WSP – Written evidence (ALN0076)
Light Pollution
Introduction
Our organisation are a Global multidisciplinary engineering consultancy with 187 lighting practitioners of all levels, 46 of which are UK based. We have a number of professionals that are experienced and dedicated to ensuring our lighting designs use the minimum amount of light required for the task to be illuminated with great care and consideration being given to mitigating the effects of Artificial Light at Night (ALAN) to the immediate surrounding environment inclusive of flora, fauna and human sensitive receptors through good design practice techniques and selection of the most appropriate luminaire and light source for the task.
Whilst we recognising that light pollution in the UK can be looked at in isolation, it is important to recognise that the issue is much bigger and is indeed a global issue in both developed and developing economies.
The UK on the face of it does appear to be lacking in terms of research of the issues from a human impacts and environmental effect/impacts stand point; but at a National level has some of the most comprehensive and globally recognised industry professional body Guidance Notes from the Institution of Lighting Professionals (ILP) for the responsible design and implementation of exterior lighting installations, produced by experts within the industry, separate from any Government lead programmes or initiatives. So there is a discord between what industry understands in terms of self-governing in an effort to mitigate the effects of light pollution; and a structured, comprehensive and meaningful legislative framework to assist Local Planning Authorities and Statutory Bodies to plan, implement, monitor and enforce issues related to light pollution. All of which have the potential ultimately (over the very long term) to reduce the known effects on human health, reduce energy and carbon consumption and improve access to dark skies.
Luminance Analyser Light Pollution Image
Question 1
1 - What is the state of the evidence base regarding the causes and impacts of light pollution in the UK as it relates to human health?
What are the mechanisms by which light pollution has an impact on human health – for example, by disrupting circadian rhythms? What are the negative impacts it can have?
As the developed and developing world has morphed in to a 24/7 global community of activity, the demand for light to enable the various activities to happen in a safe and secure manner have inadvertently increased ALAN. An indirect consequence of this is the effect that this can sometimes have on human health.
Professor Nick Dunn of Lancaster University has established the UK first laboratory looking at the impact of light pollution on human health and nature; The Dark Design Lab. The lab will study the adverse effects of light in towns and cities. Professor Dunn States in the Lancaster Research Directory (https://www.research.lancs.ac.uk/portal/en/clippings/lancaster-university-sets-up-uks-first-dark-design-lab(5f52a97b-3f64-4b95-8ba8-82d3a164d640).html) that:
"protecting dark skies" is crucial to human health and the project will work with town planners to combat the problem. "Light and dark is essential to us as human beings," he said. "People who are exposed to excessive illumination at night, they're having their biological clocks go out of synch. "If we get rid of dark skies than actually what is happening to us as humans is potentially very serious health consequences."
He goes on to say that:
“We want our cities and other places at night to be safe and inclusive for everybody," he said. "But what we do need is responsible, lighting, so that we can make sure we have environments that are beneficial to all, but also for the many creatures that we share this planet."
What are the primary sources of light pollution and how well do we understand them? Is there evidence regarding which types of artificial light, in terms of frequency, duration of exposure, or intermittency, are the most harmful?
It is a common misconception that street lighting is the main contributor to the brightening of the night; this may be true to a point and it undoubtedly does contribute, but it is this sector that has lead the way in recognising the issue and acting to evolve its products to be more night sky, ecologically and human friendly through significant lamp (LED) and optical technoloy developments to control and mitigate the issues associated with ALAN.
Dr Chris Kyba led research to understand the contribution of well designed and operated street lighting on the night sky and especially skyglow. Using satellites to measure what fraction of the total light emissions were due to street lights across the city of Tucson, in Arizona. At 01.30 every morning for ten days the city dimmed its street lights, increasing the percentage dimming each night.
His light-from-space experiment, published in the journal Lighting Research & Technology, showed that most of the artificial light wasted - by being sent upwards into space, rather illuminating a sign, street or building on Earth - does not actually come from streetlights, but from other sources. Illuminated advertisements, floodlighting installations, lit buildings, facade lighting, parking lots and sports lighting are the types of installations responsible for most of these light emissions.
Chris advises that “This is really important information for policy makers and light pollution activists," and goes on to say “this does make it more difficult to solve, because there are so many contributors. It means everyone has to get together to decide what lights need to be lit at night, and how brightly.”
Is there evidence that light pollution is worsening – for example, with the introduction of LEDs and cheaper forms of lighting, or lighting with a different wavelength spectrum?
There is clear evidence that our night skies are brightening at an accelerated rate as documented on the Natural History Museum website page (https://www.nhm.ac.uk/discover/news/2023/january/increasing-light-pollution-drowning-out-stars.html) which links in various research projects form around the world and states that the night sky is becoming around 10% brighter each year on average (the rate of increase varies around the world with Europes annual rate increasing at the slower rate of 6.5%). For example Dr Chris Kyba states ‘
'The rate at which stars are becoming invisible to people in urban environments is dramatic. If the brightening of the night sky continues at the current rate, a child born in a place where 250 stars are visible will only be able to see 100 stars there on their 18th birthday.'
The article also makes reference to the brightening of our skies not only due to the amount of light but the colour and the shift to LED technology for efficiency and optical control purposes, but it is noted that the colour shift to bluer light sources so the light pollution is becoming more blue This is explore further in the Science Advances article ‘Environmental risks from artificial nighttime lighting widespread and increasing across Europe’ (https://www.science.org/doi/10.1126/sciadv.abl6891); a shift from the orange glow associated with low pressure sodium lamps which was a common but optically uncontrollable light source form the 1970’s onwards.
Whilst we know our skies are brightening the data does lag behind because according to Dr Ashley King:
'Light pollution can be monitored by Earth-monitoring satellites, but many are limited in resolution and sensitivity,' Ashley says. 'They generally focus on longer wavelengths towards the redder end of the spectrum, whereas shorter wavelengths tend to scatter more in the atmosphere.'
A growing body of industry evidence from the likes of the Bat Conservation Trust is leading us to a shift away from cooler/neutral white light sources (4,000 to 6,000 kelvin) to warmer (2,200 to 3,000 kelvin) white light sources, for ecological purposes, but this shift could also aid in the reduction of the brightening of the night sky.
How reliable is our evidence base for these impacts – are there areas where we are less confident or additional studies that are needed?
There is a lot of knowledge and information available on the effects of ALAN, but with a lack of sound correctly researched data to substantiate what is clearly known, mainly due to a lack of funding. Often professional organisations rely on volunteers who are passionate about the subject, to give up their time to develop guidance notes, undertake surveys etc.
There is also a lot of misinformation, lobbying and light activists that are unable to prove often wild claims around lighting and its effects, and yet as they are normally the loudest and most vocal, claims are taken as gospel despite the clear lack of evidence.
The issues surrounding and the inherent effects of ALAN are known, but a bigger body of properly funded and peer reviewed research at a government level is required in order to broaden our understanding’ for example, the Institution of Lighting Professionals (ILP) and Bat Conservation Trust (BCT) are both Charitable bodies that rely on the work of student research projects or researchers in other nations; could this work bring forth a greater and more in depth understanding of the relationship between bats and modern LED lighting at an accelerated rate if it were properly funded? Manufacturers could tailor products to specific design requirements based on the light sensitivity bat species identified which also has the potential to reduce the effects associated with ALAN to the wider environment and thus night sky levels of light pollution.
Does the UK have a sufficient research base? Who are the main organisations conducting research into light pollution and how are they funded?
In short no, but there are a number of voluntary or charitable bodies that have taken the lead to monitor, inform, educate and bring awareness to the issues surrounding ALAN such as:
International Dark Skies Association UK (IDA) – Informative website (https://ida-uk.org/research/) with links to an extensive ALAN research literature database (https://www.zotero.org/groups/2913367/alan_db/library)
The Countryside Charity (CPRE) – Produce the excellent nightblight map (https://www.nightblight.cpre.org.uk/maps/)
Lancaster University – The Dark Design Lab (https://www.research.lancs.ac.uk/portal/en/clippings/lancaster-university-sets-up-uks-first-dark-design-lab(5f52a97b-3f64-4b95-8ba8-82d3a164d640).html)
Further funding is needed to be made available to such exemplar organisation in order to accelerate our level of understanding of ALAN, and, how as a collective industry across all lighting disciplines we can take appropriate steps to mitigate light pollution aspects in order to maintain a balance with the world around us and a connection to the heritage that is our dark night skies.
Question 2
2 - Where does light pollution intersect with public policy in the UK? Is the existing regulatory regime effective?
Are the Government agencies, departments, or local authorities currently responsible for monitoring and regulating light pollution appropriately resourced? Is there sufficient expertise within organisations charged with regulating or enforcing regulations on artificial light?
Our organisations lighting practitioners current understanding in relation to public policy in the UK can be summarised as follows:
Obtrusive light is legislated as a statutory nuisance by the Environmental Protection Act 1990 Section 79, Subsection 1, as amended by the Clean Neighbourhoods and Environment Act 2005 Section 102, in terms of light emitted from certain premises. This is not considered to be light pollution.
This legislation says of local authorities “and it shall be the duty of every local authority to cause its area to be inspected from time to time to detect any statutory nuisances which ought to be dealt with under section 80 below and, where a complaint of a statutory nuisance is made to it be a person living within its area, to take such steps as are reasonably practicable to investigate the complaint”;
This responsibility to investigate statutory nuisances is discharged by representatives of local authorities including environmental health officers;
These investigations are informed by the relevant local planning guidance in the area that the alleged nuisance occurs; and
If a statutory nuisance is found to have occurred, local authorities have the power to compel property owners to make amendments to their property to remove the nuisance.
The main issues we identify with the current system are as follows:
No definition of a statutory nuisance is provided, leaving this up to the judgement of the local authority representative;
Exemptions for specified premises with CNEA 2005. Developments in lighting technology and application of applicable standards through good design practice and techniques should ensure that no premise should be exempt or be able to use such as an exemption for a poor lighting installation;
No minimum inspection programme is put in place, nor any criteria for that inspection, to determine if statutory nuisances have occurred; and
Limited formal training is provided to local authority representatives regarding light pollution and nuisance issues and are often towards the bottom of Environmental Health Officers case load due to either lack of knowledge and education or suitable education/material in place to provide a level confidence in enforcement.
Have there been any changes to Government policy following the Royal Commission on Environmental Pollution’s 2009 report into artificial light in the environment? Have these been adequate?
There have not been any definitive updates to Government policy in the intervening years other than tweaks to relevant paragraphs of the NPPF, of which there are few in relation to light pollution. It is disappointing that the lighting requirements for PPS23 were cancelled/removed when the NPPF was launched which replaced the PPS23 with vague statements in eth NPPF. The Gov.uk Guidance on Light pollution, which serves as a good structure when considering lighting as part of a planning application but lacks any kind of teeth in terms of being written in to statute to give it some weight to place the hones on the applicant that all practicable means are being employed to ensure the effects of ALAN are mitigated, controlled and measured at all stages of planning, design, construction and post development monitoring.
What role should LPAs play in determining plans or restrictions on light pollution? Are the current guidelines on light pollution set under the Government’s advice for planning authorities adequate?
Local authorities prepare local plans, which may or may not contain a policy relating to lighting and light pollution, and it is the responsibility of the local authority representative to use their judgement to determine whether a statutory nuisance has occurred based upon the legislation, guidance and policy available to them. This results in a postcode lottery, where depending upon where you live, light pollution may be policed stringently or not at all. Something that constitutes a statutory nuisance in one area may not be a nuisance 5 minutes down the road. If a statutory nuisance occurs in one authority’s area, but is experienced in another, who defines whether or not the nuisance has occurred? There is a lot of ambiguity here.
Some local authorities such as Norfolk County Council and North Norfolk District Council (https://designguide.north-norfolk.gov.uk/sections/landscape-biodiversity/dark-skies-light-pollution-noise/) have developed their own policies in order to prevent and reduce the amount of light pollution in order to maintain or improve the relatively dark sky environment of their county. An example which should be emulated by central government in order to provide a good basis upon which such initiatives can be effectively implemented if they are at the heart of any changes or reform of the NPPF to ensure that one of the most prominent types of pollution is controlled and where practicable reduced.
Question 3
3 - What recommendations would you make for changing Government policy on light pollution?
What are the possible interventions that could be deployed to mitigate the effects of light pollution and how well understood are their effects?
It is our organisations practitioners’ collective opinion that there is a need for legislation at the national level to achieve the following:
To codify the definition of a statutory nuisance in terms of light pollution, including defined levels at which a nuisance is deemed to have occurred;
To define a minimum inspection programme for the assessment of statutory nuisances;
An equivalent system to the World Health Organisation (WHO) for monitoring and establishment of thresholds for light pollution.
The effects of light pollution are very well understood by industry; however when organisations are talking about light pollution, focus is always placed on street lighting, but research has clearly demonstrated that well designed and managed LED street lighting as is now being deployed across the UK is not the main source of sky glow and light pollution no, it is sports lighting, illuminated advertisements, security lighting (commercial and domestic) etc. As summarised by Dr Christopher Kyba researcher at the German Research Centre for Geoscience, mention in response to Question 1 of this document.
Are there any interventions that have been pursued effectively in other countries that could be replicated in the UK?
Recent work by the All Party Parliamentary Group (APPG) for Dark Skies has made good progress in tackling the key issues around skyglow and light pollution, and the implementation of these measures has the potential to trickle downwards into best practice for local authorities. However, better considered dark skies legislation has the potential to broaden, strengthen, and improve consistency in the obtrusive light policies of local authorities. Stronger and more consistent national legislation is needed to clarify the definition of a statutory nuisance and ensure that enforcement is consistent in different areas.
It is interesting that in air quality, there are very strict objectives, the WHO have guidelines that offer global guidance on thresholds and limits for key air pollutants that pose health risks. For NO2 and Particulate Matter these are based on annual and 24-hour averages. Local Authorities must report on these annually with Annual Status Reports. Should there be a system to link that in the Lighting World? Obtrusive light, as with air quality and noise pollution are time and place sensitive and with continued exposure, or one-off anomalies, can have significant adverse effects on the environment and human health.
3 March 2023