The Institution have for over 75 years been active in the provision of education and information to our members and the public on all aspects of lighting and have been proactive in the publication of guidance to try and help reduce the impact of exterior lighting not only on astronomy but on the wider environmental issues.

  We have participated both nationally and internationally in conferences and seminars on this issue and associated issues. Indeed the Institutions "Guidance Notes for the Reduction of Light Pollution" have been copied and used world wide since they were first introduced over 10 years ago.

  The Institution has consulted with the County Surveyors' Society (CSS) and the Associate Parliamentary Lighting Group (APLG) on this submission and I am pleased to confirm the support and endorsement of both of these organisations to our submission.

1.  THE INSTITUTION OF LIGHTING ENGINEERS

  1.1  The Institution of Lighting Engineers (ILE) is the UK and Ireland's largest and most influential professional lighting association, dedicated solely to excellence in lighting. Founded in 1924 as the Association of Public Lighting Engineers, the ILE has evolved to include lighting designers, architects, consultants and engineers amongst its 2,500 strong membership.

  1.2  The key purpose of the ILE is to promote excellence in all forms of lighting. This includes interior, exterior, sports, road, flood, emergency, tunnel, security and festive lighting as well as design and consultancy services. The Institution is a registered charity, a limited company and a licensed body of the Engineering Council.

  1.3  The ILE has a very strong regional network covering the entire UK and Ireland. Regional meetings are held regularly around the two countries giving members a chance to see presentations on the latest issues in the lighting community. The ILE offers many other ways for members to keep their Continuous Professional Development up to date, by organising a wide range of conferences, seminars and courses. The ILE's annual conference goes from strength to strength with an increasing number of delegates attending each year to discover more about how to continuously achieve excellence in lighting.

  1.4  The ILE organises Total Lighting, the UK's premier and largest ever lighting exhibition. In addition to this the ILE has held a number of well supported one day Lighting Roadshows around the UK to promote its message.

  1.5  The "Lighting Journal", produced bi-monthly by the ILE, is widely acknowledged as the best lighting publication in either country. All members receive a free subscription to the "Lighting Journal" and the ILE also supplies the magazine to subscribers throughout the world. Other services available to members include access to the ILE's technical library and free technical advice from experts in each field of lighting. A wide range of technical publications are available.

  1.6  There is an old saying that people are only aware of lighting when it is not working. The ILE is dedicated to raising awareness about the important contribution of lighting to safety and efficiency in the office, the factory and on the road as well as its impact on crime prevention, commerce, health and the environment. Good lighting promotes a feeling of security and well being; bad lighting kills people, places and jobs. By targeting schools and colleges the ILE seeks to show how for relatively little financial outlay, the whole lifestyle of housing estates, town centres and industrial areas can be transformed to have a high profile visible impact on the quality of life for their inhabitants. The ILE has proven that tremendous improvements can be achieved at small cost. The Institution lobbies central and local government to this effect and seeks to raise public awareness particularly among the young about the crucial role of lighting in everyday life.

  1.7  By providing the best possible service to members, and consistently addressing the important issues within lighting, the Institution of Lighting Engineers proves time and again that it is indeed "The Independent Voice of the Lighting Profession".

2.  LIGHT POLLUTION AND ASTRONOMY

  2.1  Civilisation as we know it would not be able to survive without good lighting. This is especially true of outdoor pursuits that have so ceased with the onset of darkness. Our ability to provide cheap and economic lighting solutions has opened up our lives allowing use to carry on working during the hours of darkness, we can now attend or participate in many leisure pursuits including sports such as football, cricket and even horse racing which a few years ago were considered as daytime activities.

  2.2  National and international research has shown the many benefits that can be added to the safety, well being and comfort of the road user by the provision of a well designed, installed and maintained road lighting systems. Good road lighting can reduce night time accidents on traffic routes by a minimum of 30%. This principle is frequently used to demonstrate the benefit to the community as a whole of providing and maintaining road lighting by the reduction of night time accidents. By providing a safe and comfortable environment and extending the hours of use modern road lighting can substantially increases the capacity of a road, helping to reduce traffic congestion and reducing the requirement to provide additional road capacity.

  2.3  The provision of modern street lighting systems in residential areas helps reduce crime and the fear of crime. Recent research in this Country has demonstrated that the cost of providing, maintaining and operating a modern lighting system can be recouped by the community by reductions in crime in less than five years. Similar studies have also shown an increase in pedestrian movements during the hours of darkness engendered by an increased feeling of safety. This is especially true for women, old people and children.

  2.4  There is further evidence to show that good lighting including the skilful illumination of buildings, statues, trees and other prominent features in our towns and cities helps to increase their use during the hours of darkness by increasing commerce and reducing the dark deserted ghettoes many such areas have become.

  2.5  Good lighting helps people to work, travel and play in safety and comfort. The many benefits of good exterior lighting should not be forgotten when considering its environmental impact, however, there are many means by which this impact can be reduced, unfortunately many new lighting systems are still being designed and installed without due consideration of these requirements.

  2.6  To most people light pollution is the bright orange glow, seen over our towns and cities, and commonly referred to as Skyglow. This phenomenon is a serious problem to astronomers as the brightness of the sky overpowers distant stars, especially those low in the sky or just above the horizon.

  2.7  Lighting systems, especially road lighting, must be designed not only to provide the correct level of illumination but to also ensure that the illumination provided is uniform, reducing dark spots on the road where accidents may occur. Similarly a small amount of light is required to the surrounds of the area being lit to help provide a pleasant environment, increasing the security of pedestrians and to ensure that motorist see pedestrians or animals about to step on to the road. In residential streets home owners generally appreciate a small amount of illumination on the face of their properties as this increases the feeling of comfort and familiarity when walking down the street and provides easier access to their properties by illuminating the door and key hole.

  2.8  Skyglow is caused by light travelling through the atmosphere being refracted or scattered by water molecules and dust. This light is made up of two separate components:

(a)  the light radiated directly from the luminaire (light fitting), and

(b)  the light reflected back off the object being lit ie the ground, a building, a statue etc.

  2.9  Full cut-off luminaires (were no light is radiated above the horizontal and is generally more vertically) are often recommended by astronomers as the best way of ensuring no unwanted light is emitted into the night sky. The use of such luminaires would help to greatly reduce the direct component of light radiated into the sky. However, their use may have other detrimental effects on the environment due to their optical design. The severe restrictions on the distribution of light from a full cut-off road lighting luminaire generally results in the need to reduce the spacing between adjacent street lights to ensure the uniformity requirements of the lighting system are achieved. This reduction in spacing can result in an increase in the:

(a)  number of luminaires used to light a road or area,

(b)  level of illumination provided,

(c)  quantity of light reflected off the road and other surfaces into the sky,

(d)  energy consumed by the lighting,

(e)  quantity of greenhouse gasses produced,

(f)  increased capital, energy and maintenance costs.

  2.10  A recent study carried out in Belgium (Meta Analysis of Upward Flux from Functional Roadway Lighting Installations, see attachment No 1) clearly demonstrates that road lighting luminaires fitted with a shallow bowl (less than 60mm depth) can overcome many of these disadvantages due to the improved distribution of the light from the luminaire. Improved distribution of light can help to reduce the overall quantity of light reflected back into the sky. However, the general outcome of the study would suggest that each lighting system should be optimised to reduce light pollution as well as to produce the correct lighting parameters.

  2.11  The high levels of light emitted at high angles by deep bowl luminaires can give rise to visual intrusion in the form of a series of regular light spots on the skyline and can be a particularly problem for astronomers in the vicinity. Shallow bowl luminaires greatly reduce the effect and full cut-off luminaires almost eliminate it. Therefore, consideration should be given to the use of full cut-off road lighting luminaires to minimise visual intrusion in areas of intrinsically dark countryside with high amenity value such as National Parks or Areas of Special Scientific Amenity and in the vicinity of nationally and internationally recognised observatories.

  2.12  Over the last 10 to 15 years great efforts have been made by local authorities to control the effect of light pollution caused by road lighting and many fine examples of good road lighting producing little or no direct light pollution can now be seen. Unfortunately, much of the existing road lighting infrastructure in this country still uses low pressure sodium, high pressure mercury or tungsten light sources that are difficult to optically control resulting in unacceptable high levels of light pollution. In the 1994 Lamp Survey carried out by the CSS (1994 Lamp Survey—England, see attachment No 2) (not printed) 74% of the existing lighting stock comprised of such light sources. Whilst the quantities of such light sources will have been reduced over the last 10 years it is estimated that a simple replacement of the old inefficient and high polluting luminaires with modern better controlled and more efficient luminaires would result in a reduction of up to 20% in light pollution from these units.

  2.13  Much of the existing road lighting equipment in this country has reached the end of its life and is in urgent need of replacement. The opportunity should not be missed to ensure that any replacement lighting is correctly designed and due consideration is given to reducing the effects of light pollution. Unfortunately, limitations on local government finance are restricting such efforts and many lighting systems are still being replaced with poorly controlled luminaires, which will still be in operation and cause light pollution for many more years (the average life of a lighting installation is 30 years plus). Much more could be done if finances were made available.

  2.14  Many commercial developments in private ownership are blighted by globe or sphere luminaires used to illuminate car park and circulation areas, these luminaires, much loved by planners and architects, are some of the worst for causing light pollution and in many cases actually emit more light upwards than downwards. These luminaires should be re-designed to ensure that light is not emitted upwards. Fortunately, many of the owners of such equipment now recognise the need to control light pollution and are it with better optically controlled luminaires, however, much of this equipment is still in existence and in need of replacement.

  2.15  With people making more use of their leisure time and taking a greater interest in sport, existing sports and leisure facilities are being overstretched and alternatives are needed to meet the increasing demand. One way of achieving this is to extend the operating hours of the facilities by providing floodlighting for night-time use. Whilst such ideals can only be applauded one person's pleasure should not cause distress and annoyance to adjacent property owners. The careful design and use of better controlled luminaires for these installations can limit these problems; however, as these solutions are invariably more expensive to provide many facility owners will only provide them if required through the planning process. It is therefore essential that planning authorities review their role and produce supplementary planning guidance setting out their policies and requirements for the control of light pollution.

  2.16  It is now relatively easy and cheap to provide high lighting levels. The ease with which this can be done has in many cases led to lighting levels well in excess of those required to carry out the task safely and comfortably being provided. For instance it is not uncommon for small local recreational sports clubs to provide floodlighting installations to regional or national sporting requirements on the basis that they may require these levels sometime in the future. Indeed many grants for such systems are based on the provision of these standards as a minimum and take little or no account of the actual requirements and use of the club. This is not only wasteful in capital and operational costs but also increases the impact on the environment due to greenhouse gasses and light pollution. Further reductions in light pollution could be achieved by ensuring that only the correct level of illumination required to safely and comfortably carry out the task is provided.

  2.17  Whilst the Committees remit is to look at Light Pollution and Astronomy the related issue of obtrusive light must not be forgotten. Skyglow blocks out the view of the stars at night, however, obtrusive light can cause upset, anguish and distress to people. Obtrusive light is light that spills beyond the area being lit and because of its quantity, direction, movement or colour, gives rise to annoyance, discomfort and distraction or reduce the ability to see.

  2.18  Increasingly, environmental health officers and planning officers are receiving complaints from the public about the unacceptable effect of light on their lives. Many of these complaints concern light spill or light trespass caused by domestic security lights installed by neighbours. Most domestic security lights are not only badly designed, installed and directed but are far too powerful for the purpose (See attachment No 3). Especially irritating are domestic security lamps controlled by over sensitive or badly aimed infra red movement detectors, which continuously keep switching on as someone or something walks past the property. This constant switching on and off can cause great distress and anguish to adjacent property owners but can be easily be controlled by a little thought and consideration by the owner of the offending light. In many instances better domestic security lighting can be provided by the use of low wattage compact fluorescent luminaires which provide a gentler, more subdued and less glaring light and can be left running all night, if required, due to their low energy consumption.

  2.19  Whilst considering the impact of light pollution the effect of reducing the level of pollutants in the atmosphere such as particulates from car exhaust and factory/power station chimneys should not be forgotten. Indeed if there was no particulates in the atmosphere for the light to be reflected off there would be little or no Skyglow. This effect can be observed by the lack of Skyglow present on a clear night. However, this should not be taken as an excuse not to reduce the emission of light in to the sky but should be considered as a complimentary action to be used to help reduce light pollution.

  2.20  Lighting in itself is not a problem; it only becomes a problem where it is excessive, poorly designed, badly installed or poorly maintained.

3.  REPLIES TO SPECIFIC QUESTIONS

3.1  What has been the impact of light pollution on UK astronomy?

  This question is difficult to answer for a non astronomer; however, it is apparent that over the last 30 to 40 years the view of the stars not only from our towns and cities but also from the countryside has been greatly reduced. One only needs to travel to less industrialised, less populated and less polluted countries to see the difference in the night time sky. The orange glow over our towns and cities is a testament to our ability to provide lighting, unfortunately whilst doing so we have reduced and in many areas obliterated the beauty of the night sky.

3.2  Are current planning guidelines strong enough to protect light pollution?

  Current planning guidelines can affect light pollution in a number of ways:

(a)  Illuminated advertisements. Current planning guidelines can be used to control not only the size and location of illuminated advertisements but also the brightness of them. The Institution of Lighting Engineers Technical Report No 5 Brightness of Illuminated Advertisements—Third Edition (first published in 1973) recommends limits on the luminance (brightness) of illuminated advertisements based on the size and location of the advertisement. Larger advertisements are lit to a lower level as are those located in the countryside. These recommendations have been adopted and applied by many planning authorities; however, lack of knowledge and understanding of the problems of light pollution and its control have reduced the national application of this advice.

(b)  New developments. Current planning guidelines allow planning authorities to impose certain conditions on the use of external lighting such as intensity, times of operation and the control of glare and spill light. These controls are generally limited to lighting from free standing supports such as lighting columns, masts and floodlighting towers and cannot be applied to lighting attached to a building. Whilst a number of local planning authorities understand and apply these principles many through a lack of understanding or technical resources only pay lip service to them possibly leading to an unsatisfactory solution causing anguish and upset to nearby property owners and occupiers.

(c)  Existing developments. There is little that current planning guidelines can do to control lighting on existing developments unless any amendments to or replacement of an existing lighting system breaches a current planning condition. It is not uncommon for existing lighting equipment to be amended or adjusted after installation or for baffles and other light controls to be removed due to poor maintenance thus defeating the reason for their original installation. Unless these amendments/adjustments are noticed by the planning authority or a complaint is received then they will not be corrected or replaced.

(d)  Domestic developments. Domestic security lighting does not require planning approval unless attached to a listed building. This anomaly can give rise to many complaints and can substantially increase light pollution, energy consumption and greenhouse gasses due to the unsuitability of equipment used.

3.3  Are planning guidelines being applied and enforced effectively?

  A number of local planning authorities have adopted the principles set out in the Institution of Lighting Engineers Guidance notes for the Reduction of Light Pollution (See attachment No 4) as part of their supplementary planning guidance notes. Unfortunately, as discussed above due to a lack of understanding of the principles or a lack of technical expertise planning guidelines are not being applied and enforced as effectively as they could be. The Institution considers that it would be beneficial if each local planning authority were required to develop, publish and adopt a lighting policy setting out standards of lighting, controls over light pollution and intrusive lighting and any other specific requirements to the local area. It is considered that the lack of objective requirements and standards hinders the application of controls. It would appear that as light pollution is not a statutory nuisance most planning authorities do not take the issue as seriously as they should. It is only when a problem occurs that they try to redress the situation. It is usually too late at this stage to effectively correct the issue and makeshift adjustments and screening are the only practicable remedy.

3.4  Is light measurable in such a way as to make legally enforceable regulatory controls feasible?

  Certain light measurements can be readily taken using commercially available instruments. These measurements include:

(a)  Illuminance levels falling on to property to determine the level of intrusive light.

(b)  Luminance values of illuminated advertisements to check for compliance with planning consents.

(c)  Luminance levels of individual luminaires to determine source intensity.

  It is not currently possible to measure Skyglow and the upward light ratio of a lighting installation, however, there are calculations and observations that can be made to try and determine the quantity and extent of these parameters.

3.5  Are further controls on the design of lighting necessary?

  There is an urgent need for additional controls on lighting to help reduce its impact on the environment. Such controls should include:

(a)  A requirement for each Highway Authority to produce and publish a Lighting strategy for its road lighting system. This strategy should clearly set out the types and standards of lighting and where they would be provided together with any special requirements for intrinsically dark landscapes, National Parks and Areas of Special Scientific Value. The strategy should clearly denote the policy for road lighting provision and its maintenance as well as setting standards to be achieved and measured.

(b)  A requirement for each local planning authority to produce and publish a strategy setting out when, where and the standards of lighting that will be acceptable under its local development plans. This strategy should clearly set out the types and standards of lighting, where they will be allowed and should cover all types of lighting for all new developments and illuminated advertisements. The strategy should list any special requirements for intrinsically dark landscapes, National Parks and Areas of Special Scientific Value.

(c)  Local planning authorities should be required to ensure that an environmental impact assessm(ent is carried out and submitted by the developer for each new development involving lighting. Each environmental impact assessment should be checked and verified by a fully qualified professional lighting engineer to ensure compliance with the planning authority's policy before planning consent is given. Such consent should include a requirement on the developer to adhere to the requirements of the environmental assessment and to maintain the lighting in such a manner that any restrictions on light pollution and intrusive light are maintained at all times.

(d)  Legislation to make light pollution and intrusive light a statutory nuisance under the Environmental Protection Act.

29 April 2003