Fix the MLO

This may be of interest to some.

The Model Lighting Ordinance (MLO) is a reccomendation from the IDA to the USA on how to model lighting ordinances. Somewhat like the requirements in a development plan.

It seems to be fairly relaxed in some areas. The IDA argues that this is not aproblem as it is US specific, but others feel that it would bee seen internationally as what was acceptable for lighting standards and damage the good work bing done by other campaigners.

I've stayed out of the argument so far (too busy), but if any of you are interested in reading on please let me know your thoughts and I can relay them back to the IDA.

Cheers,
~Al

From: Jan Hollan

The thing I'm very busy now is the IDA's Model Lighting Ordinance, see
www.fixthemlo.org .

The ``MLO'' seems to me ever more to be a real danger for the future of
the night protection, undermining many existing achievements, like Hailey
and Ketchum ordinances, Connecticut law, or, indirectly, even the world's
best legislation in Lombardy, Marche and Emilia Romagna. I think it's no
coincidence.

MLO ignores the scientific knowledge which concerns anthropogenic
contribution to the luminance of the sky. I can't find any friendly
explanation for that, considering it's issued by the
International
DARK SKY
Association...

I seriously recommend the draft of the Ordinance to your attention.

best regards,

Jenik Hollan


And the IDA response:

Hi Jenik,

Thank you all for posting your comments to the European e-mail groups. I
would first like to report that the MLO is not intended for any international
use. Much work is needed before this could even be considered.

For additional status of the MLO, the IDA Board of Directors has issued a
written reply to the letter we received from the "Fix the MLO" group. I attach
it below. If anyone has any questions about this process, please contact me.


I regret that I have been so busy traveling that I have not been keeping
everyone posted with the wonderful progress we are making at the IDA. I will try
to do better, but there is so much to be done. Thank you all and please enjoy
the holidays.

Best wishes for the new year,

Bob

Robert L. Gent
European Liaison Officer and
Member, Board of Directors
International Dark-Sky Association

Forwarded letter from IDA Board President

---

---

10 December, 2004

Greetings!

Many of you are aware that earlier this summer, the IDA released the first
draft of a Model Lighting Ordinance (MLO) for public review and it is a
"work in progress." Also, we would like to point out that the MLO is not
for international use. Only USA planning officials have been consulted,
and much more work is required before it could be released
internationally. In addition, this edition is aimed for cities, but not
for states or to be used for municipal policies. Future IDA documents will
address these areas.

The MLO has become one of our most challenging projects ever, and the
number of comments we've received is very substantial. Not all comments
are consistent. In fact, many are exact opposites. To date, we have
received well over 600 requests for the draft MLO, including many from city
planners, environmentalists, lighting designers, astronomers, and many
other groups.

As a "work in progress," we have established a MLO Comment Review
Panel. This group consists of Nancy Clanton, chair, Scott Davis, Phil
Ianna, Chris Monrad, Chad Moore and Howard Wiig. We assure you that we are
doing all we can to make develop a model that with control light
pollution. The Panel will meet in January 2005 to review all comments on
the draft MLO and it will read and take all comments seriously.

Recently, we received a letter from a group of IDA and non-IDA members
addressed to the IDA board of directors concerning the MLO. As always, we
appreciate constructive comments, and we would like to reply to some of the
key points in the letter. The letter states:

"... the draft is so severely flawed that the IDA should cease promoting it
until there is broader agreement on its content....."

First, we disagree with delaying the release of the MLO. We must begin
somewhere, and this first draft MLO is a much needed and good starting
point. If we waited for perfection, we would be waiting forever. The time
is now for a MLO draft and public review. More specifically, we would like
to comment on the following points from the letter to the IDA board:

1. Make it user friendly.

This is an important point, and the entire board agrees on this point. We
requested specific examples on this, but only one was presented in the
letter we received: We should use "light" vs "luminous flux." We agree.
This is why our draft ordinance contains the word "light" or "lighting"
more than 100 times, yet "luminous flux" is only used a handful of times
and only in the definitions.

2. Use the right metric.

We agree. Using watts per square foot (power densities) is very important
in an age of energy shortages. Not only can we limit the amount of light,
but we can show that we are helping energy conservation efforts. We
recognize that many communities have already implemented zoning
restrictions using lumens per area or foot-candles, and we have added these
as "Viable Options" to the draft MLO. New lighting technologies will be
addressed in future releases of the MLO as data becomes available.

Note: Thanks to the outstanding work of Nancy Clanton and
Associates, we did conduct considerable testing to show that the current
draft MLO power densities also control total light. In fact, we adjusted
power densities downward based on Ms. Clanton's research.

3. Stay Focused on Dark Skies. More specifically, the following
recommendations are made:

-- [the MLO] fails to limit light trespass.

This is not true. When a law recommends or mandates curfews, when it sets
lighting limits, and when it mandates shielding, light trespass is in fact
controlled. Unfortunately, there is no good metric for light trespass that
is easy to understand and enforce. We need a better metric for light
trespass that would be easily understood. Can you help?

-- it does not prohibit upward-directed sign lighting.

We do recommend that all upward sign lighting be restricted. Whether or
not a community decides to tackle this issue is up to them.

-- it fails to require curfews.

The MLO does require curfews. For non-residential, lighting must be dimmed
by at least 50 percent, and we state that whenever possible, all lights
should be turned off.

-- it excludes public lighting.

Much public lighting is street lighting, and as such, cities and counties
often exempt themselves from ordinances. However, we have stated that all
such lighting should conform to all aspects of this MLO and be fully
shielded.

-- it permits light in zone zero.

Even the darkest observatory needs some lighting for public safety. The
stairway lighting at many observatories uses dim red lights to prevent
people from tripping and falling down the stairs. A special wildlife
protection area where no people are permitted, including research teams,
might need to restrict this even further.

-- it does not address existing bad lighting.

This is a good point. e.g., When should excessively bad lights be
removed? Many existing laws use grandfathering or sunset clauses to ensure
bad lighting does not exist forever. We have received many suggestions on
sunset clauses, and we will incorporate this as a "Viable Option" for the
MLO.

In closing, there are dozens of laws being enacted regularly, some are much
better than others. We must proceed now with the first draft of the
MLO. As always, specific comments are encouraged. For example, if you
think some wording is wrong, please be sure to send us the proposed
"rewording" as well as the rationale for the change to the MLO draft. Be
sure to request the latest edition through IDA channels.

Following the MLO Panel in January, a revised draft of the IDA MLO will be
prepared. We are confident that this process will lead to a timely and
successful MLO that meets our goals of protecting the nighttime environment
through improved quality outdoor lighting.

Don Davis, President and the IDA Board of Directors

Sounds interesting. However the actual MLO itself doesn't seem to be online. It gets posted to one's door. However, from the info posted above and in the linked urls, there appear to be pros and cons with it. I guess the problem is that if one is too "extreme" (for want of a bettre word) in one's requirements on restricting lighting, then the average Joe Soap builder, architect, engineer, home owner might miss the point altogether. However, if a more reasonable compromise is made, then we may be able to get these people on board. Once they understand the issues involved, they may be ready to take the next step and reduce lighting even further.
However, the other argument is that making significant compromises isn't a good idea.
Overall though, coming up with a planned way of lighting design is badly needed. At the mo, too many architects and individuals who like showing off their house to potential thiefs are producing alot of light pollution that goes unchecked. If people can realise that there comes a point when adding more light will actually increase the risk of break-ins, then we'd be one step closer to solving the problem.
Of course, that's before we even start discussing the health and financial implications of poor lighting design.