INTRODUCTION

  (Note: photographic images submitted and not printed)

  I am responding on behalf of the British Astronomical Association's Campaign for Dark Skies (hereinafter referred to as "the Campaign"), of which I am a committee member and national co-ordinator.

  I have taught astronomy to all levels (primary, secondary and adult education) during the last 30 years, both at Poole Grammar School (1971-96) and as a travelling lecturer and examination moderator. I have been an active observer of the night sky for 40 years and I am, like all the other members of the Campaign committee, very concerned at the veiling of the starry sky by wasted light.

  I am the author of Light Pollution: Responses and Remedies (Springer-Verlag, 2001; ISBN 1-85233-497-5) the only single-author book in English (as far as I know) solely on the subject of light pollution. I have made copies available to the Science and Technology Committee.

  The British Astronomical Association is the largest astronomical organisation in Great Britain, and the Campaign for Dark Skies is one of its many sections.

  The Campaign was initiated in 1990 by a group of astronomers, concerned about the erosion of the night sky by uncontrolled and ill directed lights of all kinds, both public and private. As well as the problem of skyglow, the Campaign also addresses the terrestrial problems of glare and light trespass which such lights cause: direct light spill from nearby premises obviously hampers or prevents observation of the night sky, as well as causing many other problems. The Campaign is the largest organised network against light pollution in the UK, and indeed anywhere outside the USA.

  The Campaign's nation-wide network of 119 local officers has had some success in accelerating the pace of sensitive lamp design within the lighting industry, as representatives of that industry have confirmed. We work to convince local authorities, organisations which use large-scale lighting schemes, and individuals, that environmentally sensitive lighting, of an appropriate brightness for the task and falling only where it is needed, is both desirable and achievable. The Campaign does not call for the switching off of any necessary light.

  The lighting industry's professional guidance body, the Institution of Lighting Engineers (ILE) www.ile.org.uk , agrees with this stance, and has published the widely quoted and influential Guidance Notes for the Reduction of Light Pollution (1992, revised 2000), in which we read:

"Light pollution, whether it keeps you awake through a bedroom window, or impedes your view of the night sky, is a form of pollution and. . .can be substantially reduced in both rural and urban areas".

  The Campaign is in continual dialogue with the ILE, CPRE and other concerned bodies.

Question 1.  What has been the impact of light pollution on UK astronomy?

  1.1  The night sky, unofficially but undeniably a site of special scientific interest and an area of outstanding natural beauty, is being quietly and gradually taken away from Britons, not only in towns and urban fringe areas, but also in the countryside. Public and private lighting has proliferated rapidly since the 1950s, increasing in intensity and performance factors, but directionality has failed to keep pace with other advances in the technology. Waste upward light and sideways spillage of light outside the premises to be illuminated are seen everywhere. Ian Phillips, chairman of the UK Landscape Institute's Technical Committee, said at the Lighting and Landscapes Conference at Kew in February 2002:

"Too much lighting nowadays is not designed—it just happens. . . the dark spaces are just as important as the lit spaces".

  1.2  The extent of the problem: more than 90% of Britons experience skyglow.

  In 1991 the Campaign carried out a nation-wide survey of over 200 astronomical groups. This included a questionnaire to be distributed to group members, asking for details of their location, and of the visibility of the night sky from it. Respondents were well scattered, some observing from great cities, and others from small towns, villages or isolated rural locations throughout the country.

  805 observers, from the casual to the assiduous, responded. 727 (90.3%) stated that skyglow was visible to some extent in their night sky at home. The great majority (701) of these 727 "positive" respondents commented on the degree of severity of the effect of skyglow on astronomical observations. 211 described it as "noticeable", 453 as "strong", and 37 reported having given up observing the night sky altogether because of "impenetrable" skyglow. The conclusion drawn by the Campaign was that more than 90% of people who wish to see the night sky in the UK, and they are certainly not all amateur astronomers, probably suffer light pollution at least noticeable enough to hinder observation. Well over half of these would-be observers have to contend with considerable skyglow. These results are broadly supported by isophotic maps of the UK, based on satellite imaging, which show the problem to be worsening.

  1.3  Light pollution of the night sky has played a significant part in the migration of British professional astronomy away from the UK over the last 40 years: world-class giant telescopes such as the 100-inch Isaac Newton Reflector have been taken away to other locations such as the Canary Islands, not just to find less cloudy skies, but to escape the ever encroaching veil of waste light in the night sky over the UK. It might be objected that the UK's weather precludes good astronomy: William Herschel, Isaac Newton, Edmond Halley and many others might disagree. How many potential astronomers and astrophysicists have been lost due to the disappearance of our dark skies, previously a great source of inspiration?

  1.4  Scientists acknowledge that astronomy is the only science in which amateurs still play a significant part in original research. The many thousands of amateur astronomers in the UK, many of whom do valuable and original scientific research both within and without the British Astronomical Association, the Royal Astronomical Society and the Society for Popular Astronomy, cannot move their telescopes to better skies overseas: a typical urban observer might have a round trip of at least 100 kms to find a rural spot with dark skies. Ironically, even our countryside is not immune from the depredations of unregulated waste light, and there is almost nowhere in mainland Britain today where a truly dark night sky, as has been enjoyed by humans for millions of years, may now be seen. All citizens have the right to see a relatively unspoiled environment. Half of our environment is above the horizon: half of our environment has no protection in law.

  1.5  Other environmental organisations have expressed their support of the idea of countering light pollution, most notably the CPRE, which collaborated with the BAA in 1994 to produce the enclosed document Starry Starry Night. Indeed, the Government's own home security website www.crimereduction.gov.uk deprecates the use of "overkill" security lighting and advises against it.

  1.6  Skyglow and obtrusive upward lighting, and light spill below, also detract from the character of the night-time scene and are detrimental to local amenity, not just for astronomers, but for the public in general. We cannot stress too strongly that the adverse celestial and terrestrial effects of poor lighting are inseparable—the one nearly always entails the other. Just as a mountain has no existence without a valley, the problem of skyglow up above is indivisibly connected to problems encountered here below: the lights which cause skyglow also cause light trespass, energy waste, atmospheric pollution and glare, affecting both astronomers and non-astronomers. Astronomers are in the vanguard of the dark-skies debate, but many people who have no interest in astronomy care deeply about the waste of money and resources, intrusion and assault on visual amenity which misplaced light represents.

  Good evidence of this: the many representations from people in various walks of life at the Public Enquiry on local nightclub skybeams held in Guildford in December 1999. HM Planning Inspector Wood concluded in her decision[1] (paragraph 78): "I have to say that the beams are unwelcome intrusions. They are alien features, disturbing to those who appreciate the countryside for its non-commercial aspects, and others that wish to maintain dark skies for observation purposes or for its own sake. (paragraph 81) It is this far-reaching impact that is unacceptable, as the beams are detrimental to the amenity of the surrounding rural areas. . .it must follow that the advertisement breaches planning policies that seek to prevent harm to the Area of Outstanding Natural Beauty, and to the countryside".

Question 2.  Are current planning guidelines strong enough to protect against light pollution?

  2.1  They are not.

  Light pollution is covered in two of the Government's Planning Policy Guidance notes, PPG 17: Planning for Open Space, Sport and Recreation and PPG 23: Planning and Pollution Control.

  PPG 17 calls on planning authorities to ensure that local amenity is protected when considering applications for floodlighting on sports grounds. This guidance says impact on the openness of the Green Belt and on the character of the countryside should be key factors in determining the granting of planning permission for new floodlighting (paragraph 19). But it is only referring to the visual impact of the lighting towers during daylight, not their effect at night.

  PPG 23 suggests that planning authorities (local councils) address the issue of light pollution within their development plans. It is appropriate, for example, for them to identify objectives for reducing light pollution and raise it as one of the issues which should be considered when planning applications are drawn up and submitted.

  Lighting should be included under planning legislation, with definite instruction, not mere suggestion, to planners as to what is acceptable and what is not in new developments. Redress against irritant lighting should be made available by classing it, alongside noise, as a potential source of nuisance and a pollutant in law. Light pollution, mentioned in the Rural White Paper of November 2000, is listed below "noise pollution" under the heading "Promoting tranquillity" (9.4.4. "Light pollution of the night sky is an increasing intrusion into the countryside at night, and is an issue that we want all rural local authorities to take into account in their planning and other decisions. Local planning authorities have powers, for instance, to control many external lighting installations").

  Light intrusion is not a localised matter. People affected can be many kilometres from the source, as was stated above. They may not even live in the same jurisdiction as the offender.

  There may be no action individuals can take from the damaging effects of schemes that did get approved and subsequently proved a problem. Nor is there any provision against existing polluting schemes, especially the ubiquitous "DIY" lighting that does not require any planning approval.

  2.2  Victims of ill directed lighting should not have to resort to expensive litigation[2], or simply have to "put up with it", if their lives or leisure pursuits are adversely affected by light trespass. The upsurge reported by Environmental Health Officers in complaints involving light trespass during recent decades is symptomatic of a nationwide problem which will not be treated through education alone, or mere voluntary guidelines. Indeed, complaints about light pollution are under-reported because there is no reason for recording complaints about something that is not a statutory nuisance.

  2.3  In a seminal article Light Pollution: a Review of the Law, in the Journal of Planning and Environment Law (January 1998), environmental lawyer Penny Jewkes wrote: "Environmental protection is the sum of small concerns; this is the essence of sustainable development, which requires that decisions throughout society are taken with proper regard to their environmental impact. The planning system goes some way to achieving this, but it was never designed to bear the full responsibility for the control of light pollution". Professor Francis McManus, Reader In Law at Napier University, discussed this subject at a light pollution seminar organized by the National Society for Clean Air and Environmental Protection (NSCA) in November 1999. He stated that

"there is no doctrinal reason why light should not be considered a pollutant, and a nuisance in law".

  The powers of the planning system ought to reflect and address the groundswell of concern, and not just in the environmental/astronomical community, about the "dark side" of light.

Question 3.  Are planning guidelines being applied and enforced effectively?

  3.1  While many local authorities have lighting clauses in their local plans (and the Campaign's officers often work closely with them on this), in far too many places local authorities will not take action against existing obtrusive lighting. For example, a correspondent troubled by excess light emitted both horizontally and vertically from a nearby nightclub told the Campaign that his approach to the local council was met with a dismissive "nothing we can do" attitude. Lack of public consultation before lighting schemes are installed is another common complaint. The Campaign receives letters from people who have moved house, lost jobs through interrupted sleep, and have suffered serious mental anguish as victims of intransigent neighbours' intrusive exterior lighting.

Question 4.  Is light measurable in such a way as to make legally enforceable regulatory controls feasible?

  4.1  Yes. Digital cameras and luxmeters can provide objective measurements, but no technical equipment is needed to conclude that light is trespassing from nearby premises, is being emitted above the horizontal, or is blotting out the stars significantly. Some people believe that skyglow is the visible orange glow seen over towns and cities, but this is the extreme. At low brightness, the eye ceases to perceive colour, so skyglow can merely be a colourless lightening of the sky, easily obscuring the Milky Way and many other interesting objects that should be visible to the unaided eye.

  Although it is possible to measure and quantify skyglow, as seen from a particular location, it is very dependent on air pollution levels and meteorological conditions, and the condition of reflective surfaces in the vicinity of the light source. An apparently clear night sky may in fact belie the presence of large amounts of droplets and particles in the atmosphere (and more importantly nowadays the effects of merging aircraft contrails). These will create a veil of skyglow from even a relatively slight source of upward light. Sometimes, at a distance, one cannot easily attribute visible skyglow to particular lighting installations. There is no doubt, however, that properly controlled lighting would be of immense benefit to our view of the night sky whatever the atmospheric conditions.

  4.2  The Campaign realises that the total eradication of all skyglow is not an achievable aim, because of reflections from surfaces, but the optimum night sky for all, through proper controls on lamps' directionality and intensity, is possible.

  The Campaign would welcome legislation, based on the possibility of measurement, tending to restrict any emission of light to below the horizontal except in rare circumstances.

Question 5.  Are further controls on the design of lighting necessary?

  5.1  Yes, they most certainly are. The installation of horizontal cut-off lighting on roadways, often by the Highways Agency, has helped, but in many cases local authorities have used this as an excuse to increase the light levels, which has reduced the level of improvement as far as the Campaign is concerned. Many side streets, car parks and public places are still lit by unshielded globe lights and sideways-facing types, wasting council tax and energy and despoiling the sky.

  5.2  As road lighting gradually improves in the UK, any benefit which might have resulted has been negated in many places by the proliferation of poorly aimed and unregulated sports, architectural, amenity and security lighting. The light produced by such installations is now the major contributor to skyglow in many localities. For example, a floodlit golf driving range in Christchurch, Dorset, can be clearly seen from the middle of the New Forest, 30 km away—see picture below (not printed).

  The Campaign has persuaded B&Q to offer better quality security lighting in their outlets. Other companies are considering this, but the impact is small.

  The typical domestic "security" lights (300-500W) is far too bright. The ILE recommends 150W maximum. Over-bright lights waste energy, create dark shadows for malefactors to hide in and dazzle potential witnesses. These lights annoy neighbours because they tend to be set off easily. Also, especially in rural areas, they are partly responsible for the light pollution that ruins the night sky. Such lights can rarely be mounted to have horizontal cut-off, and cause glare and light pollution over large distances. Badly designed and installed lighting can only be forestalled through appropriate planning and environmental legislation.

CONCLUSION

  C1.  Energy would be saved, the environment helped, and lives less blighted, if the right amount of light, directed only where needed, became the norm, enforced by proper regulation. Good quality lighting is compatible with a good view of the stars, but at present a worthwhile view of the sky can be taken away overnight, without redress, if somebody installing upward-shining lights nearby chooses not to emulate others' good practice.

  C2.  The campaign would like to see light included in the Control of Pollution Act as a potential pollutant, and come under the law of statutory nuisance, just like noise. The Czech Republic has enacted a "Law for the Protection of the Atmosphere", including the effects of light: the UK should emulate this. The CPRE agrees with the Campaign on this point. It is not necessary to allow any light up into the sky, further damaging an environment which has already been too much eroded. It is certainly not necessary carelessly to illuminate others' premises, or use wattages far exceeding ILE guidelines. Design controls should be introduced to achieve good quality lighting, just as regulations ensure the safety of electrical goods.

  C3.  The campaign to restore the beauty and grandeur of the night sky is not just for the benefit of astronomers. For millions of years, human beings have looked up to the sky at night, and it has contributed enormously to their culture, their religions, and to the progress of science and the arts. Astronomy encompasses chemistry, physics, biology, and mathematics, and its study involves questions both philosophical and theological. It is acknowledged within the academic field that an interest in astronomy is often the early stimulus for a scientific or technical career; science and technology being mainstays of a thriving industrial nation. Everybody should be able to see the rest of the universe.

  In 1988, the newly introduced National Curriculum stated that all British schoolchildren should learn about "the wider universe". Most of them see precious little of the night sky from urban, and even some rural, locations, because of light pollution. The Campaign believes that, children or adults, we all have a right to a view of that universe, and as untainted a view as possible. Skyglow hardly encourages the contemplative appreciation of the grandeur of our celestial environment. As we enter a new millennium, energy and environmental considerations loom larger in human thought.

  Protection of citizens from light trespass and glare is also urgently needed. All who have a duty of care to the environment, both in office and as private individuals, should be tackling the problem of light pollution now.

  The protection of our heritage above, the starry night sky, is an idea whose time has come.

March 2003

2   eg Bonwick vs Brighton and Hove Council. (Aug 2000, BN906721). Back