Memorandum
City of Lawrence
City Manager’s Office
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TO: |
Thomas M. Markus, City Manager |
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FROM: |
Brandon McGuire, Assistant to the City Manager |
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CC: |
Charles Soules, Public Works Director |
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DATE: |
February 14, 2017 |
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RE: |
Review of Information related to City-owned and Westar-owned outdoor LED lighting |
Request from Lawrence Alliance for Responsible Lighting
During public comment at the November 21, 2017 City Commission meeting, representatives of the Lawrence Alliance for Responsible Lighting (LARL) requested that the Commission adopt an ordinance incorporating the following proposed language. For reference, Correlated Color Temperature (CCT) defines the color appearance of light emitting diodes (LEDs) and is measured in Kelvins (K).
“Henceforth, all street, task, and security night lighting installed in, or at the direction of, or owned by the City of Lawrence, KS, including Westar lights shall have light sources with Correlated Color Temperature preferably at or below 2700K, but in no case greater than 3000K.
Lighting shall be no brighter than 50 lux, the brightest limit being for street lights. Light shall be directed downward in full cutoff fixtures using beam angles of 120 degrees or less for street lights, 90 degrees or less for security lighting in residential areas or in any lights within 500 meters of the Baker Wetlands.”
LARL’s request is motivated by the issuance of the following three guidelines pertaining to LED lighting issued by the American Medical Association in June 2016 (attached).
1. The AMA supports the proper conversion to community-based Light Emitting Diode (LED) lighting, which reduces energy consumption and decreases the use of fossil fuels.
2. The AMA encourages minimizing and controlling blue-rich environmental lighting by using the lowest emission of blue light possible to reduce glare.
3. The AMA encourages the use of 3000K or lower lighting for outdoor installations such as roadways. All LED lighting should be properly shielded to minimize glare and detrimental human and environmental effects, and consideration should be given to utilize the ability of LED lighting to be dimmed for off-peak time periods.
The Commission directed staff to place LARL’s request on a regular agenda for deliberation.
Regulatory Authority
The Kansas Corporation Commission (KCC) is the regulatory agency in the matter of the electric utility’s (Westar’s) streetlight standards and rates. Westar’s provision of lighting to incorporated cities along public streets, alleys and thoroughfares is subject to the Westar Streetlighting Tariff approved by the KCC. Rates for streetlighting services using standard equipment are set forth in the tariff. Westar establishes the standards for the company’s streetlight components and fixtures and their standard fixtures have a 4000K CCT rating. Westar has advised the City that LARL’s request would require the installation of nonstandard LED fixtures. The tariff authorizes Westar to install nonstandard fixtures “at its option and upon customer’s request.” The tariff also establishes a basis of cost calculation for nonstandard fixtures. The tariff states,
“All nonstandard components shall be priced at one and three fourths percent (1 ¾%) of total investment in such facilities, plus 4.202 cents per kWh for all kWh supplied to nonstandard fixtures, plus one-twelfth of the annual cost of nonstandard lamp renewals and pole painting (if applicable).“
Without further direction about how the Commission would like to proceed on this matter, it is difficult to determine how Westar would respond to such a request from the City. It is also difficult to calculate the potential cost impact to the City from pursuing the conditions of LARL’s request.
Professional Practices
For several years the City has been converting roadway lighting and all other indoor and outdoor lighting from High Pressure Sodium to LED fixtures. Virtually all city-owned indoor lighting utilizes LED fixtures. Over the last year the Facility Conservation Improvement project (FCIP) upgraded City-owned lights to LED technology including 300 outdoor sports field lights, approximately 100 pedestrian pathway lights (including completion of the downtown conversion to LED), and parking lot lighting at the Community Health Building and Riverfront and New Hampshire garages. Additionally, the City owns approximately 1,200 streetlight fixtures at roundabouts, intersections, and downtown. Virtually all City-owned lighting utilizes LED fixtures with a CCT of 4000K (more for ball fields) based on the Illuminating Engineering Society (IES) guidelines.
Conversion to current LED fixtures has improved the visibility of pedestrians and the traveling public. The more neutral white light from 4000K LEDs provides better awareness, color recognition and small target visibility compared to fixtures with a softer orange glow, such as LEDs with CCT ratings of 2700K – 3000K. LED lighting provides better illumination and consumes less electricity than the previous High-Pressure Sodium (HPS), mercury vapor or metal halide fixtures. Even so, efficiency in LED fixtures vary due to factors including CCT rating. LEDs with a CCT rating of 4000K are more energy efficient than those with CCT ratings of 3000K or less.
When addressing roadway, pedestrian and parking facility lighting needs, the City applies the technical practices and guidelines of the IES. The IES was established in 1906 and is the internationally recognized technical and educational authority on illumination. IES has 8,000 members worldwide, including engineers, architects, designers, educators, students, contractors, distributors, utility personnel, manufacturers, and scientists. The IES formally collaborates with the International Dark-sky Association and has invited the AMA to partner in research on the effects of LED lighting on human health. The IES is an accredited Standards Development Organization (SDO) under American National Standards Institute (ANSI) approved procedures. The City’s Traffic System Supervisor serves on the IES Roadway Lighting Committee, which is the technical committee that researches and develops best management practices for lighting roadways and streets to enhance visibility and driver and pedestrian safety. This committee maintains the IES Recommended Practices for both Roadway Lighting and Parking Facilities that the City uses to guide management practices of these facilities.
Public Health
Public outdoor lighting is a complex issue, especially when considering the applications along the transportation system. The City’s professional staff apply IES technical standards and guidelines to outdoor lighting management. These guidelines consider a broad array of factors, including public health, safety and welfare as well as economic and environmental factors.
The field of public health may take an even broader perspective than that of the IES or AMA. The public health profession uses a tool called a ‘health impact assessment’ to inform public policy and program decisions. A health impact assessment is a systematic review process that uses an array of data sources and analytic methods and considers input from stakeholders to determine the potential effects of a proposed policy, plan, program, or project on the health of a population and the distribution of the effects within the population. This process can be useful in informing and providing a rational basis for public policy decisions.
Conclusion
City staff cannot refute the AMA’s position but does acknowledge that the issue is complex, and the scientific knowledge is still developing. From a public health perspective, the issue is quite complex.
As written, the request would apply to all City-owned and Westar-owned outdoor lighting. Eventually all outdoor lighting facilities would be fitted with LED fixtures rated at 2,700K – 3,000K. The request would arbitrarily restrict the City’s application of best management practices for all outdoor and roadway lighting.
The City lacks the regulatory authority to compel Westar to change its streetlight standards and rates. The City spent $850,000 on streetlighting service in 2017. The LARL proposal will result in additional costs to the City although it is difficult to determine the cost impact due to limited available information.
Recommendation
City staff advises against imposing the restrictions on LED outdoor lighting as requested by LARL.