighting, and street lighting.

Figure 7: M-E02 – 09/25/2025, 2:45 pm
Figure 8: M-E02 – 09/29/2025, 8:17 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 30

c. Monitoring Site M-E03:

The existing lighting conditions at M-E03 are Medium horizontal and High vertical illumination from Project exterior lighting located to the west of the Monitoring Site. Prominent light sources visible in the field of view from M-E03 to the northeast side of the Project site include exterior building lighting, promenade overhead string and pole lighting, and street lighting.

Figure 9: M-E03 – 07/21/2025, 3:21 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 31

Figure 10: M-E03 – 07/22/2025, 11:27 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 32

d. Monitoring Site M-E04:

The existing lighting conditions at M-E04 are High horizontal and High vertical illumination from Project exterior lighting located to the northwest, southwest, and southeast of the Monitoring Site. Prominent light sources visible in the field of view from M-E04 to the northwest, southwest, and southeast sides of the Project site include exterior building lighting, promenade overhead string and pole lighting, and street lighting.

Figure 12: M-E04 – 09/26/2025, 8:44 pm
Figure 11: M_E04 - 09/25/2025, 2:55 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 33

e. Monitoring Site M-E05:

The existing lighting conditions at M-E05 are High horizontal and High vertical illumination from Project exterior lighting located to the northwest, southwest, and northeast of the Monitoring Site. Prominent light sources visible in the field of view from M-E05 to the northwest, southwest, and northeast sides of the Project site include exterior building lighting, promenade overhead string and pole lighting, and street lighting.

Figure 13: M-E05 - 09/25/2025, 3:00 pm
Figure 14: M-E-05 - 09/29/2025, 9:07 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 34

f. Monitoring Site M-E06:

The existing lighting conditions at M-E06 are High horizontal and High vertical illumination from Project exterior lighting located to the west of Monitoring Site. Prominent light sources visible in the field of view from M-E06 to the east side of the Project site include exterior and interior building lighting, and street lighting.

Figure 15: M-E06 – 09/25/2025, 3:06 pm
Figure 16: M-E06 – 09/29/2025, 9:41 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 35

g. Monitoring Site M-E07:

The existing lighting conditions at M-E07 are High horizontal and High vertical illumination from Project exterior lighting located to the west of Monitoring Site. Prominent light sources visible in the field of view from M-E07 to the east side of the Project site include exterior building lighting, parking garage lighting, and street lighting.

Figure 17: M-E07 – 09/25/2025, 3:09 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 36

Figure 18: M-E07 – 09/29/2025, 9:50 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 37

h. Monitoring Site M-E08:

The existing lighting conditions at M-E08 are High horizontal and High vertical illumination from Project exterior lighting located to the west of Monitoring Site. Prominent light sources visible in the field of view from M-E08 to the east side of the Project site include exterior building lighting, parking lot lighting, and street lighting.

Figure 19: M-E08 – 09/25/2025, 3:49 pm
Figure 20: M-E08 – 06/02/2025, 10:08 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 38

i. Monitoring Site M-E09:

The existing lighting conditions at M-E09 are High horizontal and Medium vertical illumination from Project exterior lighting located to the north of Monitoring Site. Prominent light sources visible in the field of view from M-E09 to the south side of the Project site include exterior building lighting, pedestrian lighting, and street lighting.

Figure 21: M-E09 – 09/25/2025, 3:59 pm
Figure 22: M-E09 – 09/29/2025, 10:17 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 39

j. Monitoring Site M-E10:

The existing lighting conditions at M-E10 are High horizontal and Medium vertical illumination from Project exterior lighting located to the north of Monitoring Site. Prominent light sources visible in the field of view from M-E10 to the south side of the Project site include exterior building lighting and street lighting.

Figure 23: M-E10 – 09/25/2025, 3:11 pm
Figure 24: M-E10 – 09/29/2025, 9:58 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 40

k. Monitoring Site M-E11:

The existing lighting conditions at M-E11 are High horizontal and High vertical illumination from Project exterior lighting located to the north of Monitoring Site. Prominent light sources visible in the field of view from M-E11 to the south side of the Project site include exterior building lighting and parking lot lighting.

Figure 25: M-E11 – 09/25/2025, 3:56 pm
Figure 26: M-E11 – 09/29/2025, 10:25 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 41

l. Monitoring Site M-E12:

The existing lighting conditions at M-E12 are High horizontal and High vertical illumination from Project exterior lighting located to the east of Monitoring Site. Prominent light sources visible in the field of view from M-E12 to the west side of the Project site include exterior building lighting, metro station lighting, and street lighting.

Figure 27: M-E12 – 09/25/2025, 4:09 pm
Figure 28: M-E12 – 09/29/2025, 10:46 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 42

m. Monitoring Site M-N01:

The existing lighting conditions at M-N01 are Low horizontal and Medium vertical illumination from Project exterior lighting located to the west of Monitoring Site. Prominent light sources visible in the field of view from M-N01 to the north side of the Project site include building lighting, parking lot lighting.

Figure 29: M-N01 - 07/21/2025, 2:56 pm
Figure 30: M-N01 - 07/22/2025, 9:22 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 43

n. Monitoring Site M-N02:

The existing lighting conditions at M-N02 are Medium horizontal and Low vertical illumination from Project exterior lighting located to the west of Monitoring Site. Prominent light sources visible in the field of view from M-N02 to the north side of the Project site include exterior building lighting, outside dining lighting, and street lighting.

Figure 31: M-N02 – 07/22/2025, 9:11 pm
Figure 32: M-N02 - 07/21/2025, 2:52 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 44

o. Monitoring Site M-N03:

The existing lighting conditions at M-N003 are Medium horizontal and Medium vertical illumination from Project exterior lighting located to the west of Monitoring Site. Prominent light sources visible in the field of view from M-N3 to the south side of the Project site include exterior building lighting, and street lighting.

Figure 34: M-N03 - 07/21/2025, 2:50 pm
Figure 33: M-N03, 07/22/2025, 9:20 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 45

p. Monitoring Site M-N04:

The existing lighting conditions at M-N04 are High horizontal and High vertical illumination from Project exterior lighting located to the southwest of Monitoring Site. Prominent light sources visible in the field of view from M-N04 to the east side of the Project site include building lighting, and street lighting.

Figure 35: M-N04 - 09/25/2025, 2:12 pm
Figure 36: M-N04 - 09/29/2025, 7:34 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 46

q. Monitoring Site M-W01:

The existing lighting conditions at M-W01 are Low horizontal and Medium vertical illumination from Project exterior lighting located to the west of Monitoring Site. Prominent light sources visible in the field of view from M-W01 to the east side of the Project site include exterior building lighting and parking lot lighting.

Figure 38: M-W01 - 09/29/2025, 8:04 pm
Figure 37: M-W01 – 09/25/2025, 2:24 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 47

r. Monitoring Site M-W02:

The existing lighting conditions at M-W02 are High horizontal and High vertical illumination from Project exterior lighting located to the west of Monitoring Site. Prominent light sources visible in the field of view from M-W02 to the east side of the Project site include exterior building lighting, parking lot lighting, and street lighting.

Figure 40: M-W02 - 07/21/2025, 3:14 pm
Figure 39: M-W02 - 09/22/2025, 10:09 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 48

s. Monitoring Site M-W03:

The existing lighting conditions at M-W03 are High horizontal and High vertical illumination from exterior lighting located to the west of Monitoring Site. Prominent light sources visible in the field of view from M-W03 to the east of the Project site include exterior building lighting.

Figure 42: M-W03 - 09/25/2025, 3:20 pm
Figure 41: M-W03 -09/29/2025, 9:08 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 49

251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 50

t. Monitoring Site M-W04:

The existing lighting conditions at M-W04 are High horizontal and High vertical illumination from Project exterior lighting located to the west of Monitoring Site. Prominent light sources visible in the field of view from M-W04 to the east side of the Project site include exterior building lighting, street lighting, traffic lighting, and pedestrian lighting.

Figure 43: M-W04 - 09/25/2025, 2:20 pm
Figure 44: M-W04 - 09/29/2025, 7:53 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 51

u. Monitoring Site M-W05:

The existing lighting conditions at M-W05 are High horizontal and High vertical illumination from Project exterior lighting located to the southwest, northeast and southeast of Monitoring Site. Prominent light sources visible in the field of view from M-W05 to the southwest, northeast, and southeast side of the Project site include exterior building lighting, Promenade overhead string and pole lighting, and street lighting.

Figure 45: M-W05 - 09/25/2025, 2:47 pm
Figure 46: M-W05 - 09/29/2025, 8:25 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 52

v. Monitoring Site M-W06:

The existing lighting conditions at M-W06 are High horizontal and Medium vertical illumination from Project exterior lighting located to the northwest, southwest, and southeast of Monitoring Site. Prominent light sources visible in the field of view from M-W06 to the northwest, southwest, and southeast side of the Project site include exterior building lighting, promenade overhead string and pole lighting, and street lighting.

Figure 47: M-W06 - 09/25/2025, 2:49 pm
Figure 48: M-W06 - 09/29/2025, 8:33 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 53

w. Monitoring Site M-W07:

The existing lighting conditions at M-W07 are High horizontal and Medium vertical illumination from Project exterior lighting located to the southwest, northeast, and southeast of Monitoring Site. Prominent light sources visible in the field of view from M-W07 to the southwest, northeast, and southeast side of the Project site include exterior building lighting, promenade overhead string and pole lighting, and street lighting.

Figure 49: M-W07 - 09/25/2025, 2:56 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 54

Figure 50: M-W07 - 09/29/2025, 8:53
x. Monitoring Site M-W08:

The existing lighting conditions at M-W08 are High horizontal and High vertical illumination from Project exterior lighting located to the northwest, southwest, and southeast of Monitoring Site. Prominent light sources visible in the field of view from M-W08 to the northwest, southwest, and southeast side of the Project site include exterior building lighting, promenade overhead string and pole lighting, and street lighting.

Figure 51: M-W08 - 09/25/2026, 2:58 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 55

Figure 52: M-W08 - 09/29/2025, 9:01 pm
y. Monitoring Site M-W09:

The existing lighting conditions at M-W09 are high horizontal and high vertical illumination from Project exterior lighting located to the east of Monitoring Site. Prominent light sources visible in the field of view from M-W09 to the east side of the Project site include exterior building lighting, architectural lighting, parking structure lighting, and street lighting.

Figure 53: M-W09 - 09/25/2025, 3:04 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 56

Figure 54: M-W09 - 09/29/2025, 9:17 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 57

z. Monitoring Site M-S01:

The existing lighting conditions at M-S01 are High horizontal and Medium vertical illumination from Project exterior lighting located to the west of Monitoring Site. Prominent light sources visible in the field of view from M-S01 to the south side of the Project site include exterior traffic lighting and street lighting.

Figure 55: M-S01 - 09/25/2025, 4:26 pm
Figure 56: M-S01 - 09/29/2025, 11:12 p
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 58

aa. Monitoring Site M-S02:

The existing lighting conditions at M-S02 are High horizontal and High vertical illumination from Project exterior lighting located to the North of Monitoring Site. Prominent light sources visible in the field of view from M-S02 to the south side of the Project site include exterior building lighting, catenary lighting, and street lighting.

Figure 57: M-S02 - 09/25/2025, 4:03 pm
Figure 58: M-S02 - 09/29/2025, 10:35 pm
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 59

8. LIGHTING ANALYSIS
The Project would permit up to 16 new large format, digital Signs as described in Section 3 and depicted in Appendix A.

The following criteria are used in this Study to evaluate the Project’s impact with respect to light trespass and glare:
• Sign light trespass illuminance must not exceed 3.0 fc at the property lines of nearby residential use properties within the District
• Sign light trespass illuminance must not exceed 1.4 fc at the property lines of residential use properties outside of the District
• Sign luminance must be less than high contrast conditions, i.e., less than 30 to 1 contrast ratios. • Sign luminance visible within 10 degrees from the driver’s normal field of view must be less than 500 fL and or less than 1,000 times the minimum measured brightness in the driver’s field of view, except that when the minimum measured brightness in the field of view is 10 footlamberts or less, the measured brightness of the light source in footlambert shall not exceed 500 plus 100 times the angle, in degrees, between the driver’s field of view and the light source.

8.1 Light Trespass Analysis
Project light trespass illuminance from Project Signs is evaluated by way of the calculated illuminance (fc) as per the methodology defined in Section 6, at the vertical and horizontal calculation plane locations where lighting is under review. As noted above, this Study evaluates the light trespass illuminance from the Project at residential use properties within the District at a maximum 3.0 fc, and at residential use properties outside the District at a maximum of 1.4 fc. This Study analyzes potential and future Signs as described in the Conceptual Plan (Appendix A) which defines the Project Sign(s) locations, dimensions, and orientation.

The evaluation of Sign light trespass illuminance within the District is described as High, Medium, and Low as follows:

Illuminace greater than than 3.0 fc, is evaluated as “High”; Illuminance greater than 1.4 fc but less than 3.0 fc is evaluated as “Medium”; Illuminance less than 1.4 fc is evaluated as “Low”.

The evaluation of Sign light trespass illuminance outside the boundaries of the District is described as High, Medium, and Low as follows: Illuminace greater than 1.4 fc, is evaluated as “High”; Illuminance greater than 0.74 fc but less than 1.4 fc is evaluated as “Medium”; and illuminance less than 0.74 fc is evaluated as “Low”.

Per the illumination standards that are set forth in the Project Description (Section 3), the Project Signs will operate at maximum luminance of 6,000 cd/m2 during the day from sunrise to sunset, 300 cd/m2 in the evening from sunset to 10:00 pm, and 200 cd/m2 at night between 10:00 pm and 1:00 am, and all off from 1:00 am until sunrise, with a smooth transition from day maximum luminance to night maximum luminance beginning 45 minutes prior to sunset and concluding at sunset, and from nighttime maximum luminance to daytime maximum luminance at sunrise and concluding 45 minutes after sunrise.

The Project Sign light trespass analysis evaluates the illuminance (fc) from the Project Sign leaving the Project Site toward nearby residential use properties as shown in Figure 4 above with respect to the maximum light trespass threshold of 3.0 fc within the District and 1.4 fc beyond the boundaries of the District. The Project Signs are analyzed in this Study conservatively with the Project Signs operating at maximum nighttime luminance as noted above, in “all 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 60

white” mode. The Project Signs will not operate in “all white” mode in practice. However, all white would produce the maximum light trespass and therefore is assumed to represent a conservative analysis. The information in the Conceptual Sign Plan (Appendix A) and as described in Section 3 (Project Description) was utilized to calculate Project Sign light trespass illuminance in this Study.

The Project Sign light trespass illuminance calculation results are summarized in Tables 7, 8, 9 and 10 below for each vertical calculation plane. Complete Project Sign illuminance calculated data is presented in Appendix B and where the illuminance exceeds the threshold of 3.0 fc for sensitive uses within the District or 1.4 fc for sensitive uses outside the District, the data is presented with bold text.
a. Light Trespass Illuminance within the District
The analysis of lighting impacts includes calculations of light trespass illuminance at nearby residential uses that would be affected by the Project Sign(s). Calculations of light trespass simulate light meters measuring light from the Project Sign within a vertical plane at the residential use property line or the location where light trespass is being analyzed.

The calculations in this Study are presented at 10 feet on center, vertically and horizontally, covering the surface from the height of the ground floor commercial use properties, estimated at 15 feet above grade, to the height of the Project Signs or the height of existing residential use properties.

The light trespass illuminance from the Project Signs operating at night, from sunset until 10:00 pm at maximum of 300 cd/m2 is calculated at the vertical planes located within the District, and the results are summarized in Table 7.

With Sign luminance at 300 cd/m2
, the maximum illuminance at vertical planes within the District exceeds 3.0 fc maximum threshold defined by the District at vertical planes VP-E3, VP- E6, VP-E7, VP-E10, VP-E12, VP-W3, VP-W6, VPW7, VP-W10, and VP-W11. The Vertical Planes VP-E3, VP-E7, VP-E10, VP-E12, VP-W3, VP-W6, VP-W7, VP-W10, and VPW11 are located at commercial use properties. Therefore, light trespass illuminance greater than 3.0 fc at these vertical plane locations will not create an impact.

The vertical plane VP-E6 is located at the existing mixed-use use property at 1311 3rd Street Promenade/302 Arizona Ave (Victoria Secret/Criterion Promenade Apartments). Therefore, light trespass illuminance greater than 3.0 fc at vertical plane VP-E6 facing the 3rd Street Promenade could create a high light trespass on the existing residences on levels 2 and 3 of this mixed-use property, in the absence of the regulatory requirements of the Digital Display Ordinance. However, the Project includes a requirement that illuminance from any digital display or architectural lights of the display shall not exceed 3.0 fc at any residential uses. Therefore, the light trespass at this location from Project Sign(s) will be required to be minimized to 3.0 fc or below pursuant to the Digital Display District’s regulations through design features, such as:
(1) Sign area may be reduced to proportionally reduce the light trespass illuminance. (2) Signs may be angled and oriented away from any nearby residential properties. (3) Louvers may be integrated into the Sign design to control and limit the light trespass at nearby residential properties.
(4) Each Sign shall be fully dimmable and shall be controlled by a programmable timer so that luminance levels may be adjusted according to the time of day and applicable lighting standards. (5) A Photometric Report prepared by a lighting professional shall be submitted to the Director upon installation prior to issuance of a certificate of occupancy or commercial operation of the display, and 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 61

at two-year intervals thereafter to confirm conformance with the lighting requirements in the Ordinance.

Table 8: Sign Light Trespass Illuminance (fc) at Vertical Planes within the District, 300 cd/m2 Vertical Plane
Illuminance (fc) Sign
Luminance
(cd/sqm)
Analysis
(3.0 fc threshold) Max Min Avg
VP-E2 2.98 0.26 1.45 300
Medium light trespass, less than

3.0 fc, greater than 1.4 fc., no
impact
VP-E3 4.25 0.00 1.66 300
High light trespass, greater than

3.0 fc; commercial use property,
no impact
VP-E6 3.95 0.01 1.67 300
High light trespass, greater than

3.0 fc; at levels 2 & 3 of existing
residential use property, signage at
this location would therefore be
subject to light reduction
regulations under Ordinance
Section 9.61.205(H)(2), which
would ensure impacts are less than
significant
VP-E7 3.88 0.41 1.71 300
High light trespass, greater than

3.0 fc; commercial use property,
no impact
VP-E10 3.74 0.41 1.66 300
High light trespass, greater than

3.0 fc; commercial use property,
no impact
VP-E11 2.83 0.21 1.24 300
Medium light trespass, less than

3.0 fc, greater than 1.4 fc. no
impact
VP-E12 3.33 0.27 1.25 300
High light trespass, greater than

3.0 fc; at levels 2 to 4, commercial
use property, no impact
VP-E17 1.06 0.09 0.39 300
Low light trespass, less than 1.4 fc.
no impact
VP-W2 2.64 0.23 1.18 300
Medium light trespass, less than

3.0 fc, greater than 1.4 fc. no
impact
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 62

Vertical Plane
Illuminance (fc) Sign
Luminance
(cd/sqm)
Analysis
(3.0 fc threshold) Max Min Avg
VP-W3 5.21 0.45 2.19 300
High light trespass, greater than

3.0 fc; commercial use property,
no impact
VP-W6 3.50 0.42 1.57 300
High light trespass, greater than

3.0 fc; commercial use property,
no impact
VP-W7 3.51 0.44 1.75 300
High light trespass, greater than

3.0 fc; commercial use property,
no impact
VP-W10 3.16 0.00 1.28 300
High light trespass, greater than

3.0 fc; commercial use property,
no impact
VP-W11 3.27 0.00 1.13 300
High light trespass, greater than

3.0 fc; commercial use property,
no impact
VP-W12 1.54 0.29 0.73 300
Medium light trespass, less than

3.0 fc, greater than 1.4 fc. no
impact
The calculated illuminance at the vertical planes at Broadway & 3rd Street Promenade intersection are illustrated in Figure 59 and Figure 60.

The calculated illuminance at the vertical planes at Santa Monica Blvd & 3rd Street Promenade intersection are illustrated in Figure 61 and Figure 62,
The calculated illuminance at the vertical planes at Arizona & 3rd Street Promenade intersection are illustrated in Figure 63 and Figure 64.

The calculated illuminance at the vertical planes at Wilshire & 3rd Street Promenade intersection are illustrated in Figure 65 and Figure 66.
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 63

Figure 59: Calculation Rendering at Broadway & 3rd St Promenade Intersection, View Looking South-East, 300 cd/m2 Figure 60: Calculation Rendering at Broadway & 3rd St Promenade Intersection, View Looking South-West, 300 cd/m2 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 64

Figure 61: Calculation Rendering at Santa Monica Blvd & 3rd St Promenade Intersection, View Looking South-East, 300 cd/m2
Figure 62: Calculation Rendering at Santa Monica Blvd & 3rd St Promenade Intersection, View Looking South-West, 300 cd/m2
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 65

Figure 63: Calculation Rendering at Arizona & 3rd St Promenade Intersection, View Looking South-East, 300 cd/m2 Figure 64: Calculation Rendering at Arizona & 3rd St Promenade Intersection, View Looking South-West, 300 cd/m2 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 66

Figure 65: Calculation Rendering at Wilshire & 3rd St Promenade Intersection, View Looking South-East, 300 cd/m2 Figure 66: Calculation Rendering at Wilshire & 3rd St Promenade Intersection, View Looking South-West, 300 cd/m2 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 67

Sign light trespass illuminance is further analyzed at the vertical planes with maximm Sign luminance of 200 cd/m2 for the time period from 10:00 pm until 1:00 am.

The Project Signs light trespass illuminance at the vertical planes defined above in Figure 4, with Signs operating at maximum of 200 cd/m2 from 10:00 pm until 1:00 am are summarized in Table 8.

The calculated maximum Sign light trespass illuminance at vertical planes located within the District boundary does not exeed 3.0 fc at all vertical planes except at vertical plane VP-W3. The maximum illuminance at VP-W3 is 3.47 fc.

However, vertical plane VP-W3 is located at a commercial use property, which is not a sensitive use.

Therefore, there is no light trespass impact from the Project Signs operating at 200 cd/m2 from 10:00 pm until 1:00 at residential uses within the District boundary.

Table 9: Sign Light Trespass Illuminance (fc) at Vertical Planes within the District, 200 cd/m2 Vertical Plane
Illuminance (fc) Sign
Luminance
(cd/sqm)
Analysis
(3.0 fc threshold) Max Min Avg
VP-E2 1.99 0.17 0.97 200 Medium light trespass, less than 3.0 fc, greater than 1.4 fc; no impact
VP-E3 2.83 0.00 1.10 200 Medium light trespass, less than 3.0 fc, greater than 1.4 fc; no impact
VP-E6 2.63 0.00 1.11 200 Medium light trespass, less than 3.0 fc, greater than 1.4 fc; no impact
VP-E7 2.58 0.27 1.13 200 Medium light trespass, less than 3.0 fc, greater than 1.4 fc; no impact
VP-E10 2.50 0.28 1.11 200 Low light trespass, less than 1.4 fc. no impact
VP-E11 1.88 0.14 0.83 200 Medium light trespass, less than 3.0 fc, greater than 1.4 fc; no impact
VP-E12 2.22 0.18 0.84 200 Medium light trespass, less than 3.0 fc, greater than 1.4 fc; no impact
VP-E17

0.88 0.09 0.35
200 Low light trespass, less than 1.4 fc. no
impact
VP-W2 1.76 0.16 0.79 200 Medium light trespass, less than 3.0 fc, greater than 1.4 fc; no impact
VP-W3 3.47 0.30 1.45 200
High light trespass, greater than 3.0
fc; commercial use property, no
impact
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 68

Vertical Plane
Illuminance (fc) Sign
Luminance
(cd/sqm)
Analysis
(3.0 fc threshold) Max Min Avg
VP-W6 2.33 0.28 1.05 200 Medium light trespass, less than 3.0 fc, greater than 1.4 fc; no impact
VP-W7 2.34 0.30 1.16 200 Medium light trespass, less than 3.0 fc, greater than 1.4 fc; no impact
VP-W10 2.10 0.00 0.85 200 Medium light trespass, less than 3.0 fc, greater than 1.4 fc; no impact
VP-W11 2.18 0.00 0.75 200 Medium light trespass, less than 3.0 fc, greater than 1.4 fc; no impact
VP-W12 1.03 0.19 0.48 200 Low light trespass, less than 1.4 fc. no impact
b. Light Trespass Illuminance Outside of the District
The analysis of light impacts includes calculations of light trespass illuminance and glare at existing residential uses beyond the boundaries of the Sign District that would be affected by the Project. Calculations of light trespass simulate light meters measuring light from the Project within a vertical plane at residential use property lines or the locations where light trespass is being analyzed. The calculations are presented at 10 feet on center, vertically and horizontally, covering the vertical surface from 15 feet above grade to the height of the Project, or the height of existing residential use properties.

The evaluation of Signs light trespass illuminance outside the boundaries of the District is described as High, Medium, and Low as follows: Illuminance greater than 1.4 fc, is evaluated as “High”; Illuminance greater than 0.74 fc but less than 1.4 fc is evaluated as “Medium”. Illuminance, and illuminance less than 0.74 fc is evaluated as “Low”.

The Project Signs light trespass illuminance at the vertical planes defined above in Figure , with Signs operating at maximum of 300 cd/m2 from sunset until 10:00 pm are summarized in Table 9.

Table 10: Sign Light Trespass Illuminance (fc) at Vertical Planes beyond the District boundary, 300 cd/m2 Vertical Plane
Illuminance (fc) Sign
Luminance
(cd/m2)
Analysis
(1.4 fc threshold) Max Min Avg
VP-E1 0.41 0.07 0.19 300 Low light trespass, less than 0.74 fc. no impact
VP-E4 5.30 0.30 1.73 300 High light trespass, greater than 1.4 fc; commercial use, no impact
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 69

Vertical Plane
Illuminance (fc) Sign
Luminance
(cd/m2)
Analysis
(1.4 fc threshold) Max Min Avg
VP-E5 2.78 0.20 0.95 300 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-E8 3.24 0.36 1.40 300 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-E9 3.49 0.00 1.84 300 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-E13 0.38 0.09 0.20 300 Low light trespass, less than 0.74 fc. no impact
VP-E14 0.01 0.00 0.00 300 Low light trespass, less than 0.74 fc. no impact
VP-E15 0.22 0.00 0.01 300 Low light trespass, less than 0.74 fc. no impact
VP-E16 0.09 0.01 0.05 300 Low light trespass, less than 0.74 fc. no impact
VP-E18 0.07 0.00 0.01 300 Low light trespass, less than 0.74 fc. no impact
VP-N1 0.23 0.00 0.07 300 Low light trespass, less than 0.74 fc. no impact
VP-N2 0.07 0.01 0.03 300 Low light trespass, less than 0.74 fc. no impact
VP-N3 0.32 0.00 0.06 300 Low light trespass, less than 0.74 fc. no impact
VP-N4 0.11 0.00 0.00 300 Low light trespass, less than 0.74 fc. no impact
VP-N5 0.24 0.00 0.04 300 Low light trespass, less than 0.74 fc. no impact
VP-S1 0.04 0.02 0.03 300 Low light trespass, less than 0.74 fc. no impact
VP-S2 0.00 0.00 0.00 300 Low light trespass, less than 0.74 fc. no impact
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 70

Vertical Plane
Illuminance (fc) Sign
Luminance
(cd/m2)
Analysis
(1.4 fc threshold) Max Min Avg
VP-S3 0.00 0.00 0.00 300 Low light trespass, less than 0.74 fc. no impact
VP-W1 0.28 0.06 0.13 300 Low light trespass, less than 0.74 fc. no impact
VP-W4 3.90 0.66 2.09 300 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-W5 3.77 0.60 1.86 300 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-W8 3.57 0.30 1.36 300 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-W9 3.51 0.39 1.42 300 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-W13 0.06 0.00 0.01 300 Low light trespass, less than 0.74 fc. no impact
VP-W14 0.02 0.00 0.01 300 Low light trespass, less than 0.74 fc. no impact
VP-W15 0.00 0.00 0.00 300 Low light trespass, less than 0.74 fc. no impact
VP-W16 0.01 0.00 0.00 300 Low light trespass, less than 0.74 fc. no impact
VP-W17 0.05 0.03 0.04 300 Low light trespass, less than 0.74 fc. no impact
VP-W18 0.00 0.00 0.00 300 Low light trespass, less than 0.74 fc. no impact
VP-W19 0.14 0.00 0.07 300 Low light trespass, less than 0.74 fc. no impact
VP-W20 0.09 0.00 0.04 300 Low light trespass, less than 0.74 fc. no impact
With Sign luminance at 300 cd/m2
, the calculated maximum Sign light trespass illuminance at vertical planes located within the District exceeds 1.4 fc at Vertical Planes VP-E4, VP-E5, VP-E8, VP-E9, VP-W4, VP-W5, VP-W8 and VP-W9. The maximum illuminance at VP-E4 is 5.30 fc. However, the locations where Sign light trespass exceeds 1.4 fc are 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 71

commercial use properties, which are not sensitive uses. Therefore, there is no light trespass impact from the Project Signs at residential use properties beyond the District boundary with Signs operating at maximum luminance of 300 cd/m2
.

Signs are further analyzed operating at maximum luminance of 200 cd/m2 from 10:00 pm until 1:00 am at the vertical plane locations outside the District Boundary.

The Project Signs light trespass illuminance at the vertical planes defined above in Figure 4, with Signs operating at maximum of 200 cd/m2 from 10:00 pm until 1:00 am are summarized in Table 10.

The calculated maximum Sign light trespass exceeds 1.4 fc at vertical planes VP-E4, VP-E5, VP-E8, VP-E9, VP-W4, VPW5, VP-W8 and VP-W9. However, the areas within these vertical planes where light trepass exceeds 1.4 fc are commercial use, and therefore, will not create a light trespass impact. Therefore, there is no light trespass impact from the Project Signs at residential use properties beyond the District boundary from 10:00 pm until 1:00 am with Signs operating at 200 cd/m2
.

Table 11: Sign Light Trespass Illuminance (fc) at Vertical Planes beyond the District boundary, 200 cd/m2 Vertical
Plane
Illuminance (fc) Sign
Luminance
(cd/sqm)
Analysis
(1.4 fc threshold) Max Min Avg
VP-E1 0.28 0.05 0.12 200 Low light trespass, less than 0.74 fc. no impact
VP-E4 3.53 0.20 1.15 200 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-E5 1.86 0.13 0.64 200 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-E8 2.15 0.24 0.93 200 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-E9 2.32 0.00 1.22 200 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-E13 0.25 0.06 0.13 200 Low light trespass, less than 0.74 fc. no impact
VP-E14 0.01 0.00 0.00 200 Low light trespass, less than 0.74 fc. no impact
VP-E15 0.14 0.00 0.01 200 Low light trespass, less than 0.74 fc. no impact
VP-E16 0.06 0.01 0.03 200 Low light trespass, less than 0.74 fc. no impact
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 72

Vertical
Plane
Illuminance (fc) Sign
Luminance
(cd/sqm)
Analysis
(1.4 fc threshold) Max Min Avg
VP-E18 0.00 0.00 0.00 200 Low light trespass, less than 0.74 fc. no impact
VP-N1 0.15 0.00 0.04 200 Low light trespass, less than 0.74 fc. no impact
VP-N2 0.05 0.01 0.02 200 Low light trespass, less than 0.74 fc. no impact
VP-N3 0.22 0.00 0.04 200 Low light trespass, less than 0.74 fc. no impact
VP-N4 0.07 0.00 0.00 200 Low light trespass, less than 0.74 fc. no impact
VP-N5 0.16 0.00 0.03 200 Low light trespass, less than 0.74 fc. no impact
VP-S1 0.02 0.01 0.02 200 Low light trespass, less than 0.74 fc. no impact
VP-S2 0.00 0.00 0.00 200 Low light trespass, less than 0.74 fc. no impact
VP-S3 0.00 0.00 0.00 200 Low light trespass, less than 0.74 fc. no impact
VP-W1 0.18 0.04 0.09 200 Low light trespass, less than 0.74 fc. no impact
VP-W4 2.59 0.43 1.38 200 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-W5 2.49 0.39 1.22 200 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-W8 2.39 0.20 0.91 200 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-W9 2.35 0.26 0.95 200 High light trespass, greater than 1.4 fc; commercial use, no impact
VP-W13 0.04 0.00 0.01 200 Low light trespass, less than 0.74 fc. no impact
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 73

Vertical
Plane
Illuminance (fc) Sign
Luminance
(cd/sqm)
Analysis
(1.4 fc threshold) Max Min Avg
VP-W14 0.02 0.00 0.00 200 Low light trespass, less than 0.74 fc. no impact
VP-W15 0.00 0.00 0.00 200 Low light trespass, less than 0.74 fc. no impact
VP-W16 0.00 0.00 0.00 200 Low light trespass, less than 0.74 fc. no impact
VP-W17 0.04 0.02 0.03 200 Low light trespass, less than 0.74 fc. no impact
VP-W18 0.00 0.00 0.00 200 Low light trespass, less than 0.74 fc. no impact
VP-W19 0.09 0.00 0.05 200 Low light trespass, less than 0.74 fc. no impact
VP-W20 0.06 0.00 0.03 200 Low light trespass, less than 0.74 fc. no impact
c. Project Signs Light Trespass Analysis Using Inverse Square Law In addition, the Project Signs are analyzed to evaluate the distance where the illuminance from each individual Sign will be 0.3 fc or less, or less than 10% of the maximum permitted within the District at 3.0 fc. Incident light (fc) from a source degrades in proportion to the inverse square of the distance from the source to the location where lighting is evaluated, which for this Study is residential use properties. The illuminance EV (fc) incident at any given distance D (ft) from an illuminated surface S (ft2
) with uniform surface luminance of L (cd/m2) is calculated by the following formula:

EV = L x S

10.76 x D2
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 74

This formula illustrates the reduction in illuminance at any location as the distance increases from a source surface.

Larger sign areas produce the greatest distance from the Project where the illuminance will be equal to or greater than

0.3 footcandles. The distance from the Project Sign to the location where the Sign Illuminance (Ev) equals 0.3 footcandles is calculated utilizing the formula above and solving for D.

D = square root ((L x S))/(10.76 x Ev)
The Project Signs identified in Figure 67 and as outlined in Section 3, Project Sign Plan, are evaluated by the formula above. Table 11 presents the calculated distance from the Project Sign face to the location where the Project Sign Illuminance equals 0.3 footcandles. For a Sign with a maximum area of 1,000 square feet and having 500 square feet of Sign face on each side of the building operating at the maximum luminance of 300 cd/m2 , the Distance D is 216 feet from the Sign face.

Figure 67: District, Sign Locations, Residential Properties 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 75

The property at 425 4th Street is the nearest residential property to any Sign at approximately 171 to 264 feet from the northwest facing Sign S-15A at the intersection of 4th Street and Broadway at Santa Monica Place. The Sign illuminance from Sign S-15 A at 171 ft from the Sign will be 0.5 fc, and at 264 ft will be 0.2 fc. The existing measured illuminance at Measuring Site M-E07 at the intersection of 4th Street and Broadway, 114 feet from the northwest facing Sign S-15A at Santa Monica Place Mall is 1.79 fc (vertical). The increase over ambient illumination from the Signs at M-E07 is 1.1 fc, or 60% of the ambient. The increased illuminance at 425 4th Street will be 11% to 28% above the ambient illuminance.

The increased illuminance at M-E07 and at 425 4th Street will be less than 1.4 fc, the maximum Sign illuminance outside the District boundary, and will be substantially less than the existing ambient illuminance along 4th Street, which is a commercial thoroughfare with extensive night time activities All other residential properties outside the boundaries of the District are located more than 305 feet from any Project Sign face, and will therefore receive less than 0.30 fc from any Sign face.

All of the Project Signs will be required to comply with the Sign District Ordinance and will operate in a manner that will not create light trespass at existing nearby residential properties. More distant residential properties will receive less light from the Project due to the increased distance. Therefore, the Project will not produce a significant light trespass impact to any existing residential properties.

Table 12: Project Signs Distance (D) to Ev=0.3fc
Sign Area Distance in feet @

0.3 fc
S-1 1000 305
S-2 1000 305
S-3 1000 305
S-4 1000 305
S-5 1000 305
S-6 1000 305
S-7 1000 305
S-8 1000 305
S-9 1000 305
S-10 1000 305
S-11 1000 305
S-12 1000 305
S-13 1000 305
S-14 1000 305
S-15 1000 305
S-16 1000 305
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 76

8.2 Glare Analysis at Residential Properties
The evaluation of High, Medium and Low Contrast describes the perception of how bright a visible object appears in comparison to the surrounding objects within any given field of view. The “luminance ratio” is the ratio of the maximum Sign Luminance as compared to the Average Luminance within the field of view visible at an observer position. This ratio is referred to as “contrast”, and is determined by the variation of luminance. “High,” “Medium,” and “Low” contrast are terms used to describe the effect of the contrast ratios (the ratio of maximum luminance to the average within a field of view) of greater than 30:1, between 10:1 and 30:1, and Table 13: Project Sign Contrast Ratio at 300 cd/m2
Monitoring
Site
Existing Measured
Luminance
Project Lighting
Luminance
Average Maximum Max Evaluation
Contrast
Ratio
M-E1 138 1515 300 2.2 : 1 Low Contrast Ratio, No Glare Impact M-E2 536 7636 300 0.6 : 1 Low Contrast Ratio, No Glare Impact M-E3 563 9905 300 0.6 : 1 Low Contrast Ratio, No Glare Impact M-E4 226 2230 300 1.4 : 1 Low Contrast Ratio, No Glare Impact M-E5 196 4365 300 1.6 : 1 Low Contrast Ratio, No Glare Impact M-E6 237 4432 300 1.2 : 1 Low Contrast Ratio, No Glare Impact M-E7 313 4882 300 1 : 1 Low Contrast Ratio, No Glare Impact M-E8 458 9642 300 0.6 : 1 Low Contrast Ratio, No Glare Impact M-E9 491 8652 300 0.6 : 1 Low Contrast Ratio, No Glare Impact M-E10 328 5036 300 1 : 1 Low Contrast Ratio, No Glare Impact M-E11 449 8537 300 0.6 : 1 Low Contrast Ratio, No Glare Impact M-E12 150 1930 300 2 : 1 Low Contrast Ratio, No Glare Impact M-N1 94 1168 300 3.2 : 1 Low Contrast Ratio, No Glare Impact M-N2 112 1907 300 2.6 : 1 Low Contrast Ratio, No Glare Impact M-N3 133 2858 300 2.2 : 1 Low Contrast Ratio, No Glare Impact M-N4 94 1168 300 3.2 : 1 Low Contrast Ratio, No Glare Impact 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 77

Monitoring
Site
Existing Measured
Luminance
Project Lighting
Luminance
Average Maximum Max Evaluation
Contrast
Ratio
M-S1 112 1907 300 2.6 : 1 Low Contrast Ratio, No Glare Impact M-S2 133 2858 300 2.2 : 1 Low Contrast Ratio, No Glare Impact M-W1 179 3648 300 1.6 : 1 Low Contrast Ratio, No Glare Impact M-W2 11 1226 300 2.6 : 1 Low Contrast Ratio, No Glare Impact M-W3 92 744.7 300 3.2 : 1 Low Contrast Ratio, No Glare Impact M-W4 169 3939 300 1.8 : 1 Low Contrast Ratio, No Glare Impact M-W5 108 1382 300 2.8 : 1 Low Contrast Ratio, No Glare Impact M-W6 246 4065 300 1.2 : 1 Low Contrast Ratio, No Glare Impact M-W7 232 3616 300 1.2 : 1 Low Contrast Ratio, No Glare Impact M-W8 396 7604 300 0.8 : 1 Low Contrast Ratio, No Glare Impact M-W9 410 5317 300 0,8 : 1 Low Contrast Ratio, No Glare Impact below 10:1, respectively. Luminance contrast ratios above 30:1 are generally uncomfortable for the human eye to perceive. High Contrast, greater than a 30:1 Contrast Ratio, indicate a potential glare condition.

The existing lighting conditions at night within and surrounding the Project Site and visible within the field of view from the Monitoring Sites were evaluated on September 25, 2025 and September 29, 2025. Measurements of the existing luminance at night within the field of view from the Monitoring Sites are summarized in Section 8.3 and Table 4 above.

Potential glare from the Sign is evaluated by calculating the Contrast Ratio, which is the ratio of the maximum Sign Luminance compared to the existing measured Average Luminance in Table 4. Table 12 summarizes the measured average luminance at each Monitoring Site (from Table 4) along with a calculation of the comparison of the proposed Project Sign maximum night time luminance to the existing measured average luminance to determine the Contrast Ratio.

The existing measured luminance at Monitoring Sites M-N1, M-N4, and M-W3 are less than 100 cd/m2 . The existing
measured luminance at Monitoring Sites M-E1,M-E12, M-N2, M-N3, M-S1, M-S2, M-W2, and M-W5 are greater than 100 cd/m2 and less than 300 cd/m2
, and the existing measured luminance at Monitoring Sites M-E2, M-E3, M-E4, M-E5, M-E6, M-E7, M-E8, M-E9, M-E10, M-E11, M-W1, M-W4, M-W6, M-W7, M-W8, and M-W9 are greater than 300 cd/m2 .

The maximum Project Signs night time luminance of 300 cd/m2 results in low Contrast Ratios for all Monitoring Sites, from a minimum of 0.6:1, to a maximum of 3.2:1.
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 78

Therefore, the proposed Project Signs maximum night time luminance at 300 cd/m2 will not create a new source of glare at any Monitoring site or at surrounding residential use properties in proximity to the Project Site. Light degrades rapidly with distance as described above by the Inverse Square Law. Therefore, residential properties more distant from the Project Site than the Monitoring Sites will receive substantially less light than the Monitoring Sites. Therefore, there is no significant glare impact from the Project Signs at any residential use properties.

8.3 Glare Analysis for Roadways, California Vehicle Code The lighting impact to driver’s visibility from the Project are evaluated by way of the methodology defined in Section 7 above at the center line of the driver’s field of view and at angles wider than the center line of the driver’s field of view.

Bright sources within the drivers field of view, from the centerline of the roadway to angles up to 90 degrees from the center line of the roadway, may create glare if the light source is brighter than the limits established by the California Vehicle Code (CVC) as noted in Section 5.2 above. As summarized below, the results of this Study demonstrate the maximum Project Sign luminance is less than the limits established by the CVC for excessive luminance, or glare, during night, twilight (after sunset, and before sunrise), and during the day. Accordingly, the Project Sign meets the CVC standard for roadways approaching the Project Site from all directions.

The roadway glare analysis evaluates the maximum Project Sign luminance during night, twilight, and day with respect to the most stringent requirements of the CVC to determine if the Project introduces a source of distracting glare to drivers. The maximum Project Sign luminance at night and during twilight is 300 cd/m2 , all white. The maximum
Project Sign luminance during the day is 6,000 cd/m2
, all white.

The most stringent condition identified within the CVC Section 21466.5, states: “except that when the minimum measured brightness in the field of view is 10 footlamberts or less, the measured brightness of the light source in footlamberts (fL) shall not exceed 500 plus 100 times the angle, in roadway degrees, between the driver’s field of view and the light source.” Thus, a conservative evaluation occurs where the Project Sign is visible within the centerline of the driver’s field of view, the angle noted above within the field of view is 0, the surrounding surface luminance is less than 10 fL, and the maximum allowable luminance is 500 fL. Therefore, the most conservative condition at night or at twilight evaluates the Project Sign maximum luminance against the maximum luminance threshold of 500 fL as defined by CVC Section 21466.5.
a. Roadway Glare During Night
A measured brightness within the driver’s field of view of less than 10 fL generally occurs at night. The maximum Project Sign luminance during night is 300 cd/m2
. Calculating the equivalent maximum luminance by converting to english units from metric units: 300 cd/m2 equals 87.6 fL. Because the Project Sign is proposed to be limited to a maximum night time luminance of 300 cd/m2
, or 87.6 fL, the Project Sign maximum luminance will not exceed 87.6 fL, which is 35% of the 500 fL maximum, the most conservative limit stipulated by the CVC for conditions where the minimum brightness in the driver’s field of view is less than 10 fL. Therefore, at night the Project Sign within the drivers field of view will not exceed the 500 fL threshold and will not introduce a new source of glare as defined by CVC Section 21466.5.

For Project Sign views located beyond the driver’s 10 degree field of view, the maximum luminance is permitted to increase under the CVC. For example, light sources located 15 degrees from the centerline of the driver’s field of view would be limited to a maximum of 1,000 fL (500 fL plus 100 times the angle (5 degrees) = 1,000 fL). The maximum Project Sign luminance is 300 cd/m2 or 87.6 fL at night, or less than approximately 17.4 % of the maximum allowed by the CVC for those Project Sign locations at 15 degrees from the center of the driver’s field of view. Therefore, at night the Project Sign beyond the drivers 10 degree field of view will not exceed the 1000 fL threshold and will not introduce a new source of glare as defined by CVC Section 21466.5. 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 79

b. Roadway Glare During Twilight
The Project is also evaluated during twilight (the transition period from day to night, from sunset to 45 minutes after sunset, and night to day, from 45 minutes before sunrise to sunrise). Sunlight increases gradually from the minimum brightness at sunrise to maximum brightness at mid-day, and then decreases gradually to the minimum brightness at sunset. Therefore, the minimum ambient sunlight occurs after sunset or before sunrise. However, in order to analyze the most conservative, low level sunlight conditions, this analysis adjusts the time frame for the minimum ambient luminance condition of 10 fL to sunset and at sunrise, extending the duration of minimum sunlight. At sunset the ambient sunlight will be greater than the minimum values after sunset during twilight, and at sunrise the luminance will be greater than the minimum during the time preceding sunrise. At sunset or sunrise, the minimum luminance values within the driver’s field of view will be above the minimum night time values (10fL) due to the light from the setting or rising sun. However, to maintain a conservative analysis, this evaluation assumes the minimum luminance within the driver’s field of view will be less than 10 fL from sunset until sunrise. Therefore, for this Study the maximum luminance permitted by the CVC during twilight will remain at 500 fL. The maximum luminance permitted by the CVC is 500 fL, which converting to metric units from english units, equals 1579 cd/m2 . The CVC maximum luminance is far
greater than the proposed Project Sign luminance of 300 cd/m2 . The Project Sign will not exceed the threshold
established by the CVC of 500 fL (1579 cd/m2
) during twilight. Therefore, the Project will not introduce a new source of glare during twilight.

The Project is designed to operate at 300 candelas/m2 (87.6 fL) maximum luminance, from sunset to 10 pm, and at 200 candelas/m2 maximum luminance from 10 pm to 1 am. Signs must be turned off between 1 am and sunrise. At 45 minutes prior to sunset the Project Signs are specified to begin transition from the maximum daytime luminance of 6,000 cd/m2 to the maximum evening luminance of 300 candelas/m2 . This transition must be completed no later than
sunset to avoid potential high contrast, glare conditions. Additionally, the Project Signs may not operate prior to sunrise and must adhere to the day maximum luminance of 6,000 cd/m2 , beginning no earlier than 45 minutes after
sunrise with a smooth transition no less than 45 minutes. Therefore, the Project Sign will not exceed a maximum luminance from sunset to sunrise, which converts to a maxmum of 87.6 fL, less than the maximum permitted luminance of 500 fL. Thus, the Project will not exceed the threshold of 500 fL, and will therefore not introduce a new source of glare during twilight.
c. Roadway Glare During Day
The evaluation of the Project Sign during the day (45 minutes after sunrise until 45 minutes before sunset) compares the daytime, ambient brightness to the maximum sign brightness stipulated by the CVC during full sun conditions and overcast sky conditions. The CVC, Section 21466.5 referenced above, permits the Project Sign to "generate light intensity levels greater than 1,000 times the minimum measured brightness in the driver’s field of view, except when the minimum values are less than 10 (fL).”
During the day (45 minutes after sunrise until 45 minutes before sunset) sunlight with clear sky conditions or light overcast conditions provides sufficient illuminance to generate surface brightness greater than 10 fL and up to 1200 fL on the least reflective surfaces, such as roadway pavement. Utilizing the value of 10 fL as the minimum within the driver’s field of view, the maximum allowable brightness would be 1,000 times 10 fL, or 10,000 fL. Because the Project Signs would be, as a Project Design Feature, limited to a maximum luminence of 6,000 cd/m2 (1,751 fL) during the daytime hours of operation, the Project Sign will not exceed 6,000 cd/m2 (1,751 fL) during the day, and Project Sign will therefore operate at less than 18% of the maximum luminance stipulated by the CVC. Therefore, the Project will not create a new source of glare during day time hours of operation with clear sky or light overcast conditions.

Severe storms, heavy cloud cover, or other atmospheric conditions may occur during the day, which may cause the minimum brightness within the driver’s field of view to be less than 10 fL. The Project Signs are proposed to include photocell control system to reduce the sign luminance from 6,000 cd/m2 (1,751 fL) to 300 candelas/m2 (87.6 fL) 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 80

maximum when the ambient sun light falls to illuminance values similar to night, less than 100 fc. During the day, when storms, cloud cover, or other low ambient sunlight conditions occur and when the ambient sunlight is less than 100 fc, the Project Sign will transition from the daytime 6,000 cd/m2 (1,751 fL) to 300 candelas/m2 (87.6 fL) maximum, and thereby ensure that the sign brightness remains less than the maximum brightness stipulated by the CVC.

Therefore, the Project Sign will not create a new source of glare during day time periods with storm or severe overcast weather conditions and will not exceed 87.6 fL, or 35% of the 500 fL maximum allowed by the CVC during overcast conditions.

The Project Sign is designed to not exceed 300 candelas/m2 (87.6 fL) luminance at evening, twilight, or during overcast sky conditions, and the Project Sign will not exceed 6,000 cd/m2 (1,751 fL) during the day. The Project Sign luminance is thus less than the CVC standard, including 18% of the maximum allowable luminance identified as the threshold for glare during the day. Therefore the Project Sign will not create a new source of glare.

9. CONCLUSIONS
This Study confirms that the light resulting from Project Signs will be less than the significance thresholds defined by the District at 3.0 fc for existing residential use properties within the District. Light trespass impacts will be less than 1.4 fc for existing residential use properties outside of the District. Furthermore, at all existing residential use properties, the Project Signs maximum luminace will be less than 30 to 1 contrast ratio. Therefore, there is no impact from the Project Signs at surrounding sensitive use properties in proximity to the Project. Light intensity degrades exponentially with distance. Therefore, sensitive use properties which are more distant than the locations analyzed in this Study will receive substantially less light from the Project Signs. Therefore, there is no significant impact from the Project Signs at sensitive use properties. In addition, the light from Project Signs will not exceed the maximum defined by the California Vehicle Code, and there is no significant impact from the Project Signs with respect to driver’s glare. 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 81

10. LIGHTING GLOSSARY
Discussions of lighting issues include precise definitions, descriptions or terminology of the specific lighting technical parameters. The following glossary summarizes explanations of the technical lighting terms utilized in this Study and the related practice standards. The following technical terms are used in this Study.

Brightness: The magnitude of sensation that results from viewing surfaces from which light comes to the eye. This sensation is determined partly by the measurable luminance of the source and partly by the conditions of observation (Context), such as the state of adaptation of the eye. For example, very bright lamps at night appear dim during the day, because the eye adapts to the higher brightness of daylight.

BUG Rating: A luminaire classification system established in IES TM15-11, BUG Ratings Addendum that provides for uniform assessment of the directional characteristics of illumination for exterior area lighting. BUG is an acronym composed of Backlight, Up light, and Glare. BUG ratings are based on a zonal lumen calculation for secondary solid angles defined in IES TM15-11.

Candela: Measure of light energy from a source at a specific standard angle and distance.

Candela (cd) is a convenient measure to evaluate output of light from a lamp or light fixture in terms of both the intensity of light and the direction of travel of the light energy away from the source.

Contrast: Calculated evaluation of high, medium and low contrast of visible light sources or surfaces within the Property by a ratio of luminance. Contrast is the ratio of one surface luminance to a second surface luminance or to the field of view. Contrast exceeding 30 to 1 are usually deemed uncomfortable; 10 to 1 are clearly visible; and less than 3 to 1 appear to be equal.

Electronic Control System: Integrated hardware and software system which provides sign lighting control functionality for time-of-day scheduling, response to ambient light, and direct user control with full range of dimming from 0% to 100% full light output, full color, or all white.

Fully Shielded: A lighting fixture constructed in such a manner that all light emitted by the fixture, either directly from the lamp or a diffusing element, or indirectly by reflection or refraction from any part of the Luminaire, is projected below the horizontal as determined by photometric test or certified by the manufacturer. Any structural part of the light fixture providing this shielding must be permanently affixed. In other words, no light shines above the horizontal from any part of the fixture.

Glare: Glare is visual discomfort experienced from high luminance or high range of luminance. For exterior environments at night, glare occurs when the range of luminance in a visual field is too large. The light energy incident at a point is measured by a scale of footcandles or lux and is described in the technical term Illuminance.

This incident light is not visible to the eye until it is reflected from a surface, such as pavement, wall, dust in the atmosphere or the surface of a light bulb. The visible brightness of a surface is measured in footlamberts (or metric equivalent candelas per square meter) and is described by the term Luminance. 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 82

The human eye processes brightness variations across a very broad spectrum of intensities. The range of brightness generated by direct noon sun versus a moonlight evening is over 5000 to 1. Human eyes are capable of accommodating to this range of intensities given adequate time to adjust. However, the eye cannot process brightness ratios of more than 30 to 1 within a view without discomfort. See IESNA 10th Edition Handbook, Section 4.10.1, Discomfort Glare and Section 10.9.2 Calculating Glare.

For the purpose of this analysis, brightness of light sources may be described subjectively by the following criteria:

High Contrast Conditions: View of light fixture emitting surface, such as a lens, reflector, or lamp, where brightness contrast ratio exceeds 30 to 1 (source Luminance to background Luminance ratio).

Medium Contrast Conditions: Brightly lighted surfaces where contrast ratio exceeds 10 to 1 but is less than 30 to 1 (source Luminance to background Luminance ratio).

Low Contrast Conditions: Illuminated surfaces where contrast ratio is less than 10 to 1 (source Luminance to background Luminance ratio
Illuminance: Illuminance is the means of evaluating the density of Luminous Flux. Illuminance indicates the amount of Luminous Flux from a light source falling on a given area (See Figure 68). Illuminance is measured in footcandles (fc) which is the lumens per square foot, or Lux (lumens per square meter). Illuminance need not necessarily be related to a real surface since it may be measured at any point within a space. Illuminance is determined from the Luminous intensity of the light source. Illuminance of a point source decreases with the square of the distance from the light source (see Inverse Square Law definition).

For the purposes of this analysis, illuminance may be described subjectively by the following criteria:

Figure 68: Diagram of Illuminance
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 83

Horizontal Illuminance: Illuminance incident upon a horizontal plane. The orientation of the illuminance meter or calculation point will be 180° from Nadir.

Vertical Illuminance: Illuminance incident upon a vertical plane. The orientation of the illuminance meter or calculation point will be 90° from Nadir.

Inverse Square Law: In physics, an inverse-square law is any physical law stating that a specified physical quantity or intensity is inversely proportional to the square of the distance from the source of that physical quantity. The fundamental cause for this relationship can be understood as geometric dilution corresponding to point-source radiation into threedimensional space (see Figure 69). The divergence of a vector field which is the resultant of radial inverse-square law fields with respect to one or more sources is everywhere proportional to the strength of the local sources, and hence zero outside sources. Newton's law of universal gravitation follows an inverse-square law, as do the effects of electric, magnetic, light, sound, and radiation phenomena. Thus, Illuminance decreases with the square of the distance from the light source.

Output Direction: Luminaires for general lighting are classified in accordance with the percentages of total luminaire output emitted above and below horizontal. The light distribution curves may take many forms within the limits of upward and downward distribution, depending upon the type of light and the design of the luminaire.

Lighting Array: An installation of multiple light sources or lamps where the distance between each lamp or light source within the Lighting Array is less than 5 feet on center in any direction from any other source.

Light Source: Device which emits light energy from an electric power source.

Light Trespass: Electric light from subject property incident onto nearby properties, measured in footcandles or lux, usually analyzed by measurement at or near the nearby property line.

Figure 69: Inverse square law diagram (hyperphysics.phy-ast.gsu.edu) 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 84

Lighting Zone (LZ): Defined by IESNA and summarized on pages 10 and 11 in the LP-11-20 Environmental Considerations for Outdoor Lighting and adopted by CALGreen.

Lighting Zone LZ3: Outdoor areas of human activity where the vision of human residents and users is adapted to moderately high light levels. Lighting is generally desired for safety, security and/or convenience.

Luminaire: A complete lighting unit consisting of a light source together with the parts designed to distribute the light, to position and protect the light source, and to connect the light source to the power supply. Also referred to as a Light Fixture.

Luminance: Luminance is a measure of emissive or reflected light from a specific surface in a specific direction over a standard area (See Figure 70). Luminance is measured in footlamberts (fL) (1/π Candela per square foot) or cd/m2 (Candela per square meter). 1fL = 3.43 cd/m2
.

Whereas Illuminance indicates the amount of Luminous Flux falling on a given surface, Luminance describes the brightness of an illuminated or luminous surface.

Luminance is defined as the ratio of luminous intensity of a surface (Candela) to the projected area of this surface (m2 or ft2
).

Luminous Flux: Mean value of total Candelas produced by a light source. Luminous Flux describes the total amount of light emitted by a light source. The unit for measuring Luminous Flux is Lumen (lm).

This radiation could basically be measured or expressed in watts. This does not, however, describe the optical effect of a light source adequately, since the varying spectral sensitivity of the eye is not taken into account. To include the spectral sensitivity of the eye the Luminous Flux is measured in lumen. Radiant Flux or 1 W emitted at the peak of the spectral sensitivity (in the photopic range at 555 Figure 70: Diagram of Luminance
251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 85

nanometers produces a Luminous Flux of 683 lumen). The unit of lumen does not define direction.

Monitoring Sites: Monitoring Sites are locations selected for observation and field lighting measurements to evaluate the views to the Project Site from nearby sensitive use properties and to determine the extent and intensity of existing light sources within and surrounding the Project Site. The Monitoring Sites are within the public right of way or Project Site, and may be in proximity to sensitive use sites. These locations are representative of the view to the Project from the vicinity of the sensitive sites surrounding the Project Site to the north, south, east and west. Figure 4 below illustrates the Monitoring Site locations.
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APPENDIX A: CONCEPTUAL SIGN PLANS
Digital Display at 1202 3rd Street Promenade
Digital Display at 301 Arizona Avenue
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Digital Display A at 4th Street/Colorado Avenue - Santa Monica Place Digital Display B at 4th Street/Broadway –Santa Monica Place 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 88

Digital Display C at 2nd Street/Broadway – Santa Monica Place Digital Display D at 3rd Street/Broadway
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Digital Display at 1301 3rd Street
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APPENDIX B: LIGHT TRESPASS ILLUMINANCE CALCULATION DATA 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 91

APPENDIX C: IESNA LP-11-20, 4.1 Lighting Zone Definitions 251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 92

251030 SM010_Santa Monica Sign Ordinance Study_Final December 8, 2025 page 93

APPENDIX D: IESNA RP-8-22 Table 4-2