IDA's Model Lighting Ordinance Open for Review

I was just wondering what the IDA was up to when I got this bit of news from
a yahoo list I am on called astro-officers. Either way you want to go, it is
good to read up on this and comment. I am about to request my own copy of
the MLO but I wonder why they can't just put it up on their website instead
of making people send an email with all kinds of information????

To request a copy of the "MLO" go he
http://www.darksky.org/ordsregs/mlc/modlicod.html

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The below text can be found at: http://www.fixthemlo.org/

On November 1st, a group of concerned of dark sky proponents sent the
following letter to the Board of Directors of the International Dark-Sky
Association. That letter, duplicated below, and this "fix the MLO" web site
represent this group's efforts to stop the adoption of the IDA's proposed
MLO in its current form. The letter's signers are listed following the
letter.

DATE: November 1, 2004
TO: Board of Directors, International Dark-Sky Association
and Model Lighting Ordinance Review Panel
IDA Model Lighting Ordinance
Three years ago the IDA announced its intention to draw up a new model
ordinance to assist communities that wish to regulate outdoor lighting. Some
of the dark-sky advocates whose names appear at the end of this letter
served on the Working Group that was formed to develop this model. We found
to our dismay that comments from those not affiliated with the lighting
industry were rarely heeded or even acknowledged during the drafting
process. A number of us have communicated individually with IDA officers,
directors, or staff but have found that expressions of concern have fallen
largely on deaf ears. All of us have concluded that the document released
for "public review" as Draft 2004.1 indicates a direction for the Model
Lighting Ordinance that will fail to serve its intended purpose.

We believe this draft is so severely flawed as to require major overhaul and
that IDA should cease promoting it until there is broader agreement on its
content. IDA has said that the MLO is to be a "living" document, which seems
somewhat at odds with the supposed intent to have identical ordinances in
many communities. More important, the kinds of incidental revisions that
term suggests are, we believe, beside the point. We are convinced that much
more fundamental change is needed.

We are aware of the complex and cumbersome process that has been instituted
for offering detailed comment on v2004.1. This letter addresses more
generally some of the basic problems with the current draft and, we hope,
makes clear that dissatisfaction with it is not limited to a few isolated
and "unqualified" individuals.

We are distressed at the prospect of having to actively oppose an IDA
document, but if the MLO persists in its present form or similar, many of us
see no alternative. Here are three of the principal changes we believe are
required to make this MLO worthy of IDA, acceptable to the undersigned, and
we believe, acceptable to the broader membership of IDA.

1.. Make it user friendly
We believe a model lighting ordinance should be as simple and easy to
understand as possible. It should be written for the intelligent layman, not
for "lighting professionals." Lighting ordinances need to be understood by
the people who must enact, implement, and enforce them. Many of us have been
intimately involved in the writing, enactment, and implementation of
lighting codes in our communities. Probably the most consistent problem we
face is that communities have considered lighting codes too complicated.
This MLO is much more complicated than the most complex code we have ever
worked with.

Much has been made of the fact that many local lighting laws are not
"technically correct," but the significance of this seems to have been
missed. To the extent that this is true of existing laws, it demonstrates
that with rare exception lighting professionals are not the ones that get
codes enacted. Though the lighting professionals involved in the drafting of
the MLO have contributed great value to the effort by assuring it is
technically correct from their standpoint, we believe the vital practical
perspective gained in our many collective years of working with communities
to enact and implement lighting codes has been lost. A model must be written
for all of the people who will be using it, including not only lighting
professionals but also electricians, lighting retailers and manufacturers,
architects, municipal planners, small-business owners, and the general
public. In fact, in nearly all communities concerned with the preservation
of dark skies, lighting professionals are involved with only a tiny fraction
of lighting projects

We believe a model ordinance that addresses as a first priority dark-sky
preservation can be technically correct yet still written in plain English.
To cite but one example, the shielding definitions in MLO 2004.1 refer to
"luminous flux." This will communicate nothing to the layman, and the
present definitions do little to help. Why not just "light"? Or perhaps
"lumens" (clearly defined!)? How would that be incorrect?

The current MLO goes considerably beyond simple dark-sky preservation,
moving into the realm of detailed lighting design with specifications on
pole heights, luminaire photometrics, maximum wattage limits, and myriad
lighting use types with associated power density and area calculations. To
accomplish all of this, the MLO has become much too complex. Dark-sky
protection can be accomplished with a much simpler document than this.

2.. Use the right "metric"
We believe the metric used to address outdoor lighting should be a measure
of light. A watt is a measure not of light but of power. With efficacies
(mean lumens per watt) ranging from 8 for 25-watt incandescent to 183 for
180-watt LPS, using power as a surrogate for light must inevitably result in
limits too high to most effectively curtail excess light. This problem will
only worsen with the adoption of emerging and not-yet-invented technologies.
We are aware that watts-per-square-foot has a place in some energy codes,
but we do not believe it has been demonstrated to be successful in
controlling light pollution to the degree we feel necessary. Using lumens
and/or footcandles as the measure of light entirely eliminates this problem,
and such standards have already been shown to be effective in many lighting
codes.

3.. Stay focused on dark skies
Since this model is to be promulgated by the International Dark-Sky
Association, it should establish criteria that will be the "gold standard"
of night-sky protection. If a community finds the MLO overly strict, it can
simply loosen the requirements as it sees fit for local application. But the
aim of this MLO should be to provide guidance for minimizing light pollution
to the greatest degree possible consistent with safety, security, and
utility.

The present MLO draft fails this standard in many ways in addition to the
watts-per-square-foot flaw. A few examples:

a.. It fails to prohibit light trespass.
b.. It fails to prohibit upward-directed sign lighting--a huge source of
light pollution in many communities.
c.. It fails to require curfews. (Reducing power 50% is not the same as
turning it off.)
d.. It excludes public lighting of every sort. Guidance for
streetlighting is essential even if some communities choose to place it in a
separate document, and we see no reason to exempt municipal lighting for
building exteriors, parking lots, sports facilities, etc.
e.. It permits lighting in Zone Zero of five zones. There needs to be a
zone where no permanent lighting is permitted.
f.. It fails to address pre-existing non-conforming lighting. Guidance
needs to be provided, in supplementary materials if not in the model itself,
for communities wishing to establish sunsets.
In sum

IDA's stated purpose is "to protect and restore...mankind's heritage of dark
skies." We do not feel the MLO in anything like its present form will be
helpful to those working "on the ground" to establish regulations that will
achieve this objective; in fact, we believe it will substantially undermine
such efforts.

A number of us are questioning whether we will be able to continue
supporting IDA if it adopts this MLO. We will certainly not support its
enactment in our communities. We implore you not to sabotage the work we are
doing to advance IDA's goals.

We would appreciate a written response to this letter from the Board.

Respectfully,

Lee Altenberg, PhD
Karolyn Beebe, IDA
Mike Best, IDA
Gary Citro, IDA
Barry A.J. Clark
Gail Clyma, IDA/IESNA
Bob Crelin, IDA
Kevin Fleming, Chairman, ICOLE
Bonnie Garrity, IDA
John Alan Gilkison, National Public Observatory
Dan Green, IDA
Scott Griswold
Cliff Haas, CRL/IESNA/NELPAG
Susan Harder, IDA/IESNA
Missy Holohan, IDA
Chris Luginbuhl, IDA/IESNA
John McMahon, PhD
George Nickas, ICOLE
Johnny Noles, IDA
David Oesper, IDA/IESNA
Francis Parnell, IDA
Stephen M. Pauley MD, IDA/IESNA
Tim Poulsen, IDA
Julie Schaar, IDA
Mark Schuyler LC, IDA/IESNA
Leo Smith, IDA
Stan Stubbe, IDA/IESNA;
Hazel Thompson, IDA.

--
Dawn Baird-Chleborad
www.astronerds.com * Great holiday gifts for or from astronomers*