Update, Dec 17, 2016 – After I further questioned more of the same unclear approach to answering my questions, answering in part but not fully, related to the LED conversion, I received a rather cold email from the Director of Transportation for Region of Waterloo stating the project was moving ahead regardless of any concerns I still have regarding increased light pollution and light trespass. Region Councilors are siding with staff, as one would expect in a “club”. It appears the science and medical data, the professionals I presented statements from including Engineeers, Doctors and Professors, are not going to be enough to warrant improving the LED specifications. This is most unfortunate.

In my ongoing communication with the Region of Waterloo regarding the LED street light conversion, I have again had to point out problems with their approach. This is new artificial lighting we will be filling our night time environment with and the effects are clearly unknown. Many scientists, engineers, doctors and environmentalists are providing data and proof that the wrong type of light will have biology and ecology impacts.

4000K LED street lights along King St in Waterloo Ontario Canada
4000K LED street lights installed in Waterloo, Ontario along King Street. These lights emit more blue light which the American Medical Association, the Region of Waterloo Health Department and the International Darksky Association have warned against the increased light pollution and negative effects on humans and wildlife.

I have spent much time over the past months and years trying to make sure staff, councilors and Mayors have relevant information and know the facts on LEDs, not just the hype.

So it was very concerning to me to learn that the Region of Waterloo won’t require suppliers to provide the spectrum reports for the new LED lights being submitted in bids. Essentially there will be no data to confirm the quality of the light and the amount of blue light within it most importantly. Instead they will essentially be making guesses based on manufacturer information and qualitative assurances which cannot be confirmed.

Here are some of my key points presented to the Region of Waterloo transportation manager. Also included were Regional councilors and the commissioner of transportation and environment for the Region, none of which have responded nor provided their own comments to date on the LED conversion issues.

  • Based on your response, the Region is confirming, regarding the LED conversion, that it does not have any means of properly and accurately determining the light quality being purchased. (no spectrum reports)
  • The Region is also confirming, based on your response, that it will not be requiring the spectrum report for any or all of the LED luminaires being considered.
  • Without the spectrum report, which is data, the Region has effectively made a “guess” (not data) with regards to the light quality (blue levels in particular) and how it relates and/or meets AMA and Region Health Department statements/notes on LED lighting biology impacts.  As I have clearly pointed out several times past, blue light content can vary substantially from one 3000K manufactured LED to another. Most current products can have a CCT of 3200 or even 3300K or more in some cases (but are advertised as 3000K CCT). This should be verified as well as the blue light level with the spectrum data, not qualitative assurance or guesses.
  • Beyond the human health concerns, without the spectrum report to know conclusively that we are minimizing the blue component to the lowest possible levels, The Region is also making a “guess” on the impacts of the night time ecology and increases to light pollution/skyglow throughout the Region due to Rayleigh and Mei scattering. Not the best approach for unleashing a new lighting technology across the board for decades to come. We are already seeing a dramatic increase in skyglow from ongoing LED conversions on residential and commercial properties/buildings so you can appreciate my interest in selecting the least offending LED luminaire for 43,000 installations across the Region.
  •  Leaving it up to residents like myself, by suggesting I obtain the spectrum reports for the listed LED luminaires is very concerning statement to have read from the Region. A Region supposedly concerned with environmental impacts and improvements.
  • Without the spectrum report (the data) and instead using staff guesses for determining light quality the Region would not be in accordance with Region’s ROP, “Lighting for Dark-Sky 3.D.7 Area Municipalities are encouraged to develop policies or guidelines to prevent or minimize the impact of outdoor lighting on the night sky”. “3.D.8 The Region will, wherever feasible and appropriate, use technology that supports dark-sky lighting in all new street lighting.” LEDs can have as much as 50%-85% more blue component light than HPS lights. Again, the spectrum reports are critical in selecting the best LED luminaire for the conversion and to be compliant with the ROP.


Another problem that kept coming up was the misuse or confusion as to what lighting guidelines or compliance they were following. One Region staff person would say Dark Sky Friendly, while another would say Dark Sky Compliant. The RFP issued by the Region indicated they should have confirmation of meeting International Darksky Association certification. When I asked for confirmation as to whether the Region would be meeting Dark Sky compliancy, the Region of Waterloo transportation manager referred to my questioning of terms as “semantics”. Quite troubling I think. My response on that was:

  • I’m not sure important terminology and definitions within a large scale and serious implementation of new artificial lighting across the Region, is best referred to as “semantics”. Dark sky compliance is different than Dark sky friendly. The compliances are different. IESNA guidelines which often see excessive lighting are not as concerned with the night biology and ecology as the IDA/RASC GOL guidelines are. Light pollution and skyglow are taken seriously by many within the Region even if our officials don’t or don’t fully understand the damage it is having/creating. It’s ironic that those overseeing and deciding on what is best approach to reducing and controlling further night time light pollution impacts, are snug in their beds at night with little or perhaps no real assessment of the problem. I however have years of at night time, in-field experience, researching and observing and photographing the growing problem of light pollution and the effects it is having/creating. This is something sitting behind a desk and looking at photometric information cannot duplicate. It is one of the reasons I believe we have the disconnect occurring herein to this LED conversion with officials and councilors concerned.

Another major concern with the Region of Waterloo’s approach to the LED conversion is the lack of full shielding procurement ahead of any rsident complaints that will arise from these very bright LED street lights. Light trespass into bedroom windows and onto private property where it is not wanted or needed has been a primary issue with other LED conversions throughtout North America. I have requested and the KW RASC has requested on more than one occasion for proof and specifications that the Region has, even a small inventory, of engineered full shielding to prevent light trespass issues. This information has never been provided and the requests dismissed essentially. My response to this again was:

  • You have indeed clearly stated that the Region will consider full shielding as required on a case by case basis. You have not been so clear in providing details and answers (requested several times) as to how the Region will address these concerns to come. You have avoided provided any information in the form of PDF spec or mechanical drawings that demonstrate the Region has procured an engineered solution to the problem of light trespass for the new LED luminaires in advance of the rollout. The Municipalities involved will then not have solution either. Why not simply state the Region does not have any engineered option for full shielding at this time and is deferring to dealing with it when and if complaints come in. It’s evident in your statement about the veiling luminance that the diodes (LEDs) will be exposed to view, which means the fixtures are not a “true” full cutoff design. The Waterloo Region Nature email sent to Region staff and Councillors earlier this year stated shielding should be used for the LED luminaires as part of the overall protection of [/fusion_builder_column][nocturnal and] diurnal species within our night ecology [disruption of foraging and competition can ensue]. Myself and the KW RASC are not the only ones repeatedly asking for this. I and others are disappointed the Region will not even invest in a small inventory of (engineered design) full shielding.

What a unique opportunity we have been given. If we go by the length of time HPS street lighting has been with us, I would say this LED conversion is a once in a lifetime opportunity for many of us. Should we get it right, the first time? Some of us in the Region of Waterloo (Ontario, Canada) feel we should.


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