Memorandum from the Commission for Architecture
and the Built Environment (CABE)
1. CABE is a non-departmental public body,
jointly funded by the Department for Culture, Media and Sport
(DCMS) and the Office of the Deputy Prime Minister (ODPM). We
are the nation's champion for better places: places which work
better, feel better, are better. CABE's interest in the issue
of lighting in our towns and cities arises from a number of areas
of our work. Through our Design Review programme, which offers
free advice on the design of selected projects, and our Enabling
programme, which provides support and advice to clients during
the early stages of projects, we have offered advice on a large
variety of development schemes, some of which include lighting
as an important feature. CABE has conducted research into improving
the quality of our streets, and this resulted in the publication
last year of our document "Paving the Way". A number
of the issues discussed in it are relevant to the lighting of
streets and buildings. In addition, our predecessor organisation,
the Royal Fine Art Commission (RFAC), published a report on this
issue called "Lighten Our Darkness", and many of the
conclusions included in that document continue to be relevant.
2. CABE believes that there is a clear need
for more thought to be given to the lighting of our towns and
cities, and for local authorities in particular to give greater
guidance on good practice. We support the lighting up of selected
buildings, engineering structures and public spaces and believe
that this can add to public enjoyment of our towns and cities.
However, this needs to be done with care and with the joint aimentirely
achievable in our viewof enhancing the appreciation of
those features which are lit, while minimising the contribution
that the lighting makes to the problem of light pollution.
3. At the moment most of our towns and cities
are visually disappointing, or, at worst, visually disastrous
at night. In some places the lack of lighting is a problem, in
others underlighting, overlighting or the use of inappropriate
colours and forms of lighting create poor environments. Lighting
fixtures which are badly designed and haphazardly controlled are
a problem both aesthetically, and in terms of contributing to
light pollution. We recognise that a serious consequence of the
poor nature of much of our lighting is that urban light is blotting
out the night sky. It is a cause for serious regret that sky glow
now means that it is virtually impossible to see the stars in
many towns and cities.
4. A common source of light spill is street
lighting and in this regard we believe that safety and security
should not be achieved at the expense of other visual considerations.
Light spill can obscure the details and form of adjacent facades,
as well as contributing to light pollution. We would urge the
use of shields which restrain light from trespassing. On aesthetic
grounds, we would also support consideration of light sources
other than low-pressure sodium, which has a distinct and unappealing
orange colour.
5. In order to tackle the problems associated
with much of our street lighting, we believe that there needs
to be a greater understanding of the relevance of urban design
to highways issues. Currently there is a lack of clarity about
what is guidance and what is mandatory regarding the design of
highways and their immediate environment. In this respect, we
think a summary detailing the statutes, regulations and design
guidance affecting streetscape design and management should be
produced. This should include guidance on suitable design standards
which are appropriate to their environment; some of the problems
with street lighting arise from the fact that standard highways
solutions are applied in settings where they are inappropriate,
for example the application of trunk road lighting standards to
minor residential streets. We would like to see existing guidance
on highway design rewritten to bring it in line with Government
policy on design, sustainability and the urban realm, and we think
that urban design should form a key component of all training
courses for professionals dealing with streetscape and highways.
6. With regard to the lighting of buildings
and other structures, not all lighting which is poor aesthetically
also contributes to light pollution of the sky, but the two are
inextricably linked in many cases. For example, the excessive
floodlighting of a building can result in the "flattening"
of architectural details, as well as generating light pollution.
We therefore think that tackling poor aesthetic lighting and thereby
enhancing appreciation of our architecture, public spaces and
natural environment goes hand in hand with tackling the light
pollution which has such a damaging affect on our appreciation
of the night sky.
7. In terms of current planning guidelines
and controls on the design of lighting, CABE agrees with the view
expressed by the ODPM document "Lighting in the Countryside:
Towards Good Practice" that "the planning system offers
much greater scope than is currently realised to control, guide
and influence lighting associated with new development".
8. Although exterior illumination does not
in itself require planning permission, the structures and installations
involved may require planning permission or the lighting may be
associated with a development proposal which requires planning
permission. Where this is the case, the lighting elements can
be influenced by use of planning conditions.
9. Local authorities should consider the
need for policies on lighting in their development plan. Since
planning applications are determined in accordance with the development
plan unless material considerations indicate otherwise, the existence
of policies on lighting would be a useful tool in securing appropriate
lighting as part of development schemes. A number of Planning
Policy Guidance Notes provide support for the inclusion of lighting
issues in the preparation of development plan policies and, in
turn, the determination of planning applications.
10. There are more controls with respect
to listed buildings, where both the local authority and English
Heritage can be involved, and consent is certainly needed if the
lighting fixtures affect the special architectural or historical
interest of the building in question. Local authorities should
consider the importance of policies and controls within areas
which may be dependent on strong architectural cohesion and plan
for their character, to ensure that the lighting of individual
buildings respects that character, as well as seeking to avoid
light pollution.
11. We would like to see more local authorities
draw up guidelines for good practice in the design of lighting
and this could be contained in Supplementary Planning Guidance.
Such guidance should include:
advice on the amount and type of
light required for specific tasks and purposes
encouragement to good neighbourliness
environmental awareness and advice
on energy consumption and efficiency
advice on fixtures, their positioning
in relation to façade design, with the aim of avoiding
glare and light pollution
the encouragement of lighting trials
the suggestion that installations
should be treated as a part of the overall architectural concept.
advice on the colour of lighting
to be used and the effect of different lighting on building materials
the accessibility and maintenance
of fittings
the importance of ensuring that replacement
parts match the original scheme eg in terms of the colour of the
light
consideration of the vulnerability
of fittings to theft
In drawing up guidance, local authorities could
refer to a number of advisory publications, including the RFAC's
report "Lighten Our Darkness" and the Chartered Institution
of Building Service Engineers and the Institution of Lighting
Engineers report "Lighting and the Environment : A Guide
to Good Urban Lighting". In addition the ODPM have published
"Lighting in the Countryside : Towards Good Practice",
which contains much relevant advice, although not all of it will
be applicable in urban situations. Clearly it would be desirable
for there to be comprehensive national guidance which could form
the basis for local policies.
12. We believe that there should be a comprehensive
lighting strategy for every urban centre, to ensure that guidance
is carried out in a coordinated manner.
A lighting strategy would give consideration
to aesthetic concerns and aim to ensure that all those making
lighting decisions acted in concert with one another and with
visually literate experts to create a well-considered and comprehensive
effect. In certain areas of towns and citiesfor example,
in important squaresthe aim should be to coordinate the
lighting of the various buildings and other features in and around
the square, not only to increase enjoyment of the individual buildings
but also to create a harmonious effect which, for example, suggests
a hierarchy of buildings through the use of lighting.
13. It is our view, which we have stated
a number of times in reviewing schemes which have come before
us, that the lighting of significant buildings should be considered
as an integral part of the design process, and not treated as
an "add-on" at a later date. Where a building is likely
to be lit, we would therefore like to see local authorities insist
upon evidence of a properly considered lighting scheme as part
of any design submitted as a planning applicationthis will,
of course, be easier if the requirement for appropriate lighting
is a policy in the development plan. Such a lighting scheme should
also be shown to be consistent with any wider lighting strategy
which may exist for the area in which the proposal is located.
As noted previously, local authorities can ensure implementation
of appropriate lighting schemes after the granting of planning
consent by means of planning conditions, and we would urge them
to do so.
April 2003
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