On November 1st, Region of Waterloo transportation department staff gave Regional Council an update on the LED conversion. A link to the video archive for this presentation can be found at the end of this post.

While the presentation certainly gave Councillors a warm and fuzzy feeling about the LED conversion details to date, it neglected to full inform and/or elaborate fully on important details that Council members should understand prior to any future voting on this project moving forward.

I actually submitted two statements. The first one was entered as part of public record for this Council meeting (a Planning and Works meeting). The second statement which is below, I sent to Councillors after viewing the Region staff update presentation on this LED conversion.

I felt it necessary to send Region of Waterloo Council members this further statement so details left out of the Region staff presentation could be brought to their attention. As well details of the presentation that I felt gave a false impression of the true facts, were also addressed in this statement below.

Hello Councillors,

I had a chance to watch the video archive of the Nov 1st meeting. Specifically the LED conversion update presented by staff. Council needs to fully understand this topic prior to any voting. Watching the video I can see no one really does understand it though. There were red flags in the presentation. These points were not questioned.

While it may appear different and that I am at odds most of the time with details of this LED conversion, I do respect staffs work on it regardless. I do believe they feel they are doing their best. I do believe some aspects of this they have correct. I also do respect the fact that most people do not understand artificial lighting at night (ALAN) unless you have a specific reason to. Well in fact we all do. The protection of our night ecology and our own well-being are but a couple very good reasons. We will be changing the quality of our night environment for decades to come with this street light conversion. This should not be trumped by energy and cost savings alone nor any hype surrounding it.

Facts NOT mentioned within the presentation:

1) 3000K target goes back in discussion to almost a year ago now. Not sure why staff downplayed the 2700K LEDs. New LED technology is available and quickly emerging with lower CCT (<2700K) and even better energy and cost savings. The Region could save even more energy and money if we did better with the required specifications. There’s a lot of new coming in 2017 on the LED front/advancements. As for 2700K not being available currently when asked – yes it is. Many cities in USA are either installing 2700K or switching to 2700K out of blue light concerns.

2) The Region presentation suggested action of tilting of fixtures to solve light trespass problems. This doesn’t work, I speak from experience with this and…

  • It was stated the LED fixtures will allow light up to 90deg, but not beyond that so no uplight which is good. But…
    • If light is allowed up to 90deg, or even 80deg you will have light trespass. That was not told to you.
    • Further when asked to comment on this, Peter Hiscock, P Eng, Professor Ryerson University said ” Yes, absolutely. And [in addition] that ‘low angle radiation’ between 80 and 90 degrees is a major contributor to sky glow.”
    • Please note that blue light from LED has been proven to increase skyglow – definite fact. As well RoW staff know this and have confirmed it in communications. It was not told to you we are adding more blue light moving from our 2100K HPS lights to 3000K LED. More on this below.
    • American Medical Association report issued June 2016 says “Blue light scatters more widely (the reason the daytime sky is “blue”)” “blue-rich lighting that travels along the horizontal plane [80deg, 90deg] increases glare and dramatically increases the nighttime sky glow caused by excessive light pollution.”
    • The only way to prevent this light trespass and skyglow problem from LEDs is to not increase our blue light levels at night and to use fixtures that have built in or add-on “sharp cut-off” shielding available. I sound like a skipping record but it is for really good reason!
    • The light source (LEDs) must be concealed, not visible. The RoW staff’s “full shielding” terminology is misleading in that it gives a false impression. This shielding method only relies on out of the box fixture design. It is already well known that LEDs are not concealed well with the majority of fixture designs currently on the market, using only factory light cut-off designs. This is one reason why we see people complaining in news stories about LED lights. The light source is not shielded properly.
    • Think of this RoW staff “full shielding” as a “lamp shade” that doesn’t work well enough. It does not extend down far enough and the bulb is still visible to your eyes; glaring at you. Sharp cut-off shielding correct this problem.
    • BUG rating (Backlight, Uplight, Glare) is used and referenced in manufacturer specs. Glare component within the BUG rating has to do with forward light throw and light trespass. The higher the number from “0” the worse it gets. If the LED fixtures have a G2 or G3 rating (or more), you have light trespass and glare occurring. This can be further exasperated by pole height.

3) The Frederick Street LEDs example regarding glare. No increase in collisions:

  • This “study” can be compared to the ones about crime which have been widely criticized. It was designed to show the lights were not doing something really bad. Its scope did not show a wide enough of range in light “quality” to be an effective test.
  • It is well known that testing should be done by dispassionate and independent researchers who understand the variables and the biases that can corrupt a study. This was not the case with this cited example. However who is going to pay for a study that may not support the desired outcomes?
  • There was some chuckling about looking at the Sun when discussing the disability and discomfort glare issue. While it’s true no one looks at the Sun or should without proper optical filter, the fact is LED lights are 1/16 to 1/30th the brightness of the Sun. This has very harsh impacts on vision. Especially residents that are 40 years of age or older. Add rain to night time roads and the problem increases. The aging eye does not cope as well with extreme intense light sources (glare). We also have to consider peripheral vision and the impact these LEDs will have on motorist and pedestrian vision. By blinding our eyes’ light rod/receptors with intense LED light, we are activating our daytime vision while driving at night. It makes our night vision less effective. So discerning differences between lit and not lit areas while driving, can be very dangerous. You may not see something that you should be seeing. I guarantee you as well, most people do look from time to time fleetingly at a light source. I have when driving. Like a moth to a flame. This needs to be taken more seriously by RoW instead of trying to disprove the glare impacts.

How does brightening and polluting of our night happen from street lights?

light pollution light trespass glare LED

In diagram above it shows why we need to use lowest blue (low Kelvin, <2700K should be considered now) and have sharp cut-off shielding and not over-light the roads).  Staff presentation wasn’t exactly forthcoming about the broader aspects/implications of light trespass and how light pollution and skyglow are created. There is also wasted energy/money with light that is allowed up to 90deg and not controlled with sharp cut-off shielding, so we are missing out on more savings. Sharp cut-off shielding focuses the light, directs the light and you can then operate the LEDs less bright (lower wattage/lumens) which extends life span; more savings! This is because none of the light or energy is wasted with sharp cut-off shielding in place. We would be wasting energy and light with RoW staff’s out of the box fixture design shielding approach.

Bad LED street lighting in Kitchener, Ontario

Above is a photo I took of LED street lights in a Kitchener residential neighbourhood. These are no uplight, 90deg “full shielding” like RoW staff’s. I see a lot of light trespass into bedroom windows, tops of houses and lot of glare. What do you see? This is why sharp cut-off shielding is needed for LED. They are very blinding and more bright.

led street lights over lighting glare bright

Above is a photo taken by a gentleman from Colorado, of a street in Juneau, AK, USA,  where concerns about LED street lighting are also happening. It shows the over-lighting caused by the increased intensity (brightness) of LED street lighting. HPS lights are on the left, the LEDs are on the right of the photo towards the background. Note: look at the road/ground differences. (Photo credit and copyright belong to the Gentleman who posted this originally on Cloudy Nights forum:  http://www.cloudynights.com/topic/549520-led-na-vapor-streetlight-comparison/)

Light trespass is not just about sleep disruption as the presentation noted. It is also about the quality of the night environment for residents and ecology.

  • Light trespass also impacts nocturnal species be it wildlife, insect or plant – this is part of light pollution in general.
  • Light trespass also interferes with the use of private property for those residents interested in exploring the night sky from their private property without being forced to drive an hour or more away like second class citizens. Light trespass and glare creates glare which impedes vision and diminishes their ability of the property owner/resident to observe the night sky which the Region claims to be protecting. We listen to and provide for residents who want improvements such as more bicycle lanes so why can’t we be inclusive for others with different interests and needs? Street lighting is for roads and sidewalks. Not lighting up or protecting private property. The presentation failed to mention any of this.
  • Eliminate the glare (sharp cut-off shielding) and you eliminate light trespass completely. Combine this with quality light <2700K LED and you reduce impact of skyglow contribution and disruption of wildlife patterns such as migration. Wow eh! Simple.
Birds killed by light pollution. Disruption of ecology, our environment is the result of bad lighting at night.

Every year, the Fatal Light Awareness Program (FLAP) Toronto, “displays” these victims of light pollution to raise public awareness. Light pollution negatively effects ecosystems without regard unless we make the changes needed and think differently about how we dump artificial light into our night time environment.

Improper installation of current Region street light fixtures was brought to the attention of Region staff as far back as 2010/2011.

  • Yet in 2016 we are still seeing improper installation of fixtures. Toe-up (tilted up), tilted to one side or the other, not level to the ground, not 90-degree or 0-degree up tilt.
  • There are means to ensure fixtures are installed properly so the design is not compromised and spilling light beyond where it is intended.
  • Improper installations create inconsistencies and diminish the dark-sky friendly attributes and capability of the fixture. This is especially concerning where new LED street lights are going to be installed which are far brighter than our current HPS lights.
  • Workers usually have a limited time to install each fixture. 10 mins or so in some cases as example. So they are forced to move quickly and the result (mistakes) can be seen with our current lights. Without proper training and quality controls (before and after installation) for ensuring fixtures are installed correctly, we will see light pollution increase; light trespass, glare and even skyglow.
  • Staff had a little animated diagram showing an add-on shield going up the pole to the base of the light fixture.
    • First off the light pole was shown as tilting towards the otherside of the road. This would be improper installation which is a seperate matter and problem on its own with street lights in Region of Waterloo. Shielding does not correct for bad pole installations! Misleading.
    • While this animation presented the appearance of sharp cut-off shielding it was NOT – misleading again! Council was not told this though and since no Councillor noticed it I think it is another example of how Council does not understand the full implications of the LED conversion.
    • If you review the video showing this shielding, you will notice that when the shield shimmies up to the base of the light fixture, the light cone below only changes on the house side (back side). This is called “backside shielding”. Don’t confuse it “sharp cut-off shielding” as it is not. Backside shielding only stops light trespass on one side of the road. Not across the road where glare and light trespass (remember BUG rating above!) can also intrude on private property and into homes.
    • This backside shielding has extremely limited capability in controlling light trespass or glare and is restricted to addressing only 1/4 of the overall problem.
    • All that has been asked (and denied numerous times) is for a small inventory of sharp cut-off shielding be sourced now at the same time as the LED conversion. Sharp cut-off shielding will address 100% of glare and light trespass problems. Also since the “working group” consists of Region and Municipal staff, sourcing and having sharp cut-off shielding at the time of conversion will mean Municipalities involved will have this ability to control the light for residents as well. Before complaints start rolling in from home owners.

4) Up to 60% reduction in light trespass was claimed. Analyzing photometric data (photometric being the light pattern on the ground from a street light) from behind a desk using only the manufacturer’s data is not conclusive that light trespass will be reduced. See above photo (Fig 2) of which these Kitchener LED street lights’ photometrics were assessed and approved by City and Hydro staff as being “good” in terms of light trespass control. Definitely not good! The only conclusive way to know is to conduct in-field real world observation and photometric analysis of each LED street light make/model being considered for the conversion. This has not been done. Again, without sharp cut-off shielding the glare and the more intense light source from LEDs, will increase light trespass not reduce it.

5) Staff presented an image showing light temperature (Kelvin) to Councillors.

  • It showed 6500K which is daylight (on a cloudy day) and how the LED street lights will be 3000K, lower on the colour temperature scale. It was also said that the blue light level would be less.
  • This is similar to the glare misinformation in that its narrow focus was to show that 3000K is better in terms of blue light amount than 6500K is. Of course it is! That’s not disputed but that’s not the issue here.
  • Staff failed to state that we will be increasing the blue light levels across the Region (43,000 times!) with the 3000K LEDs (they contain up to 25% blue light) since we are switching from, as noted by the Region staff, 2100K HPS lights currently in use which have a lot less blue light in them (contain <10% blue). Of course we can’t confirm the blue light level in the 3000K LED conclusively because the Region did not require the spectra reports.
  • Contrary to what staff would like you to believe via the presentation, we are not doing better with the 3000K. Increasing the amount of blue light 43,000 times across the Region will add to light pollution and negative ecology effects. That’s what blue light at night does. That’s what makes it so concerning on scientific, medical and environmental levels.
  • We are increasing blue light levels by switching from 2100K HPS to 3000K LED, not reducing blue light. It’s irrelevant to compare against 4000K the original target a year or more ago or even 6500K since we are not targeting that colour temperature. So a little bit of poison is OK for the environment, for wildlife, for plant species, for us? It’s ok to increase skyglow not reduce it like the ROP states (which appears to have no teeth really). That’s what we are saying while claiming to be so eco-friendly in Region of Waterloo? This is artificial light environment poison multiplied by 43,000 lets not forget.

6) Dimming was mentioned as means of mitigating light pollution. Unless the RoW is definitely including dimming control for its share of LED street lights in the conversion, this point is meaningless and should be disregarded since it will not be applicable.

I am passionate and truly care about dark-sky advocacy and protecting our night ecology in Waterloo Region.  I’ve been speaking to all of you and other officials about this since 2008. Many other residents truly care as well, some even emailed you. Waterloo Region Nature is concerned.

Hopefully township Councillors are also concerned because light pollution from a City (Kitchener-Waterloo) can travel up to 160KM into rural areas. You can see KW’s light dome (skyglow) from a 45min drive out past Conestoga Lake or a 30min drive out near Linwood.

This LED conversion is providing a unique, once in a lifetime opportunity for huge change when it comes to reducing skyglow and light pollution. What we do now will have lasting effects and with all the new developments to come, we will be adding even more street lights in the near future. Improving on the LED specifications and light controls is not a bad thing. It’s a good thing. It’s the right thing to do. It is being environmentally responsible when it comes to our contribution to climate change, which is about more than just energy or cost savings.

For those Councillors that do care about the environment and night sky above us, I said before, lighting is always viewed as a technical issue even though it is primarily an environmental issue – because you are changing the natural environment for one reason or another and nature is qualitative, not quantitative. Lets approach this qualitatively. The LED conversion needs to a be win for both energy/cost savings but more so it should be a win for our nocturnal environment, our night sky and the future health of our Region decades to come.

The decisions made by the Region on the LED conversion effect all of the municipalities and townships involved as well. It is not just about Region street lights. Leave out something important at the Region level and the municipality doesn’t have it either. A domino effect that our night environment and people and other species, will pay the price for down the road.

History has recorded the perspectives, actions or inactions, on this issue from both sides for future review. Let’s hope common sense prevails. We can, we must, do better.

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