MLO V.2004.1, position of Italian orgs.

[Jan Hollan <jhollan@amper....muni.cz>]

reposting from magnitude6, restored paragraphs are my guess. jenik


   Here you find the position of the Italian organizations that fight LP:
   CieloBuio, IDA Italian Section and Unione Astrofili Italiani.

   Fabio Falchi



   Comments on IDA's MLO V.2004.1

   by

   CieloBuio, IDA Italian Section and Unione Astrofili Italiani


   The Model Outdoor Lighting Ordinance (MLO), being a document
   developed by IDA for Municipalities should be primarily aimed to
   preserve the nocturnal ecosystems, night environment and night sky.
   In the current version for public review (2004.1) it fails to do so.

   This document, even if it is aimed to North America municipalities
   only, will be understood by all the lighting people as the direction
   to follow in the whole world. If the final document will not be
   changed substantially toward a night friendly one, it will undermine
   the serious efforts carried on outside USA. It will be used saying
   that if IDA advices to do so, why do you want a stringent limit?

   If even IDA does not push toward ordinances effective in fighting
   light pollution, who will? Light designers? Lighting industry?

   CieloBuio, IDA Italian Section and Unione Astrofili Italiani strongly
   recommend to rethink all the MLO toward a new night sky friendly
   version. The current one will not protect the night environment and
   will not fulfil the second to sixth purposes listed in the MLO
   preamble (page 2). Some of the reasons follow.


   a.. MLO uses lighting zones.

   As the scientific studies on light pollution (LP) had since long
   demonstrated, LP propagates to over 200 km from the sources. This,
   with the additive properties of LP from different sources, will not
   permit to protect a site dividing the territory in zones, unless the
   zones have hundreds km long radius. Moreover, zoning will be a sort
   of environmental racism: some people will be protected more than
   others. The definitions of the various types of zones are quite
   aleatory and will allow more pollution where it is already produced,
   perpetuating the status quo. The best international laws against LP
   do not use zoning.


   b.. MLO permits to use NOT fully shielded fixtures almost everywhere.

   The table 2 on page 5 shows that except for LZ0, a two percent upward
   flux is allowed everywhere. Note that a detailed study taking into
   account the light distribution of luminaires and surfaces (Cinzano,
   P., Light pollution by luminaires in road lighting, 2002) shows that
   a prismatic glass fixtures with ULOR_inst=2% produces an increase of
   200% of the scattered flux due to emission at low elevations over the
   horizon (where light pollution propagation and addition is more
   effective) in respect to the flux produced by the road surface alone.

   Using watt instead of lumens for characterising the lamps permits to
   have abnormally high upward fluxes and permits them to grow as the
   technology advances.

   As an example of the 'limits', in LZ3 it is possible to use
   unshielded lights of more than 9000 lm for landscape and façade
   lighting (more than 30000 lm for LZ4). Other example: sphere fixtures
   are permitted in LZ3 and LZ4, if they emits less than 10% of their
   flux above the horizon. Compare these 'limits' with the only one and
   simple limit of 0 cd/klm at the horizon and above already
   successfully enforced over all the territories of Lombardia, Marche,
   Emilia-Romagna (about 15 million inhabitants).


   c.. The MLO total power limits are far too high.

   Those listed in table 4 (page 8) of the MLO are simply ridiculous.

   The limits on illuminances allowed in the serious Italian regional
   laws (such as Lazio, Lombardia, Marche, Emilia-Romagna) are about 15
   to 30 lux (usually the limit is on the luminance, so the illuminance
   depends on the surface reflectance) for all the purposes except the
   external working places (where higher limits are allowed, always
   fully shielded of course).

   The only comparable limits in the MLO are those listed under the LZ0.
   Already in the LZ1 40 lux are permitted in the sidewalks, walkways
   and bikeways, not speaking of the 300 and 350 lux on the car service
   stations and building entrances. The limits on the LZ2, 3 and 4 are
   progressively out of this world: 160 lux on parking lots, landscape
   lighting, driveways; 200 lux on sidewalks, walkways and bikeways;
   1000 lux on building entrances; 2400 lux on service stations; 500 lux
   on building facades!

   The limits on table 4 are not in lux, but in watt per square foot. To
   convert in lux we used a 1000x factor, considering lamps of 93 lm/w
   efficiency (with more efficient lamps the limits grow consequently).


   The one listed above are the major flaws we found in the current
   version of MLO. We ask for a new rewritten version to undergo a new
   public review.