Memorandum from the Hampshire Astronomical
Group, submitted by Graham Bryant, Vice-Chairman
1. INTRODUCTION
1.1 I am the Vice-Chairman of the Hampshire
Astronomical Group and had led the campaign for better lighting
in the county of Hampshire for the last 13 years. I lead the Hampshire
Astronomical Group's activities at curbing the worst excesses
of poor quality lighting and encouraging good quality lighting
policies and designs.
1.2 I am also a committee member of the
British Astronomical Association's Campaign for Dark Skies (CfDS)
and have been so since the formation of the CfDS in 1990. I was
the CfDS's Newsletter Editor for its first nine years and built
a reputable national and international circulation. I have attended
both national and international conferences and lectures on "lighting
and astronomy" in the capacity of organiser, presenter and
as a delegate
1.3 The Hampshire Astronomical Group has
one of the best equipped amateur observatories in the south of
England boasting four observatories which house telescopes including
a 0.6m, 0.41m and a 0.3m reflector, all computer controlled, replete
with the latest imaging technology through to a historic 0.13m
Cooke refracting telescope which is an ideal instrument for teaching
and public viewing. The observatory also has numerous additional
portable instruments and a support building and engineering workshop
facilities.
1.4 The observatory facility is utilised
by University of Portsmouth's Mathematics and Astronomy undergraduate
students and many use the observatory for their final year observational
project work. The members of the Hampshire Astronomical Group
use the facilities for observations which have been used to contribute
to data bases which are then used by the `professional' scientific
community for further research. More recently the observatory
facilities have been used for confirmation observations of discoveries
of exploding stars in distant galaxies.
1.5 The observatory stands atop a 150m (619ft)
hill in the South Downs some 16km north of the City of Portsmouth.
This is the third observatory site the Group has moved to in the
Group's 43 year existence, the latest move during the mid 1970s
was ostensibly due to the encroaching problem of light pollution
from its then nearby town of Fareham. The Hampshire Astronomical
Group is now acutely aware that we cannot move away from further
urban lighting, so curbing the lighting was the only option left
open to the Hampshire Astronomical Group in its attempt at maintaining
the observational, scientific and educational viability of the
facility.
2. WHAT HAS
BEEN THE
IMPACT OF
LIGHT POLLUTION
ON UK ASTRONOMY?
2.1 Professional astronomy, in the visible
part of the spectrum, has all but moved off the UK mainland and
sited its multi-million pound operations from sites such as the
Canaries and Hawaii. Light pollution is one of the factors which
sealed the fate of UK mainland based visual astronomy. However,
many university and amateur astronomy facilities do not have the
resources to undertake astronomy outside of the UK, and arguably
it is inappropriate for those institutions to do so, therefore
it is often the university and amateur facilities which are effected
most by the problems of light pollution.
2.2 Amateur astronomy is acknowledged as
being one of the few sciences in which the amateur still has a
significant role to play in scientific research into the subject.
This can be part of adding to current data bases or individual
search routines where discoveries can be made. Light pollution
threatens these endeavours.
2.3 Many amateur facilities are open to
the general public (as are the Hampshire Astronomical Group's)
either on a regular basis or for specified limited events. In
our experience, many members of the public are clearly ignorant
of the sky above them, as from towns and cities in the UK much
of the night sky is blighted by the ubiquitous orange sky glow
which masks the starry night.
2.3 Many school children have to study astronomy
as part of the national curriculum, most cannot see the night
sky for real in all its glory and beauty and see what their teachers
have explained in the classroom. Astronomy has often been described
as the spark that sets many people into seeking a career in science.
With the demise of the visibility of the night sky for most people
in the UK we as a society will be the poorer for it.
2.4 A survey of amateur astronomers conducted
in 1991, instigated by the CfDS, showed that in excess of 90%
of respondents were effected by sky glow. It is not known if this
could be extrapolated to the population of the UK. However, the
CfDS commissioned a poster depicting the UK at night by the Remote
Sensing Center at Farnborough and it is easy to see the major
population areas in the UK by the amount of light spill from the
towns and cities in the UK. This additionally indicates a significant
waste of resources in energy usage.
2.5 We have seen in recent years the use
of the night sky as an almost blank canvas for advertisers with
the use of sky-beams or space-flowers. The use of the sky in this
way to advertise a facility or event is disastrous for astronomy
with shafts of light sweeping through the night sky obliterating
the stars and faint nebulae. Fortunately their use has been partly
regulated under planning law (see Guildford Council vs Harpers
Night Club Ref: APP/Y3165/H/98/0848/P4) and HM Planning Inspector
stated at the time that such beams were "unwelcome intrusions".
3. ARE CURRENT
PLANNING GUIDELINES
STRONG ENOUGH
TO PROTECT
AGAINST LIGHT
POLLUTION?
3.1 It is generally accepted within the
astronomical community and those non-astronomers who contact the
astronomical lobby for assistance in dealing with problematic
lighting, that the planning guidelines are not strong enough.
3.2 I have been contacted by many distraught
members of the public whose lives have been blighted by the insensitive
use by neighboursboth commercial/industrial and residential,
of poorly aimed or designed lighting. Unfortunately, unless such
lighting can be demonstrated to be a hazard to road users, aircraft
or on navigable waterways there is no legal redress.
3.3 In a survey of Environmental Health
Officers (EHOs) in the 1990's, a massive increase in complaints
regarding lighting were recorded by EHOs. Unfortunately, the Environment
Health Departments had no powers of redress as light cannot be
regarded as a "nuisance".
3.4 Light, like noise (sound) is essential
to our lives, however, too much light, like too much noise, is
detrimental and as such, we believe Local Authorities with the
backing of legal redress, should be available to manage such problems
of excessive lighting. We are acutely aware that some commercial
operations such as ports require by law a certain level of illumination.
3.5 The Hampshire Astronomical Group worked
closely with the Continental Ferry Port in Portsmouth in reducing
light spill from their floodlights. An excellent solution was
found with shielding floodlights from light spill into adjacent
properties and the night sky, as such the Ferry Port managers
were presented with a Good Lighting Award, signed by Sir
Patrick Moore, to acknowledge the ability of both astronomy and
commercial operations to co-exist in respect to lighting. Unfortunately
we are not always so successful is persuading all "light
polluters".
3.6 It is our experience that within the
planning process the daytime visual impact of a design of a lighting
scheme is often the subject of the planning decision rather than
the night-time impact of the illumination. It would be our opinion,
that both aspects should be considered with equal weight when
such schemes are considered within the planning process.
3.7 Light travels far: a planned scheme
with lighting in one area, town, district or county can easily
be viewed from another. As such the visual amenity, be that the
night sky or night-scene of other areas can be, and often are,
significantly and detrimentally effected. An example are golf
driving ranges and sports facilities, which are visible for many
kilometres. This impact is often never the subject of the planning
decision. Because each council planing departments view the issue
of lighting differently, one area with good approach to lighting
(eg wish to see the right amount of lighting in the right place
during the right time) could be seriously effected by the decision
in a neighbouring council which pays little or no regard to the
problem of light-trespass.
3.8 The Hampshire Astronomical Group would
argue that good quality lighting per se, means that the night
sky is similarly preserved.
4. ARE PLANNING
GUIDELINES BEING
APPLIED AND
ENFORCED EFFECTIVELY?
4.1 Many local authorities have lighting
clauses in their local plans. Locally the Hampshire Astronomical
Group has a good relationship with one of our local authorities,
and we are often made aware of lighting schemes for comment, that
are brought before the local planners. This is not so with other
local authorities. The good relationship we have with our local
authority has been brought about after a decade of contact and
constant communication.
4.2 We believe it should not be the preserve
of astronomers to monitor such lighting schemes when brought before
planning departments, this should, we believe, be integral within
planning regulation and enforcement. We have had experience of
planning permission being granted for lighting schemes, the lighting
impact of which had not been assessed, and the consequence was
distress for local people and significant impact on the night-sky
with very little or as often the case, no redress.
4.3 We understand that to assess the likely
impact of lighting schemes some expertise on light and lighting
is required. We offer to the local planning department by way
of our comment in public consultation, such expertise, which of
course the local planners can accept or reject, we believe more
robust guidelines are required to enable the application and enforcement
with the planning process.
5. IS LIGHT
MEASURABLE IN
SUCH A
WAY TO
MAKE LEGALLY
ENFORCEABLE, REGULATORY
CONTROLS FEASIBLE?
5.1 Light is measurable as every photographer
is aware. Luxmeters can be used to measure the amount of lumination
from a light source. Many lighting engineers use computer modeling
to determine the amount of light a scheme will place either on
the ground or on a building in the design stage.
5.2 Since the amount of light pollution
(sky-glow) seen in the night sky is very dependent on aerosols
in the atmosphere from either water vapour, dust particles or
other pollutants, measuring the brightness of the night sky (which
is perfectly feasible) would not be a good measure of effectiveness
of controls on light pollution. Some light will always be visible
in the night-sky through light reflectance from the ground.
5.3 The Hampshire Astronomical Group believes
that the aspect of regulation and control need not be over-technical.
Simple guidelines such as "Light should not be emitted
above the horizontal except in exceptional circumstances"
and limits to the amount of light (in lux) spilt outside of
the curtilage of the property to which the scheme belongs, should
be sufficient. One can see with the unaided eye whether light
is spilt onto adjacent property, this is known as light trespass.
5.4 One should also consider the problem
of when considering enforcement and regulation. Disability glare
is experienced when one is subject to viewing the light source
itselfmost noticeable when driving where cars travelling
in the opposite direction have their lights on full beam.
5.5 It is the experience of the Hampshire
Astronomical Group that disability and discomfort glare (sight
of the actual intense light sourcethe bulb or discharge
tube) aspects of light pollution and trespass which create most
complaints by non-astronomers and for which we are frequently
asked to assist. Limiting the light output to the illumination
of the land contained within the property only, and not outside
the curtilage, would stop this problem at a stroke. It would also
stop light pollution of the night sky from direct illumination.
6. ARE FURTHER
CONTROLS ON
THE DESIGN
OF LIGHTING
NECESSARY?
6.1 The Hampshire Astronomical Group believes
that further controls are necessary.
6.2 Many poor lighting schemes are in existence
simply because of the poor light control of some light fittings
(luminaires). If rigorous guidelines were in operation this would
encourage the design and manufacture of better quality luminaires
in order to meet the regulatory requirements. We are fortunate
to have a vibrant lighting industry that is well able to rise
to these technical challenges, it is the belief of the Hampshire
Astronomical Group that such proposed regulations would continue
to favourably place the lighting industry as a world leader in
design and manufacture.
6.3 The light output of a number of floodlights
is considered, both with the astronomical community and the lighting
industry, to be too high. The Institution of Lighting Engineers
(ILE) recommends a maximum of 150W much less than the 300-500W
lights, pejoratively described as "rottweiler" lights.
Such high levels of illumination create discomfort and disability
glare, deep shadows and does not provide "security"
for which they are, in our opinion, ill described.
6.4 In previous correspondence with various
Government departments regarding the matter of lighting controls
we have always been confronted with the argument of "education
not legislation". The Hampshire Astronomical Group is convinced
that this approach is no longer tenable and would draw the committee's
attention to issues that had similar life saving approaches of
the use of crash helmets and use of seat belts. If ever there
was an argument to change people's behaviour with simple education,
these would be examples. Ultimately, Parliament had to resort
to the use of legislation as the general population did not heed
simple good advice which saved lives. "Education" alone
is a wholly ineffective method of changing behaviour and we urge
the Committee to look beyond such an approach.
7. CONCLUSION
7.1 The Hampshire Astronomical Group has
welcomed this opportunity to set out before the Science and Technology
Committee the issues regarding the vexatious problem of light
pollution and its deleterious effects on astronomy.
7.2 It is the opinion of the Hampshire Astronomical
Group that there is now an opportunity to adopt robust controls
on the worst excesses of light pollution and trespass.
7.3 If the UK Government drafted some regulatory
control within a legal framework it would not be the first to
adopt such measures. Many regions and national governments around
the world are now adopting such laws or have done so. The Czech
Republic has enacted a national law restricting wasteful lighting
protecting the night sky, other regions around Europe have similar
regulations. The USA was one of the first countries in the world
to see local ordinances (by-laws) restricting wasteful upward
light.
7.4 Whilst your committee is restricting
itself to the matter of light pollution and astronomy it should
be acknowledged that there is growing scientific evidence that
wasteful light also has a serious and deleterious effect on the
migratory patterns of birds and can decimate local insect populations.
7.5 The Hampshire Astronomical Group believes
that this issue of light pollution or trespass needs to be seen
in the wider environmental context, and that what is good practice
for the preservation of the night-sky is also protecting the wider
environment and using earth's precious resources wisely.
8. RECOMMENDATIONS
8.1 The Hampshire Astronomical Group would
want to see Parliament investigate and then adopt similar legislation
as to that which exists in other countries with the specific aim
of protecting the environment from the problem of Light Pollution/Trespass.
8.2 That legislation in the Czech Republic,
Lombardy region of Italy and the Catalonian region of Spain be
examined as a starting point in drafting such legislation.
8.3 As a minimum, the Hampshire Astronomical
Group would want to see a strengthening of planning law so that
night-time effect of any illumination is a material consideration
when determining planning applications that are proposing to install
lights/lighting.
8.4 The Hampshire Astronomical Group would
want to see an amendment to the Control of Pollution Act regarding
the issue of lighting, and have excessive lighting viewed alongside
other potential nuisances.
8.5 The principle of zero upward light spill
(eg above the horizontal from the light source) and restricted
lux levels on the ground outside of the curtilage to a prescribed
distance, from a property utilising any illumination should be
embodied within any proposed regulations.
April 2003
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