ENCLOSURES

  Response to Living Places, Powers, Rights, Responsibilities: Section F4, Dealing with nuisance lighting (not printed). Letter to Homebase on domestic security lighting (not printed) and the response from Micromark (Annex).

  I suggest that you read the two enclosures now to gain an understanding of where I am coming from on this issue. The first was forwarded to DEFRA in February and I see no reason to change it. As you may not have seen this I have enclosed a copy. The second was a letter that I compiled to draw Homebase (diy store) attention to the poor quality/non existence information on domestic security lighting products on sale in its stores. Homebase did not reply. Three months later, I did receive the response from Micromark, one of Homebase's suppliers. While it contains good information with suggested changes, none appear to have been implemented. If anything, the Homebase situation has worsened as a result of Homebase now filling its shelves with its own brand 150/500W symmetrical floodlights. You will not be too surprised to be informed that the packaging shows the floodlights screwed to a brick wall and pointing horizontally. It is possible that Homebase was already committed contractually to this and was in no position to change in the short term. An acknowledgement letter would nevertheless have been polite.

  The two enclosures hopefully inform you of my concern that artificial night lighting is having on our views of the night sky (we are all astronomers) and the impact on wildlife. Recent news also informs us that prolonged exposure to artificial light, particularly for nightshift works, can lead to cancer in humans. The recommendation here is to sleep in a dark bedroom, if possible.

  Ever since the solar system formed over four billion years ago, the only light shining on this planet at night has been sunlight reflected from the surface of the moon and starlight. Our wildlife has survived over hundreds of millions of years in responses to these low light levels at night, until recently. Artificial light is totally alien to this planet and must be used sparingly, wisely and cautiously. As with all things human, we seem to have to go too far to know how far to go.

  The biggest contribution to light pollution comes from orange (low-pressure sodium) streetlights. Small amounts of this narrow spectra light is acceptable to astronomers, as it can be filtered to reduce information loss and by lepidopterists as moths are less attracted to this light. However, the upward light spillage from these streetlights has totally ruined our naked eye views of the night sky.

  The sideways and upward light spillage from these lights adversely affects wetland ecosystems. The Yorkshire Dales National Park is no longer dark at night thanks to the orange streetlights of Darlington, 30 miles away. I walked home from a party in the early hours recently, choosing to take the footpath through the wood and across the fields. The stars were out but there was no moon, yet I had no difficulty in seeing my way even through the wood. The giant sky glow of Reading was sufficient to illuminate the fields and the woods. I wonder how much this lack of darkness at night is benefiting criminals.

  It is a simple observation that the street is vertically below the light and that Full Cut-Off streetlights are the obvious and only choice. Unfortunately, some Highways Agency lighting engineers still install low pressure sodium lights with their poor light control and high pressure sodium lights with large deflecting bowls beneath them which do exactly that, bounce the light horizontally and upwards. In rural areas, these lights are visible horizontally as far as the curvature of the earth allows. In some, but not all, cases professionally paid lighting engineers are not doing a responsible job to address light pollution issues and the effect on wildlife. A central government directive to all Highway Agency lighting engineers that only FCO streetlights must in future be used is necessary, with immediate effect. In rural areas, the backward spillage of light onto trees, hedgerows, ditches etc must be prevented by shielding to protect wildlife. They should also be asked to produce a timescale plan of streetlight replacement to FCO lights only.

  Another issue on streetlights needs to be considered. Where streetlights have failed either individually or as a block, they are not missed in some cases. This implies that they are either unnecessary or too bright. While the lighting of roundabouts and road junctions may be considered necessary for safety reasons, is ribbon street lighting in rural areas really justified? Lighting levels were established many years ago when vehicle headlights were poor in comparison to today's standard and windscreen washers were non-existent. Is it now not time to review the need for streetlights and the current level of brightness? If you cannot drive without streetlights you should give serious consideration to giving up driving.

  Other light pollution sources are unfortunately on the increase. This includes poor quality security lighting in car parks, commercial premises, domestic security lighting, sports pitches, and the floodlighting of buildings including churches. Unnecessary lighting, such as the floodlighting of trees and garden lights are all on the increase. The evidence suggests that the industry supplying the lights doesn't care (see the second enclosure) and is unwilling to change. Only in Areas of Outstanding Natural Beauty (AONB) is there some evidence of rejection of lighting.

  One cause for much poor sports pitch and security light can be found ironically in the Institution of Lighting Engineers (ILE) own Guidance Notes for the Reduction of Light Pollution, section A4 (not printed).

  Symmetrical floodlights with up to a 900 wide angled main beam must have their centreline at 450 to the vertical to prevent light spillage above the horizon, not 700 and point down much steeper than this to contain the light to within the property boundary. The ILE tell me that this section is aimed at narrow beam sport pitch lights. While this may be true, it clearly states all lights and has in my opinion been the prime reason why so many floodlights are poorly aimed. They all have this 700 property that is mathematically unsound.

  Clearly, existing legislation is having only marginal effect. There is a need, therefore, for legislation to not only prevent further poor lighting from being installed but to also encourage existing poor lighting to either be removed or replaced by responsible lighting. From a wildlife point of view, the only light that benefits wildlife is no light.

  Since the industry in the main has failed to rise to the challenge, there is a need for legislation to define lighting standards. Many porch lights, for example, waste a high percentage of light by shining upwards and those with embedded PIR controls that cannot be adjusted, spring into life when people pass by on a public right of way called the pavement or drive past in a car. Legislation is necessary to ensure that porch lights have a negative ULR and a PIR controller that can rotate on a horizontal axis to reduce sensitivity thereby preventing nuisance switching. Information on how to adjust the sensitivity of the PIR controller and check it's functioning will be necessary. This approach readily extends itself to domestic security lighting. Symmetrical floodlights have poor light control and should be banned. Asymmetric lights installed at a sensible height (3m) will light from above and not from the side (see Astrica model) and not shine into peoples' bedrooms. Adjustable PIR controllers with quality information should ensure quality installation. The ILE has already established that 150W is more than enough. Commercial security floodlights follow a similar argument. The use of symmetrical floodlights is the big cause of light pollution so banning their use is the obvious step. Large area car parks use FCO lighting so why not commercial premises? Globe lights have a ULR in excess of 50% and should also be banned. I may appear to be doing a lot of "banning" but I do so because alternative lighting with good light control is readily available. All I am proposing is the removal of the "bad apples" from the bag.

  Building floodlighting is also an increasing source of light pollution, particularly when they shine upwards. All lighting should be downward directed. Pub lighting is also essentially a free for all. One pub installs big bright lights, presumably in the mistaken belief that more lights means more customers and others follow suit. The result is more big bright lights, more energy waste, more light pollution and no more customers. Multi-coloured lights are also being used to attempt to attract more custom. Unfortunately, these lights do more to ruin any architectural merit that selective lighting may draw out. Pub garden lights are also usually poor. No one sits in the garden at night in the winter, so why are the lights on? Some pubs even turn on their exterior lights all day long, a rather selfish and unnecessary waste of energy. Churches, particularly in rural areas are a serious source of light pollution due to the upward direction of the lights. "To harm nature is to harm God", says a speaker on the Radio 4 program "Thought for the day". But that is exactly what church floodlights are doing. More and more people are pointing floodlights back at their own houses, floodlighting trees, and using various methods of illuminating gate posts et al.

  Ten years ago and for over four billion years before that, none of this lighting existed, so why is it necessary now? There was no pub lighting, no church lighting and definitely no garden lights. There was, therefore, no need for legislation to prevent lighting that did not exist. There is a need now. Light Pollution, whatever the source, is a very serious issue. Not only have we ruined the naked eye view of the spectacular night sky white with starlight and with little chance these days of ever seeing the Milky Way, our own spiral galaxy, we are also imposing a serious threat to wildlife both from light pollution and the existence of lighting. Central government has a key role to play in providing legislation to prevent further poor lights from being installed and is in a position to lay down measures for responsible lighting for streets, sports pitches, car parks, security etc. Education, while this is an important part of the process, before legislation does not appear to be working although it can work with legislation in the future to create change.