To: Mr. Dick Roche,
Department of the Environment, Heritage and Local Government,
Custom House,
Dublin 1
Sunday, December 12, 2004
I am writing to you on behalf of the Irish Light Pollution Awareness Campaign (ILPAC), a group comprised of amateur and professional astronomers, wildlife enthusiasts and environmentalists. The aim of our group is to encourage the use of less polluting and wasteful lighting in Ireland. We are also affiliated at an international level to the International Dark Sky Association (IDA). I would like in this letter to briefly outline the issue and solutions that we think the Irish Government should consider.
Ireland, when compared using satellite data to other European countries, can still boast some of the darkest skies in Europe. This means that children in our towns and cities can still look into the night sky and see faint stars and the Milky way -- something that is lost in many other countries. Amateur astronomers around Europe are often amazed at the quality of the skies in Ireland when compared to other countries. Astronomers in the UK may have to drive hundreds of miles to get to a dark sky whereas in Ireland I can take a comparatively short drive of tens of miles from the City Centre and be under the relatively dark skies of your constituency in under an hour. Preserving our deep astronomical and scientific heritage is almost a good enough reason on its own to state in law that light pollution is a nuisance; but there are also more practical reasons.
If unchecked, Ireland will have to pay out massive fines under the Kyoto protocol. Much of these fines will be due to energy production, and the cost of the fines will most likely be passed on to consumers through their utility bills. We believe that introducing light pollution legislation provides a win-win situation for all parties concerned:
* By insisting that when street lighting needs replacement by County Councils, it is replaced by more efficient lighting (ideally flat glass full cutoff lighting) that does not spill light above the horizon. The running costs of the light can be reduced since there is no light being wasted. The effects of such lighting can be seen on some modern motorway interchanges where the lighting is all directed downwards. This safe lighting saves money, does not spill light above the horizon, does not cause glare for motorists and generally does not shine into houses. Councils would not need to replace all streetlights immediately, given effective management of street lighting they could be replaced with better fixtures as they need replacing. This would keep the implementation cost of such an initiative to a minimum.
The city of Calgary in Canada are currently replacing their street lighting in a move that will reduce CO2 emissions by 19,000 tones a year, and reduce electricity bills by over €1 million per year. The plan will have paid for itself within 5 years.
*By requiring that lighting, including security floodlighting, be the minimum needed for security and working purposes. Lighting on buildings that shines beyond where it is intended, is more intense than is required, or is on at inappropriate times, should legally be considered a nuisance and the public should have the right to object to such lighting and have it altered or removed. The Institute of Lighting Engineers recommends a maximum wattage of 150W for 'security' lighting yet many security and DIY outlets sell lights in excess of 500W. By requiring people to properly consider lighting on their premises they may be able to reduce the running costs of exterior lighting significantly. Kerry County Council is one council that has taken the initiative in this regard by requiring in its development plan that "Details of any external lighting scheme intended as part of any new development shall be submitted as part of the planning application. Applicants will be required to demonstrate that the lighting scheme proposed is the minimum needed for security and working purposes." Clare County Council is considering a similar statement in their Development Plan.
On Wednesday December 8th the UK government introduced a bill that would make light pollution a statutory nuisance; specifically, "artificial light emitted from premises so as to be prejudicial to health or a nuisance."
I would ask you as the Minister for the Environment to consider this piece of legislation as a possible base for introducing a similar bill in the Dáil.
The UK Bill appears to have several flaws which any Irish bill should address at the outset. These include: A nuisance not clearly defined is the reference "prejudicial to health". This could mean that someone could only object if, for example, they had a doctor's letter stating the nuisance caused sleep deprivation even though the light in question may clearly shining well beyond its intended area. The UK Bill has too many exemptions. The Bill make exceptions for bus stations and airports. These are clearly areas where control of light pollution is of primary concern. In a bus depot lights should be only directed downwards in a non polluting way to reduce glare on drivers and intending passengers. Allowing buildings near bus stations to use bad lighting could have serious consequences if the glare was to affect the bus drivers vision. Similarly at airports, while the runway and necessary areas need to be correctly lit, having non essential buildings shine light above the horizon could cause an air traffic accident, particularly in foggy conditions.
ILPAC, and the International Dark Sky Association would be delighted to have the opportunity to work with the department in advising for such a Bill. We are sure that the opinions of scientific bodies, professional astronomers and lighting engineers, as well as light pollution campaigners in Northern Ireland and the UK would also be willing to submit suggestions.
I hope I have provided you with a reasonably detailed summary of the issues and possible solutions to this issue along with the advantages to all concerned in dealing with the problem. Some more details are available on our website
www.irishastronomy.org/ilpac
. Should you or any member of your Department wish to discuss this further please do not hesitate to contact me.
Kind Regards,
Albert White,
Irish Light Pollution Awareness Campaign
  