on GPP streetlighting Sep 2008 draft

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

(just a fw of a slightly corrected document sent before the Dec 5 midnight deadline...)

To: eugpp@aeat....uk

Dear eugpp,

I'm writing you, as a senior Czech "Umweltberater" (environmental counsellor), 
to offer you my remarks on Technical specifications and GPP Product sheet on 
Street Lighting.

The main problem of those documents is, that the most important environmental 
aspect of nighttime artificial lighting, namely

  the disruption of the natural day-night cycle,

is not even mentioned in the documents. The GPP Product sheet words,

 "Other environmental impacts could potentially result from ...
  light pollution, depending from the location of the lighting"

seem to be like a crude joke...

The impacts are not potential, but huge, well-known, widely acknowledged 
(see e.g. a recent issue of National Geographic) and world-wide. Light 
pollution is clearly the largest adverse impact of streetlighting. A Czech 
representative research (1000 respondents over 15 years) has shown, that 
five per cent of respondents cannot sleep well because of 
artificially-produced light intruding their bedroom windows... A more 
recent study from Israel demonstrated that the only strong predictor of 
breast cancer (from all possible which were tried), is the intensity of 
outdoor lighting.

The documents don't even mention many peer-reviewed papers describing the 
problems caused by streetlighting or showing the (proven) ways how they could 
be reduced. The only relevant literature given within the references of the 
larger document (Ecological Consequences of Artificial Night Lighting) is 
mentioned without caring about a proper way of giving references (no publisher, 
no URL...), indicating that the authors did not even see it (the book as well 
as some online articles are easy to find on www.urbanwildlands.org).

Also, they don't mention any countries or regions with strong legislation 
aiming at reducing light pollution and power consumption due to outdoor 
lighting: Slovenia and 8 regions of Italy. The legislation there is very 
successful, and there are no problems with implementing it. Power savings are 
large, growth of light pollution has been stopped there, unlike in all other 
regions of EU. The main rule is rather simple: emissions from luminaires in 
horizontal and upward directions are to be ZERO. The rule is very simple to 
obey, and visibility of streets to pedestrians and drivers is improved 
tremendously thanks to much reduced glare.

I've been corresponding with the main author of EuP Lot 9 study Street 
Lighting by VITO during the last phase of their work, since autumn 2006 -- 
too late to influence it relevantly. The last stakeholder's meeting in 
December showed me that one of the reasons they were unable to include 
light pollution within the criteria or to the life-cost assessment was 
their missing knowledge of its scientific definition.

Consequently, I've elaborated a paper on it, later discussed by leading 
scientists at this field and by the Darksky 2008 conference. Please see the 
final version
  http://amper.ped.muni.cz/light/lp_what_is.pdf
 -- not only the definition, but the many ways of quantifying it and some hints 
and references dealing with minimising it are available in that document.

Another relevant documents from that time are within the
  http://amper.ped.muni.cz/light/EuP
directory.


The current versions of the two documents on GPP for streetlights cannot help 
the EU goals to reduce power consumption a lot till 2020 and much much more 
till 2050 and further on.

On the other side, realizing that light is poison at night, to be used with 
large caution and only when necessary, might help to reduce power consumption 
for street lighting by an order of magnitude.

It would be a pleasure for me to help you to prepare such an improved, 
really useful document.

with best regards,

Jan Hollan