What’s Missing? Only the Key To Success
What is “success” for the city streetlamp replacement project? How does “success” inform the choice of luminaires for the project? In early March one of us began a search for documents describing both of these. In April, Director Wheeler repeatedly said these documents exist and promised to provide them, but never did. In response to a public records (IPRA) request, the city found no project requirements, luminaire specifications, and no evaluation of luminaires against specifications. This note describes the significance of that finding and the search leading up to it.
Project Requirements, Project Specifications, and Why You Should Care
Project requirements are nothing more than the list of expected project outcomes. Absent a clear understanding of expectations, engineers can’t design a solution that will meet expectations. In a large and complex project with many stakeholders and many different expectations for success, absence of projects requirements is an all-but-certain guarantee that one or more important expectation will fail to be met, leading to outright project failure and requiring significant additional time and expense to repair.
Project requirements define the “problem” the project exists to “solve.” In the case of the streetlight project, they lead to specifications on the luminaires. Every project requirement leads to one or more technical specifications that acceptable luminaires must satisfy for the project to succeed; and, every project specification should trace back to a project requirement. For example, if street lighting project success means a certain energy savings, then the luminaires will need to have a certain minimum efficiency. That minimum efficiency is a specification. And, if project success requires a certain savings in maintenance costs, the luminaires will need to have a certain reliability: another specification. And so on.
Specifications that are not traceable to requirements make it harder – sometimes even impossible – for the project to succeed. A specification that does not match-up with a requirement is an artificial constraint that reduces the flexibility needed to help the project succeed.
If they exist at all, project requirements and specifications must exist in written form. Otherwise they cannot be applied uniformly and without risk that the “solution” will mistakenly overlook an important requirement or specification in some cases, leading to an outcome that does not meet its needs; or, over or incorrectly apply them in others, denying the city an outcome that meets its needs at lower cost or greater benefit.
The bigger the project – in cost, in complexity, in effect, in number and kind of stakeholders and stakeholder expectations – the more important it is that the project have clear requirements and that the solution not be subject to artificial constraints that do not derive from those requirements.
After an extended search for project requirements or luminaire specifications, on March 15, 2021 Sam Finn wrote to the mayor and the councilors expressing concern over the apparent absence of either project requirements or luminaire specifications.
On April 15, Mr. Ollie Eisman wrote to Director Wheeler, asking after after any public documents that “shows the process of selecting the final LED streetlight design.” Director Wheeler wrote in reply
- There are project specifications, which can be provided on request.
- There are project requirements, which also can be provided on request.
- Luminaires have been vetted to meet all project requirements, including “community goals and regulations.”
- All luminaires “far exceed all dark sky regulations with full cutoff shielding and other state of the art features that protect wildlife, health, safety and reliability.”
- Public Works had evaluated many luminaires, but had not identified any 2200 K fixtures that meets all project specifications.
(It is perhaps worth noting at this point that the “requirement” that the street light replacement project put the city on-track for Dark Sky Community designation was barely a month old (if that), and that the community advisory panel had met for its first time only 1.5 days earlier, on the evening of 13 April.)
On the same day, Mr. Eisman replied asking Director Wheeler for the documents she offered to provide. He also asked what project needs precluded the use of 2200 K luminaires. Director Wheeler did not respond to request for documents or the specific question regarding 2200 K luminaires.
Also on April 15 and following up on Mr. Eisman’s request, Sam Finn reminded Director Wheeler, with a CC to Dalkia Project Expeditor Ernst, of his earlier request for requirements and specifications and asked that she provide these. Neither Director Wheeler nor Project Expeditor Ernst responded.
On April 22 Mr. Eisman wrote to Director Wheeler again, noting it has been a week since the her offer to share details of LED street light specifications. He asked when they will be available. Wheeler responded
- The package of specs is getting very close to ready to release to post on the project website and provide to you.
- Public Works over the last 2 months has been evaluating additional fixtures that meet the city’s goal of being a dark sky community while meeting regulations and project specs.
Again following up on Mr. Eisman’s note, Sam Finn wrote Director Wheeler noting that project requirements and luminaire specifications, if they exist at all, must exist in written form. He asked for those documents. Director Wheeler responded, as before, that “the package of specs is getting very close to ready to release to post on the project website and provide to you.”
IPRA Request and Documents Provided in Response
When it became clear that the requested documents would not be forthcoming, Sam Finn filed an IPRA request with the city of Santa Fe. You can read the the request here. In summary, three types of documents were requested:
- Project requirements and documents related to project requirements for the city’s street light replacement project;
- Luminaire specifications and documents related to specifications used to evaluate the suitability of luminaires for use in the project;
- Documents related to all specific luminaires selected, rejected, or under consideration for use in the city’s project.
The IPRA request was filed on April 23, 2021. On April 28 the city requested additional time – until May 7 – to satisfy the request. On May 7 the city provided 14 documents, declared the request satisfied, and closed the request.
Of the 14 documents provided in response to the IPRA request, none were either project requirement or project specifications documents.
One document returned in response to the request was §716 of the New Mexico Department of Transportation’s Standard Specifications for Highway and Bridge Construction. This NM DOT Standards Specifications identifies the standards that all luminaires placed on NM DOT roads must satisfy.
One document – the April 13 presentation made to the “Community-Guided Lighting Design Working Group” – included on one slide two bullets that might be related to project requirements; however, the bullets themselves were insufficiently detailed to identify an actual requirement and the presentation did not include anywhere a reference to actual project requirements.
Finally, one document provided was a spreadsheet listing a selection of 62 luminaires, their CCT, lumen output, power requirements, energy efficiency, light distribution pattern, BUG rating, warranty duration, and life expectancy. Some of these quantities are marked as estimated. No product specification sheets were provided in response to the IPRA request; so, it is unclear where the information in the spreadsheet – estimated or otherwise – came from. All the luminaires included in the spreadsheet have CCTs of either 2700 K, 3000 K, or 4000 K. No luminaires in the spreadsheet have a CCT of less than 2700 K.
In several different emails during the week April 15–22 Director Wheeler stated clearly and directly that
- there exist project requirements for the city streetlight replacement project
- there exist project-specific specifications for identifying luminaires that would satisfy the engineering solution proposed to meet the project requirements; and
- 2200 K CCT luminaires have been considered for use in the project but rejected on the basis of project specifications.
In response to the IPRA request, the city provided
- no project requirements;
- no project-specific luminaire specifications, whether traceable to project requirements or not; and
- no evidence that luminaires with CCT less than 2700 K have been considered by the Department of Public Works for use in the project.
Either Director Wheeler misspoke several times, in exactly the same way, in several different emails over a period of a week; or the Department of Public Works failed to satisfy the IPRA request for the documents.
Santa Fe’s streetlight replacement project is an expensive and complex undertaking. It is anticipated that it will take the city at least a half-dozen years to pay off its costs (though in the absence of a clear understanding of the project’s goals the reliability of that estimate is at best questionable). The choices made will affect the city ambience, city residents, and residents of the greater Santa Fe area, for the next generation. The lighting will affect city and area tourism, and home and business property values, for at least that long. There has been far too much misinformation disseminated about the lighting project, IES safety guidelines, and IDA policy by the Department of Public Works and by the contractor Dalkia. It is crucial that the Governing Body assert direct control over the community engagement process, have an honest and open conversation with the community to learn their desires and expectations for the street light replacement project, capture the results of that conversation in project requirements, and take the necessary steps to make sure that the project is carried out in a way that is most likely to meet all the stakeholder goals as articulated in those requirements. The best way – the only way – to achieve these goals is for the city to engage a licensed Professional Engineer, expert on matters of roadway lighting, whose sole interest is to assist the Governing Body in identifying its expectations for the street light replacement project, and providing expert advice to the City on how to meet those expectations.