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HomeMy WebLinkAbout1-29-2020 Public Comment - M. Baker - Street LightsJanuary 29, 2020 Dear Bozeman City Council, We read the story about your decision to address the issue of high glare streetlights. https://nbcmontana.com/news/local/bozeman-leaders-address-bright-streetlight-issue We also carefully reviewed the presentation by City Engineer Shawn Kohtz. http://weblink.bozeman.net/WebLink8/0/doc/204317/Electronic.aspx So many cities, especially early adopters, have now come to realize that, along with energy savings, outdoor LED lighting came with a significant number of dangerous health effects. We are happy to see Bozeman taking the time to revisit the LED lighting situation. Soft Lights is an advocacy group focused on educating decision makers about the emotional harm and eye damage caused by high energy LED lights, with a goal of convincing the decision makers to install soft, pleasant lighting that is safe for humans and the ecosystem. While LED lights have advantages, there are also serious health problems associated with LED and with over-lighting. Scientists have shown that artificial light at night has increased the risk of breast cancer by as high as 33%. Artificial light at night is also causing sleep disorders and severely impacting the ability of wildlife to succeed. Studies have shown that bright lights do not reduce crime. Overall light pollution across the planet has been increasing at an unsustainable rate of 2% per year. The report by Mr. Kohtz is well done and makes many good recommendations. However, there are still some items that we would like to address. Light Sensitivity Disabilities People with light sensitivities have strong connections to color temperature, flicker and brightness. This group includes people with photophobia, autism, PTSD, epilepsy, bipolar disorder, highly sensitive persons, migraine sufferers those with lupus, low vision and blindness. Often, cities have forgotten to reach out to these groups to determine their outdoor lighting needs. The Americans with Disabilities Act requires that governments accommodate those with disabilities, which includes light sensitivity disabilities. We know, for example, that high color temperature causes deep emotional angst in highly sensitive persons. So, besides the issue of glare, light sensitive disabled persons have feelings of anger, agitation, depression and anxiety caused by the blue spike of high color temperature LED lights. Another aspect of LED light is sub-sensory flicker. The electronic drivers for LED lights come in varying quality. Low quality drivers produce sub-sensory flicker that can be seen by some people, which, of course, is debilitating. Therefore, it is critical that your manufacturer guarantee no sub-sensory flicker. Therefore, before choosing a lighting solution, we urge the council to ensure that the selected outdoor lights do not harm those with disabilities. Careful attention to this matter now should help prevent ADA lawsuits in the future. Amber Color Temperature In 2016, the American Medical Association released their report on LED streetlights. That report specified a maximum of 3000K color temperature to protect human health. However, in the years since that report, numerous studies have shown how dangerous blue light really is. Dr. Mario Motta is a cardiologist and trustee with the American Medical Association, who co-authored the 2016 AMA report on LED lights. Based on this additional research, Dr. Motta now recommends that cities install LED lights using a color temperature that is as low as possible. Our own experiences have shown us that 2700K is the maximum comfortable color temperature. As noted in Mr. Kohtz’ report, HPS produced light in the 1900 to 2100K range. This is a very good color temperature for nighttime. The HPS light evokes pleasing and calming emotions that should be associated with nighttime. Now that engineers have invented 1700K and 2200K LED streetlights that have the same energy efficiencies as 4000K, there is no reason to use a high color temperature for residential areas. Soft Lights does not promote any particular lighting manufacturer. However, we have recently learned that Crossroads LED has invented a 2200K streetlight with internal diffusion and a CRI exceeding 90 that we believe is worth investigating. Another manufacturer that makes 2200K amber is Lumican. We recommend the following maximums for color temperature: 2700K for business districts, 2200K for residential and 1700K for sensitive areas. Never exceed 2700K, even for major streets and freeways, because there is no benefit to using a higher CCT, only more harm. Overall Light Pollution As part of this current process to modify your existing outdoor lighting, we recommend that the Bozeman council set a maximum of Class 3 on the Bortle scale of light pollution for the central part of the city, and a maximum of Class 2 for the outer areas. By setting an overall light pollution goal, Bozeman can limit overall light pollution from government, business and residential installations. The council should make it a stated goal that they intend to restore the million billion stars to the nighttime sky for all Bozeman residents. We believe that viewing those stars is a fundamental human right. Humans need quality sleep to maintain health. Wildlife needs darkness in order to navigate and forage for food. Our entire ecosystem and circadian rhythms are based upon the day/night cycle. We must be extremely cautious when adding artificial light into the nighttime environment. As such, lighting should be severely dimmed or completely turned off late at night. Safety It is very important to clearly understand the word “safety” when associated with lighting. There is a widely held misconception that brighter lights equals more safety, in terms of crime or visibility. The fact is that “safety’ is a complicated topic, not answered by simply adding more and brighter light. Crime is not affected by light, but rather by time of day. Therefore, when we speak of safety, we should focus our efforts on visibility and health. The enemy of visibility is glare. Glare is caused by high energy blue wavelengths. The higher the color temperature, the more blue light and glare, which results in decreased vision and less safety. The human health effects and ecosystem damage caused by artificial light at night means that our safety is reduced when we think in terms of long-term health. Since multiple studies have shown that artificial light at night greatly increases risks of breast cancer, diabetes, sleep disorders and mood disorders, then our safety is compromised by using artificial light at night. Other Lighting Issues • Most new cars now have Automated Braking Systems and by 2022, all new cars with come equipped with this feature. In our opinion, this means that we no longer need to light the actual roadway where cars drive. This area will be lit by car headlights and the car will “see” using other sensors. Eliminating glare from streetlights will improve driver and pedestrian safety. We believe that cities should consider removing the tall streetlight poles and replacing them with 3-foot-tall bollards that light only pedestrian walkways and bike paths with soft light. • Human eyes have cones, rods and ganglion photoreceptor cells. Each cell type performs a different function for daylight, darkness and circadian rhythm. The eye and brain form a highly tuned system based on the natural cycle of day and night. When we add artificial light at night, we should weigh the damage caused by the artificial light against the benefit of doing so. When it is determined that artificial light is truly necessary, we should use the lowest possible brightness so that the eye and brain can be relaxed and performing at a high level. Using brightness levels as low as 20 lumens is not out of the question. • LED Billboards direct high energy light directly into our eyes. This causes glare and distraction. In addition, we believe that this violates our 14th amendment right to liberty. We believe that LED billboards have no place in a civil society and should be banned completely. • Strobing LED lights have suddenly appeared on utility trucks, police cars, stop signs, radio towers, garbage trucks and many other places. Unfortunately, nobody seems to have studied the effects of strobe lights, especially on those with light sensitivity disabilities. We know that strobing LED lights cause significant emotional harm to many and possible permanent eye damage. We also know that these strobing LED lights are a significant driver distraction that endangers safety workers, pedestrians and drivers. We urge the council to ban all strobing LED lights and to use softer, safer solutions. Publications We recommend that city follow the roadway lighting recommendations from the Illuminating Engineering Society RP-8-18 https://www.ies.org/product/american-national-standard-practice-for-design-and- maintenance-of-roadway-and-parking-facility-lighting/ Also, the European Union has an extensive report on roadway lighting. https://publications.jrc.ec.europa.eu/repository/bitstream/JRC115406/jrc115406_eugpp_road_lighting _technical_report_1.pdf Thank you for considering this information as you make your decisions regarding street lighting in Bozeman. Sincerely, Mark Baker mbaker@softlights.org Soft Lights www.softlights.org