Monday, January 29, 2018

LED Legislation: 2018 General Assembly

UPDATE:  HB58 was left in Appropriations Committee on 2/13/18

Virginia IDA contributes to changes in legislative language; takes no position on HB58

During the 2016 and 2017 Virginia General Assembly sessions, the Virginia chapter of IDA opposed legislation introduced by Delegate John Bell (D-Loudoun).  (You can read an explanation of why in our post dated February 2, 2017 under "older posts"). 
 
The Virginia State Capitol is lit by one of the most wasteful and 
polluting of fixture designs--the "acorn"--using a glaring high 
Color Correlated Temperature source that further amplifies
 light pollution.

This year the legislation returned as House Bill 58 and our concerns were the same as in years past: mandating LED lighting for all state properties and facilities is risky.
The absence of a Color Correlated Temperature limit, exemptions for places where protecting the night sky and nocturnal habitat is a priority (including existing and potential certified Dark Sky Places), or any mention of adaptive control is a recipe for a well-intended law producing bad public policy and worse lighting.  

Energy-efficient technology does not equal environmentally responsible lighting when decisions are based only on efficiency (and cost) and not on comprehensive consideration of the full effects of lighting on our environment, natural and built, and on us.  Nor does it guarantee energy savings. Unfortunately, recently published research suggests that our tendency to respond to efficiency gains with increased consumption likely applies to LED lighting, with light pollution continuing to spread and intensify. 

Earlier this month Virginia IDA and the Smart Outdoor Lighting Alliance addressed these concerns again with Delegate Bell.  As a result of our conversation, Delegate Bell agreed to amend HB58's language to include a compromise CCT limit of 3500K and exemptions for state parks, astronomical observatories, and environmentally sensitive areas.  (The CCT limit is still above the 3000K limit that is the standard for IDA, SOLA, and the American Medical Association, but without any limit at all there was nothing to stop a state procurement process from unleashing 4000K, 5000K, or even 6500K lighting because it's the most "efficient").  

As a result of these changes, Va. IDA has taken a neutral position on HB58, neither supporting nor opposing it. 

We appreciate Delegate Bell hearing our concerns and his willingness to include us in the process of amending his legislation. HB58 left a subcommittee of the General Laws Committee on a 5-3 vote and has been referred to the Appropriations Committee at which time the new language will be incorporated.  You can follow HB58 here

Saturday, January 6, 2018

Richmond's Dept. of Public Utilities' LED Streetlight Pilot Project


Simplistic labels like "GREEN!" and "EFFICIENT!" continue to obscure the complexities of LED lighting that too often turns out to be both wasteful and harmful to ecosystems, night skies, and human health and safety. Here is a summary of Virginia IDA's involvement in an LED streetlight pilot project unfolding in the City of Richmond. 

The City of Richmond's Department of Public Utilities has begun an LED streetlight pilot project, installing three different LED fixtures in six locations. (Fill out the survey on your reaction to the streetlights here!) 
While  neighborhood associations covering the impacted streets were notified by the pictured newsletter this past summer, Virginia IDA was unaware of the project until November 14th when I encountered the conversion underway as I drove my son to school on Forest Hill Avenue. 

I immediately sought as much information as possible from DPU and shared it with Richmond members and supporters of IDA.  I also referred all information to Bob Parks, LC, MIES of the Smart Outdoor Lighting Alliance for his assessment. (All communication related to this issue was also copied or forwarded to City Councilwoman Kristen Larson and her legislative assistant Bryce Lyle.)


The most obvious concern, even with limited information, was that ALL fixtures originally selected for installation are of a 4,000K Color Correlated

Temperature. This violates LED quality standards and best practices for community friendly lighting.  Numerous streetlight conversions around the country and the world have resulted in neighborhoods rejecting high CCT lighting. DPU's information also makes unsubstantiated claims that the lighting will influence crime or crime-solving. 

On November 20th DPU provided me with "spec" or "cut" sheets for the fixtures as well as photometric summary data from Virginia Tech Transportation Institute (VTTI).

Bob Parks reviewed this information and consulted with Dr. Ron Gibbons, DPU's consultant with VTTI.  Mr. Parks subsequently provided to DPU recommendations with which Dr. Gibbons concurred and which met the design criteria for the city established by WSP/Parsons Brinckerhoff.  The recommendations specified a 3,000K option for residential areas, identifying equivalent fixtures that would also reduce energy costs by up to 25% over the previously proposed fixtures without any negative impact on visibility or safety. 

Mr. Parks also offered SOLA's "pro bono public outreach coordination services to the City of Richmond if the 3000K alternative fixtures are included in the pilot test. These services would include developing a neutral written survey to assess public preference, organize and conduct a town hall meeting to promote the pilot test, and conduct a walking tour of the installed fixtures. After the walking tour is concluded we would collect the surveys and provide you with the collated data to be used in your final decisions."


Mr. Parks also noted that, " . . . the recent AMA report has heightened residents' concerns regarding higher CCT lighting and its potential impact on human health and the environment. SOLA regularly consults with cities on this issue and through public outreach demonstrations has found that most residents, when given the option of warmer color temperature, prefer it overwhelmingly. Furthermore, in many new fixtures the decrease in efficacy for warmer color temperature is minimal or nonexistent.  SOLA believes that preserving neighborhood character and ambiance is an important aspect of LED street lighting conversions that is too often overlooked. Another crucial consideration needed to ensure community satisfaction and acceptance of new LED lighting is the reduction of glare and light trespass, improving overall visual comfort."


DPU initially expressed interest in working with SOLA, but later explained to me that the agency had no means of covering necessary travel costs. I clarified by e-mail, voice mail messages, and in a phone conversation on December 21st that those costs could and would be covered by donations to SOLA (a nonprofit).  DPU still demurred, noting that they did not need another consultant even while confirming that public outreach is not part of Mr. Gibbons' role or scope of services.  Instead DPU has stated that it will conduct its own public outreach and survey although it has no experience in crafting or implementing such an assessment on community lighting. As of December 21st, DPU had not yet had a follow-up meeting with Dr. Gibbons but did express the intention to discuss with him the inclusion of a 3,000K fixture option at the beginning of 2018.

I concluded that conversation by emphasizing Virginia IDA's support for a robust public input process that does not shut out residents beyond the immediate area, a range of quality lighting options (because residents can only experience and compare what is presented to them) including at least 3,000K if not lower, and the use of adaptive control to demonstrate dimming. DPU was not familiar with referenced case studies from other cities and indicated that they are only looking at Washington, D.C.'s streetlight conversion. DPU emphasized that this is just a "pilot project, not a conversion", but of course the intent of a pilot project is presumably to make decisions that ultimately will be implemented on a larger scale. 


Richmond residents who wish to weigh in on DPU's pilot project with questions, concerns, or comments can fill out this survey  and/or contact DPU directly: 

Al Scott, DPU Deputy Director, Gas & Lights
(804) 646-8307
Alfred.Scott@richmondgov.com  
Daniel Rifenburgh, Engineer IV, Technical Services Division
804-646-8537
Daniel.Rifenburgh@richmondgov.com

You may also wish to consider contacting your city council representative. 


For reference, I am copying below an email containing LED-related resources I sent to Mr. Scott on December 22, 2017: 


Mr. Scott,

Thank you for talking with me yesterday. I am following up with the resources I referenced and promised to share:

1) LED STREETLIGHTING CASE STUDIES (there are more, but here are just three)
Cambridge, MA
Includes a thorough discussion of energy savings through adaptive control http://volt.org/cambridge-led-streetlight-retrofit-project/

San Jose, CA
This includes a link to the 134 page assessment report by consultants Clanton and Associates. (Note that it includes analysis of research contributed by Dr. Gibbons.)
http://volt.org/san-jose-ca-led-streetlight-retrofit-project/

Davis, CA Recommendations for public input include 2700K example and dimming options.
http://volt.org/lessons-learned-davis-ca-led-streetlight-retrofit/

2) CITY OF PHOENIX USING 2700K
City of Phoenix government website page on LED streetlight conversion.  Phoenix is using 2700K lights as result of extensive community input.
https://www.phoenix.gov/streets/neighborhood-matters/street-light-information/LED

3) City of Pittsburgh LED Streetlight Research Project (ATTACHED)

4) IDA's LED Practical Guide (ATTACHED)

5)  One of the more recent articles on  Washington, D.C. LED project where citizens have increasingly organized and pushed for 2700K CCT and a follow up letter to the editor:

https://currentnewspapers.com/led-streetlight-plan-sees-continued-resistance/

https://currentnewspapers.com/letter-to-the-editor-city-should-compromise-on-led-streetlights/


6) Link to Department of Energy pedestrian friendly lighting study.  (Sharing this because of the community involvement/public input process that was used): https://www1.eere.energy.gov/buildings/publications/pdfs/ssl/2013_gateway_pedestrian.pdf


I don't know if I've mentioned this before, but VDOT recently put on pause, pending further evaluation, a plan for an extensive 4,000K LED conversion based on concerns raised within the Commonwealth Transportation Board about the effects of high CCT LEDs.  This issue will continue to be addressed by the CTB and VDOT.


Sincerely,


Laura Greenleaf

co-leader, Virginia chapter of the International Dark-Sky Association