111721 TA2018001 BOS REPORT_PART5.PDF
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USER’S GUIDE - Page 10 ORDINANCE TEXT - Page 10
Exceptions to III.(C.) 1. Automatic lighting controls are not
required for the following:
a. Lighting under canopies.
b. Lighting for tunnels, parking garages, garage entrances,
and similar conditions.
2. Automatic Lighting Reduction Requirements
The Authority shall establish curfew time(s) after which total outdoor
lighting lumens shall be reduced by at least 30% or extinguished.
Exceptions to III.(C.) 2. Lighting reductions are not required
for any of the following:
a. With the exception of landscape lighting, lighting for
residential properties including multiple residential
properties not having common areas.
b.
c. Code required lighting for steps, stairs, walkways, and
building entrances.
d. When in the opinion of the Authority, lighting levels must
be maintained.
e. Motion activated lighting.
f. Lighting governed by special use permit in which times of
operation are specifically identified.
g. Businesses that operate on a 24 hour basis.
When the outdoor lighting consists of only one luminaire.
III. GENERAL REQUIREMENTS (cont.) - Ordinance Text
MODEL LIGHTING ORDINANCE - USER’S GUIDE
TEXT
MODEL LIGHTING ORDINANCE -
CURFEW REQUIREMENTS - User’s Guide
The intent is to reduce or eliminate lighting after a given time. Benefits
include reduced environmental impact, longer hours of improved
astronomy, energy savings, and improved sleeping conditions for
residents. Additionally, some police departments have indicated that
post-curfew light reductions make drive-by patrolling easier because it
allows them to see further into and through a site.
The authority should determine the time of curfew and the amount of
lighting reduction based on the character, norms and values of the
community.
Typically, curfews go into effect one hour after the close of business.
Restaurants, bars and major entertainment facilities such as sports
stadiums, may require the curfew go into effect two hours after the
close of business. The authority may elect to have no curfew for facilities
with shift workers and 24 hour operations, or to extend the curfew time
to meet specific needs. The MLO can be modified to address those
concerns.
Areas without street lights or with very low ambient light levels should
consider turning off all non-emergency lighting at curfew while
commercial areas or urban areas may prefer a reduction in lighting
levels. A reduction of at least 30% is recommended for most uses.
ORIGINAL PAPER
Artificial lighting in the industrialized world: circadian disruption
and breast cancer
Richard G. Stevens
Springer 2006
Abstract
Breast cancer risk is high in industrialized
societies, and increases as developing countries become
more Westernized. The reasons are poorly understood. One
possibility is circadian disruption from aspects of modern
life, in particular the increasing use of electric power to
light the night, and provide a sun-free environment during
the day inside buildings. Circadian disruption could lead to
alterations in melatonin production and in changing the
molecular time of the circadian clock in the suprachias-
matic nuclei (SCN). There is evidence in humans that the
endogenous melatonin rhythm is stronger for persons in a
bright-day environment than in a dim-day environment;
and the light intensity necessary to suppress melatonin at
night continues to decline as new experiments are done.
Melatonin suppression can increase breast tumorigenesis in
experimental animals, and altering the endogenous clock
mechanism may have downstream effects on cell cycle
regulatory genes pertinent to breast tissue development and
susceptibility. Therefore, maintenance of a solar day-
aligned circadian rhythm in endogenous melatonin and in
clock gene expression by exposure to a bright day and a
dark night, may be a worthy goal. However, exogenous
administration of melatonin in an attempt to achieve this
goal may have an untoward effect given that pharmaco-
logic dosing with melatonin has been shown to phase shift
humans depending on the time of day it’s given. Exoge-
nous melatonin may therefore contribute to circadian dis-
ruption rather than alleviate it.
Keywords
Breast cancer Æ Circadian disruption Æ
Melatonin Æ Shift work
Introduction
There is a large variation in risk of breast cancer among
societies of the world, with the relatively more industrial-
ized showing five-fold or higher risk than the least indus-
trialized [1]. In contrast with other common cancers which
also vary across societies, the reasons for the rise in breast
cancer that comes with Westernization is poorly under-
stood. For lung cancer, the reason for it’s variation is very
clear: as societies pick up the habit of smoking, lung cancer
incidence and death increase accordingly and dramatically;
liver cancer is largely explained by endemic hepatitis virus
infections, and alfatoxin; stomach cancer declines as
societies refrigerate food; colon cancer is strongly influ-
enced by red meat intake, sedentary lifestyle, and aspirin
ingestion. In contrast, the majority of the variation in breast
cancer risk among societies, and rising risk within socie-
ties, is unaccounted for by the established risk factors for
breast cancer [2, 3]. There is increasing support for the idea
that circadian disruption from aspects of modern life,
especially electric lighting, is a factor in the population
burden of breast cancer [4]. Studies of shift workers, as
suggested by Stevens et al. [5], have reported elevated risk
[6–10], and studies in blind women, as suggested by Hahn
[11], have reported reduced risk [11–14]. The studies in
blind women were conducted under the belief that blind
Supported by grant ES11659 from the National Institute of
Environmental Health Sciences.
R. G. Stevens (&)
University of Connecticut Health Center, Farmington,
CT 06030-6325, USA
e-mail: bugs@neuron.uchc.edu
Tel.: +1-860-679-5475
Fax: +1-860-679-5464
Cancer Causes Control (2006) 17:501–507
DOI 10.1007/s10552-005-9001-x
123
women, as opposed to sighted women, do not have the
opportunity
for
nocturnal
melatonin
suppression
by
exposure to light during the night.
‘Light-at-night’ and breast cancer
Originally, it was argued that part of the rising risk of
breast cancer in industrialized societies was due to in-
creased use of electric lighting which could suppress
melatonin [15]; a suppression of melatonin was hypothe-
sized to increase estrogen [16], and thereby increase risk.
This idea was based on experiments in rodents on the
effects of constant light exposures on mammary tumori-
genesis [e.g., 17], and on the epidemiology of breast cancer
in which risk was highest in the most industrialized, and
thereby most electrified, societies. However, Shah et al.
[17] found no effect of constant light on plasma estradiol
levels in rats, although melatonin administration lowered
estradiol. It is not clear whether melatonin or light-at-night
affects estrogen production in humans, the data being
limited and conflicted [18–25].
Apart from effects on estrogen production, there are
several mechanisms by which melatonin might affect
breast cancer that have emerged (reviewed in [26]). These
include direct oncostatic effects, interference with estrogen
receptor function, effects on immune function, and effects
on free radical biology. In particular, an effect of light at
night, including dim light, on melatonin production can
have profound effects on growth and progression of both
transplanted liver tumors in rats [27] and transplanted
human-derived breast tumors in rats by altering linoleic
acid metabolism [28].
The first study of prediagnosis melatonin level did not
find a difference between women who later developed
breast cancer and those who did not [29]; the authors note,
however, that the early studies of estrogen and breast
cancer were inconsistent, and it has required a combined
analysis of many studies to show that there is in fact a
strong association [30]. In addition to affects on melatonin,
the potential for light to alter circadian rhythm generation
in the suprachiasmatic nuclei (SCN) leads to the potential
for disruption of clock gene communication with cell cycle
regulation in the mammary tissue [4, 31]. Disruption of cell
cycle regulation and/or apoptosis opens a large new area
for investigation of light effects on cancer risk.
Light and exogenous melatonin
Suppression of the normal nocturnal surge in melatonin
by exposure to light at night may increase breast cancer
risk by several different mechanisms [26, 28, 32–34].
(Stress and cortisol may also play a role in circadian
disruption and cancer [35, 36]) Therefore, maintenance of
a strong melatonin rhythm seems desirable. However,
supplementation with melatonin could result in ‘Circadian
Disruption’ itself due to the emerging understanding of
the impact of exogenous melatonin on the human circa-
dian rhythm. In fact, the circadian phase shift induced in
humans by a pharmacological bolus of melatonin can be
comparable to that induced by a bright light stimulus.
Wirz-Justice et al. [37] conducted a study in which 9
healthy young men were subjected to one of 4 conditions:
5 mg of melatonin at 20:40 in the evening, a 3 h period
of 5000 lux light beginning at 21:00, both, or neither
(with placebo for the melatonin tablet). All nine subjects
received all four exposure conditions. Melatonin onset
was then measured the day following the treatments under
a constant-routine, dim-light regime (>10 lux). Under the
light-only exposure, there was a 41 min phase delay;
under the melatonin-only exposure, there was a 24 min
phase advance. The two together tended to cancel each
other: with both exposures, dim-light melatonin onset
(DLMO) was not significantly different from exposure to
neither.
Before Lewy et al. [38], it was speculated that the hu-
man pineal was insensitive to light. Since that seminal
work, the intensity of light at night shown experimentally
to be required to lower melatonin has declined to very low
levels [39].
It is also becoming clear that light level during the day
can affect melatonin secretion at night [40], and also sen-
sitivity to a light exposure at night on suppression of
melatonin [41]. Hebert et al. [41] conducted an experiment
in which 12 young, healthy subjects (6 male and 6 female)
spent 1 week in a bright-day environment (exposed to sun)
and 1 week in a dim-day environment (dark goggles worn
during the day). At the end of each week, the subject’s
sensitivity to melatonin suppression by light in the middle
of the night was assessed. On the 6th night in dim light
( < 15 lux), a baseline of melatonin was determined by
saliva sampling every 30 min. During the next night, the
subjects were exposed to 500 lux light for 3 h beginning at
1 am. Percent light suppression was significantly greater
after the dim week than after the bright week. However,
there was a greater amplitude of melatonin production after
the bright week than after the dim week.
Light and cancer in mice and rats
Among the first experimenters to investigate the impact of
constant lighting on mammary tissue susceptibility to
tumorigenesis was Jo¨chle [42]. He reported that C3H-A
mice under constant light showed accelerated development
502
Cancer Causes Control (2006) 17:501–507
123
of spontaneous tumors, whereas C3H–HeJ mice under
constant light showed delayed spontaneous mammary
tumor development and a longer life span. The C3H–HeJ
mouse has a degenerate retina (rd) and is visually blind.
However, it has now been shown that nocturnal melatonin
in the C3H/He rd mice can be suppressed by light [43].
Among the first to investigate the effect of light on
chemically induced mammary tumors in rats was Khaetski
[44; as described in 45] who conducted experiments in
which ‘outbred rats’ were exposed to constant light
beginning at four months of age, and given dimethyl-
benzanthracene (DMBA). Compared to rats on 12:12
light–dark (LD) cycle and which also received DMBA,
those on constant light had reduced mammary tumor yield.
In contrast, Khaetski reported that when constant light did
not start until 4 weeks after DMBA administration, tumor
development was accelerated compared to rats which
continued on the 12:12 LD cycle.
Within the context of the conflicting early experiments
in which mammary tumors were either stimulated or
reduced in rodent models, the question becomes what are
the factors which influence tumor yield from constant
light? In the 1980s, Shah et al. [17] conducted an elegant
series of experiments in which constant light and pineal-
ectomy were used to investigate whether melatonin might
explain the effect of light. They found that constant light
beginning before birth significantly increased terminal end
buds of the female offspring at maturity, and increased
susceptibility to DMBA-induced mammary tumors. In an
attempt to replicate this finding, Anderson et al. [46] ob-
tained weanling female rats from a supplier, placed one
group on constant light and the other on 8:16 light/dark
regimen, and administered DMBA when the animals were
52 days of age. In contrast to Shah et al. [17], Anderson
found a significant reduction in mammary tumor burden in
the constant light group. They also found, unexpectedly,
that 29 of the 50 rats in the constant light group showed
mature milk glands in the mammary glands at age 141 days
despite being virgin, whereas none of the 50 rats on LD
showed any such structures.
The reason for the different tumor response appears to
be due to differences in the age of the rat at first exposure
to constant light which resulted in differences in mammary
tissue development. This, in turn, would alter tumor sus-
ceptibility [47]. Constant light began in utero in Shah et al.
[17], but began at age 26 days in Anderson et al. [46].
After a replication of these exposure conditions, Russo
et al. [48] conducted a detailed histological examination of
the mammary tissues, and found that light beginning at
26 days of age (LL26) produced a very different mammary
gland development than light beginning in utero (LL0);
among the LL26 rats, mammary gland differentiation was
dramatically accelerated compared to the LL0 rats, and
thereby at the age of 50–55 days were less susceptible to
DMBA- induced tumorigenesis.
Another possibility is that light exposure of pregnant rats
restricted to the period of gestation might increase mam-
mary density and susceptibility to chemically induced
mammary tumorigenesis of the female offspring later in
their lives, even though after birth they were maintained on
a 12:12 light–dark cycle. This is based on the idea that
in utero exposures which alter hormones relevant to breast
cancer might increase the lifetime risk of daughters [49, 50].
Shift work and diurnal preference
Shift work presents a quantifiable exposure that can result
in circadian disruption. Time of day preference (or morn-
ing/evening preference; [51]) has been reported to predict
tolerance to evening or graveyard shift work. Those
workers who report a preference for morning being less
tolerant to night work, and more likely to stop this work for
medical reasons [52]. Melatonin profile has also been
reported to be the best predictor of Horne-O¨ stberg score for
morningness/eveningness
among
the
three
circadian
markers: rectal temperature, heart rate, and melatonin.
Griefahn [53] conducted a controlled constant routine
study in which 51 persons completed the Horne-O¨ stberg
questionnaire and were then kept under strict bedrest for
24 h under constant dim light. Among both women (17
subjects) and men (34 subjects), the peak melatonin during
the night hours was about 4 h earlier in the morning types
than evening types. In addition, the total melatonin pro-
duction was greater in morning types. A possible impli-
cation of this is that shift-working women with a morning
preference, or who have a genetic polymorphic variant
associated with morning preference, may be at greater risk
of breast cancer than women with an evening preference.
Schernhammer et al. [25] present interesting new data
showing lower melatonin and higher estradiol in long-term
shift working nurses compared to non-shift working nurses
in the Harvard Nurses’ Health Study. These data are con-
sistent with an elevated breast cancer risk, but are not con-
sistent with an elevated risk of colon cancer in shift workers
(as these authors have also reported, [54]). Both Zhang et al.,
[55] and Nelson et al., [56] report higher estradiol associated
with lower risk of colon cancer. In contrast, high estrogen
(and estradiol in particular) has been convincingly associated
with increased risk of breast cancer [30].
Light and alcohol interaction
An emerging area of research is focusing on effects of diet
and of alcohol ingestion on circadian rhythms and on
Cancer Causes Control (2006) 17:501–507
503
123
modifying the effect of light on circadian rhythmicity. It is
becoming apparent that timing of meals and alcohol
ingestion can alter circadian rhythms independently of light
and also affect light’s ability to phase shift circadian
rhythms. These ideas may have relevance to risk of breast
cancer in women in the industrialized world. For those
women on non-day shift work schedules, the timing and
composition of meals may be an important co-factor in
their risk of breast cancer [28].
Change in time of day of meals in rats can uncouple the
circadian rhythm of the liver from that in the SCN [57].
Changes in circadian markers occur less rapidly in other
tissues such as kidney, heart, and pancreas than in the liver
[58], but eventually also become uncoupled from the SCN.
Baird et al. [59] reported on experiments in which rats
received ethanol injections at four times during the day:
1 am, 7 am, 1 pm, and 7 pm. Ethanol shifted circadian
activity and temperature rhythms depending on the time it
was administered.
Earnest and colleagues have been investigating the ef-
fects of developmental exposure to ethanol in rats. They
have found that ethanol during the period of rapid brain
development (postnatal days four to nine) causes perma-
nent changes in the endogenous circadian clock of the SCN
[60]. In particular, rats exposed to ethanol at ages four to
nine days postnatal (corresponding to third trimester
in utero exposures in humans), are more sensitivity to the
phase shifting effects of a light pulse during the dark period
of the circadian day [61]. Moderate to heavy alcohol
consumption has been consistently associated with in-
creased risk of breast cancer in women [62]. Stevens and
Hiatt [63] suggested that alcohol ingestion may result in
lowered melatonin levels which, in turn, may lead to ele-
vated circulating estradiol concentration in blood [16].
Stevens and Hilakivi-Clarke [64] hypothesized that expo-
sure of pregnant rats to ethanol would increase suscepti-
bility to mammary tumorigenesis in their female offspring
by raising estradiol. Hilakivi-Clarke et al. [65] have now
investigated this possibility. Pregnant female Sprague–
Dawley rats were pair-fed isocaloric diets containing either
16% alcohol of total energy (labeled as low), 25% alcohol
(moderate) or no alcohol, from day seven to day 19 of
pregnancy. These alcohol exposures generate blood alcohol
levels of about 61 mg/dl (0.061%, stimulatory dose) and
96 mg/dl (0.096%, modestly intoxicating dose), respec-
tively, and are much lower than those that induce fetal
alcohol syndrome in rodent models (which is between
0.15% and 0.175%). Female rats exposed to alcohol
in utero developed increased number of mammary tumors,
consistent with increased presence of terminal end buds
and epithelial density seen in these animals. The greatest
tumor yield and greatest mammary density in the female
offspring at their adulthood was in the moderate in utero
alcohol group. However, for estradiol, there was an in-
crease in pregnant rats in the lower alcohol group, but not
in the moderate alcohol group. This casts doubt on the
presumed estradiol-mediated mechanism for an in utero
alcohol effect on mammary tissue development and breast
tumorigenesis, and may indicate a role for altered circadian
functioning as a mechanism.
For breast cancer in women, and the potential for
exposures of pregnant women to increase risk in their
daughters later in life, the role of diet and alcohol in
modifying circadian rhythms and interacting with lighting
is an important area of pursuit.
Early susceptibility and lifelong risk
If cancer requires two or more mutations in a cell [66, 67]
as is currently believed, then the occurrence of breast
cancer at a young age does not require membership in a
susceptible subgroup. There will be a distribution of cases
across the age spectrum even if all women were genetically
identical and had similar carcinogen exposures throughout
life. However, there clearly are susceptible subgroups who
are indeed diagnosed with breast cancer at a younger age
such as carriers of a mutant BRCA1 allele. Mutations in
genes involved in fundamental processes of cell cycle
regulation and apoptosis would be expected to be more
strongly associated with risk in young women because
these processes begin at conception. Given the emerging
realization of the central role of the clock gene apparatus in
gene regulation throughout the organism, there may be
specific clock gene variants which also confer early sus-
ceptibility. These may both explain part of the family
history effect from germ line mutation, and confer
increased individual risk from sporadic mutation. In sup-
port of this possibility, Zhu et al. [68] have reported that a
polymorphic variant of the Per3 gene is associated with
breast cancer in young women.
Causal associations and biological mechanisms
There are two pathways to discovering causal associa-
tions: serendipity and prediction. The vast majority of
causal associations have been found by the first pathway,
serendipity. This has come from the astute observation of
a series of cases, from ecological studies, and from large
epidemiological studies examining many exposures. For
example, it became clear from epidemiology that smoking
‘caused’ (i.e., greatly increased risk) lung cancer long
before biological mechanisms were identified. There is
now consensus that the observed association of smoking
and lung cancer in epidemiological studies is causal; yet
504
Cancer Causes Control (2006) 17:501–507
123
there is still not consensus on exactly what mechanism(s)
is operating. Many examples of this exist including con-
sensus that the associations of HBV and liver cancer,
aspirin use and colon cancer, and alcohol and breast
cancer are all causal, yet for none of these is there con-
sensus on what is the dominant mechanism. For each,
much has been learned about the pathophysiology of
exposure to the agent, but it is still not clear what part of
this pathophysiology is most important, or whether there
are other unrecognized mechanisms which account for the
observed causal association.
To obtain consensus that an observed association is
causal requires more epidemiogical studies to eliminate
chance, and then bias, as accounting for the results. At
some point, it becomes clear that the exposure ‘causes’ the
disease. Factors to consider are described by Hill [69] and
include strength, consistency, dose response, reversibility,
coherence, temporality, and biological plausibility. Bio-
logical plausibility, or lack of it, is weak evidence for or
against the causality of an association; as Hill wrote:
‘…this is a feature we cannot demand.’
Strength of the association is only pertinent to a judg-
ment of causality, not of importance. Once an association is
judged to be causal, then even a very modest relative risk
can be very important. For example, smoking accounts for
more deaths from heart disease than from lung cancer de-
spite the fact that the relative risk is over ten for lung
cancer but less than two for heart disease.
The shift work association with breast cancer was found
only after a biological mechanism was proposed and a
prediction made (by letter to the Nurses’ Health Study in
1987, and then published in 1992; 5). Before this associ-
ation can be judged to be causal, chance and bias must be
eliminated as plausible explanations. The status of this
association is shown below.
It is rare for a postulated biological mechanism to lead
to an epidemiological observation, as was the case for shift
work and breast cancer. More typically, the epidemiolog-
ical observation is made and then this leads to laboratory/
basic science aimed at identification of potential biological
mechanisms.
Biological plausibility plays at best a minor role in
judging causality, and is not required. The value in iden-
tifying possible biological mechanisms can be for the
purposes of intervention, but not always. The mechanism
by which smoking causes lung cancer is irrelevant to the
intervention: smokers should just quit. For shift work,
however, identifying possible mechanisms would be very
helpful for interventions because shift work will not go
away. For shift work, a flow chart of hypothesized mech-
anism leading to a predicted association leading to evi-
dence for that association is shown below.
The studies can ‘prove’ the predicted association to be
causal, but cannot verify the originally proposed mecha-
nism. Proof of causality is attainable, whereas proof of the
mechanism is virtually unattainable. (The word ‘proof’ in
this context can only mean a consensus of experts. In
reality, proof exists only in mathematics.)
Conclusion
The topic of light, circadian disruption, and risk of breast
cancer has expanded in scope dramatically in the last ten
years. Since the first speculation that increasing light-at-
night might be raising breast cancer risk by reducing
melatonin and raising estrogen [15], many more potential
mechanisms for a light effect on breast cancer have
emerged [26]. The epidemiology has also advanced from
the original suggestion that shift workers would be at
Reason for
observed association
Status of evidence
Needed
Chance
Too few studies so far conducted to eliminate chance
despite ‘significance’ of some of them
More studies of different types and locations
Bias
Other factors associated with shift work may be the real
cause, e.g., alcohol consumption
Co-variate adjustment on all known risk factors –studies
of demographics of shift workers
Causal
If chance and bias are eliminated, then the association is
causal
But this does not prove the originally proposed
mechanism
Cancer Causes Control (2006) 17:501–507
505
123
increased risk. This was published in 1992 [5], although it
was communicated by letter to the Nurses’ Health Study
researchers in 1987; it was subsequently incorporated into
their 1988 questionnaire, and the question formed the
basis for findings from the Nurses’ Health Study of in-
creased risks of heart attack [70], breast cancer [10], and
colon cancer [54] in shift working nurses. Davis et al. [9]
also reported increased risk of breast cancer associated
with history of shift work in a case-control study; and
before either of these reports, Hansen [8, 71] reported
increased risk in shift workers in a huge case-control
study in Denmark. Hahn’s [11] idea that another test of
the ‘light-at-night’ hypothesis is the prediction that blind
women should be at lower risk has also yielded valuable
data. And now a new generation of studies can examine
dietary interactions with altered light exposures (such a
shift work), and focus on polymorphic variants in clock
genes for possible associations with risk and/or for
interactions with other factors that may disrupt circadian
rhythms.
Note added in proof
A study just released has reported a sig-
nificant inverse relation of melatonin and breast cancer risk in the
Nurses’ Health Study (Schernhammer ES, Hankinson SE (2005)
Urinary melatonin levels and breast cancer risk. JNCI 97:1084–7).
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123
HARVARD MEDICAL SCHOOL
BRIGHAM & WOMEN'S HOSPITAL
DEPARTMENT OF MEDICINE
DIVISION OF SLEEP MEDICINE
Steven W. Lockley, B.Sc. (Hons), Ph.D.
Division of Sleep Medicine
Brigham and Women’s Hospital
Harvard Medical School
221 Longwood Avenue
Boston MA 02115
Tel: 617 732 4977
slockley@hms.harvard.edu
Leo Smith
Board of Directors
International Dark Sky Association
1060 Mapleton Avenue
Suffield, CT 06078
May 31, 2008
Dear Mr. Smith:
This letter is in response to your inquiry as to whether light levels produced by streetlights might
adversely affect sleep, hormone levels and potentially health in people living in a dense urban
environment.
By way of introduction, I am a faculty member in the Division of Sleep Medicine, Brigham and
Women’s Hospital and Harvard Medical School and I have been studying the effects of light on
human circadian rhythms, including sleep, hormones, alertness and performance rhythms, for
15 years. Among other roles, I am the Chair of the Commission Internationale de l'Eclairage
(CIE) Division 6 Technical Committee TC6-63 ‘Photobiological strategies for adjusting circadian
phase to minimize the impact of shift work and jet lag’ and a Member of the Light and Health
Committee, Illuminating Engineering Society (IES) of North America. I am also on the Editorial
Boards of the journal Sleep and the Sleep and Health Education Program, Harvard Medical
School.
Our studies aim to understand the ‘non-visual’ effects of light on human physiology. About 10
years ago, a novel photoreceptor was discovered in the mammalian eye, including humans,
which is anatomically and functionally different from the rod and cone photoreceptors that we
use for vision. This new photoreceptor cells are located in a different part of the eye to rods and
cones, in the ganglion cell layer, and these cells are ‘hard-wired’ to the parts of the brain that
control our daily sleep and hormone rhythms, particularly the suprachiasmatic nuclei in the
hypothalamus, the site of the central circadian pacemaker or ‘body clock’. Light information from
the environment is detected by these cells to synchronize the internal circadian clock with the
external time of day and day-night changes to ensure that our physiology and behavior is
properly synchronized with the external environment. The importance of this regular, daily light-
dark cycle exposure is readily observed if this light-dark information is altered. For example,
shift-workers who stay awake at night and try and sleep in the day, or those flying across
multiple time zones, experience sleep, alertness, performance and metabolic disorders because
their internal clock cannot readjust quickly enough to the change in light-dark cycle and
consequently becomes desynchronized from the environment.
In addition to resetting the biological clock, light also acutely suppresses the production of the
pineal hormone melatonin. Melatonin is the internal biochemical signal of darkness and night
duration and its production changes in response to season and light exposure. Under a natural
light environment, light would never be seen when melatonin is produced and would therefore
be unaffected. With the invention of artificial light, however, light exposure now often occurs
during the night, stopping the production of melatonin and increasing alertness. In animal
studies, melatonin can act as an oncostatic – can slow down the growth of cancerous tumors –
and suppression of melatonin speeds up some types of tumor growth. While such studies have
not been repeated in humans, there is good epidemiological evidence that female shift-workers,
who are often exposed to light at night when their melatonin production occurs, have higher
rates of breast cancer than non-shift working women. Notably, totally blind women, who have
less light exposure, have reduced rates of breast cancer. While we have yet to understand fully
the environmental and health impact of being exposed to light at night, these preliminary data
suggest a detrimental effect of prolonged exposure to light at night.
While early research into the effects of light on sleep and hormones suggested that bright light
exposure was necessary to stimulate a response, over the past 20 years ours’ and others’
research has shown that the sleep and circadian systems are exquisitively sensitive to light, and
that very dim light is capable of eliciting measurable effects on human physiology. There are
many papers detailing the effects of light levels equivalent to that experienced indoors in
artificial room light, down to light as dim as 1.5 lux. Below I will review briefly the results from
several papers from our own laboratory (copies of the papers are enclosed). There are other
papers which I would be happy to provide if necessary.
The first studies describe the effects of different intensities of light on the circadian pacemaker,
melatonin levels, alertness and brain activity (see Zeitzer et al., Journal of Physiology 2000 and
Cajochen et al. Behavioral Brain Research 2000, enclosed). Subjects were exposed to one
intensity of white light ranging from 3 lux to 9100 lux for 6.5 hours during the night. During the
light exposure, blood samples were drawn to measure levels of the pineal hormone melatonin,
they were asked to rate their alertness levels, and electrodes were placed in their face and head
to measure the rate of slow eye movements and brain activity. The circadian rhythms of
melatonin were measured the day before and the day after the light exposure to assess the
effects on the biological clock.
2
Figures 1 and 2 show the dose-
response effect of light on the
physiological
and
behavioral
responses. Figure 1 shows the
effect of light on circadian rhythm
resetting
(A,
left
panel)
and
suppression of melatonin production
(B, right panel). The first thing to
note is that the dose-response
function is such that about 100 lux
of
light
causes
~50%
of
the
maximum response to very bright
10,000 lux light. Secondly, light from
20-100 lux is still capable of causing
a 0.5 -1 h shift in the timing of the
circadian pacemaker (A) and suppressing melatonin by up to 20% (B).
Figure 1
Figure 2 shows the results from the same study but for the dose-dependent alerting effects
of light. The left panel shows subjective ratings of alertness and the middle panel shows the rate
of slow eye movements, considered a reliable objective marker of fatigue. The right panel
shows the power density in the electroencephalogram (EEG) recordings in the theta-alpha
range (5-9 Hz); high brain activity at these frequencies is indicative of sleepiness. As Figure 2,
shows, all three measures of alertness showed a dose-dependent change with light intensity
such that higher intensities caused a more alerting effect. Even a low intensities (100 lux and
lower), however, light was still able to induce a measurable change in fatigue.
3
Figure 2
The final laboratory study was conducted to test the power of dim candle-light (~1.5 lux in the
vertical angle of gaze) to keep the circadian system synchronized to 24 hours (Wright et al.,
Proceedings of the National Academy of Sciences USA, 2001; attached). Subjects lived in the
laboratory for up to 55 days and were scheduled to live on one of three different ‘day’-lengths;
23.5 h, 24.0 h and 24.6 h under dim light while awake and darkness when asleep. Although the
dim light was unable to reset the circadian pacemaker enough to remain synchronized to the
23.5 h and 24.6 h days, candlelight was sufficient to keep the subjects entrained to 24 hours.
Notably, most totally blind people are unable to remain synchronized to 24 hours, again
highlighting the importance of even dim light on affecting human physiology and behavior.
These and other studies have shown that dim light is capable of stimulating effects on human
sleep and hormonal levels. While brighter light elicits larger effects, we cannot consider dim light
an inert stimulus and must keep it in mind when reviewing the appropriateness of light
environments. Studies are underway to measure the actual light levels that people are exposed
to while indoors and I anticipate that these levels will be significant in urban environments, and
even higher when individuals live closer to intrusive street lighting. There is absolutely no need
for any horizontal or vertical light to be emitted from street lamps; focusing light solely downward
will provide better, more focused lighting for traffic and pedestrians and allow sufficient lighting
to be produced with lower energy usage and at a reduced cost. Fixtures which permit horizontal
and vertical light are not only inefficient and unnecessary but also emit light inappropriately into
living spaces, particularly bedrooms. This light intrusion, even if dim, is likely to have
measurable effects on sleep disruption and melatonin suppression, particularly in those whose
bedrooms might be in close proximity to streetlights. Even if these effects are relatively small
from night-to-night, continuous chronic sleep and hormonal disruption may possibly have
longer-term health risks. For example, recent epidemiological studies have shown increased
rates of obesity and cancer are associated with decreased nightly reported sleep duration.
Intrusive street lighting, as well as wasting money and energy, is likely to have an adverse effect
on human health, effects which are entirely avoidable with better planning of urban lighting
fixtures. Short- and long-term measures to reduce light pollution will reduce energy demands,
reduce reliance on carbon-based fuels and improve the health of the urban environment.
With these consequences in mind, I applaud your efforts to have intrusive street lighting
abolished and I wholeheartedly support your campaign. Please let me know if I can be of further
assistance.
Yours sincerely,
Steven W. Lockley, Ph.D.
Assistant Professor of Medicine, Division of Sleep Medicine, Harvard Medical School
Associate Neuroscientist, Division of Sleep Medicine, Brigham and Women’s Hospital
Honorary Associate Professor in Sleep Medicine, Warwick Medical School
Encl.
Zeitzer JM, Dijk DJ, Kronauer R, Brown E, Czeisler C. Sensitivity of the human circadian
pacemaker to nocturnal light: melatonin phase resetting and suppression. Journal of Physiology
2000;526 Pt 3:695-702.
Cajochen C, Zeitzer JM, Czeisler CA, Dijk DJ. Dose-response relationship for light intensity and
ocular and electroencephalographic correlates of human alertness. Behavioral Brain Research
2000; 115(1):75-83.
Wright KP Jr, Hughes RJ, Kronauer RE, Dijk DJ, Czeisler CA. Intrinsic near-24-h pacemaker
period determines limits of circadian entrainment to a weak synchronizer in humans.
Proceedings of the National Academy of Sciences USA, 2001; 98(24):14027-32.
4
44
MAG DSSG Participants and Interested Parties - Contact List
Name
Organization
Phone
Email
Michelle Ahlmer
Arizona Retailers Association
(480) 833-0009
michelle@azretailers.com
Carmella Aja
Stevens and Stevens, WSPA
(602) 741-4129
susie@stevensandstevenslaw.com
Elizabeth M Alvarez del
Castillo
National Optical Astronomy Observatory
(520) 318-8414
ealvarez@noao.edu
Chris Anaradian
City of Tempe
(480) 858-2204
chris_anaradian@tempe.gov
Howard Anderson
(480) 897-7425
handy13@mindspring.com
Doug Atkins
Tel Tech Networks
(602) 723-7062
doug.atkins@teltechnetworks.com
Anubhav Bagley
MAG
(602) 452-5056
abagley@azmag.gov
Sandra Bahr
Sierra Club
(602) 253-8633
sandy.bahr@sierraclub.org
Fred Baker
City of Apache Junction
(480) 474-5127
fbaker@ajcity.net
Heidi Bickart
MAG
(602) 254-6300
hbickart@azmag.gov
Paul Bleier
Arizona Sign Association
Ed Boik
City of Peoria
(623) 773-7565
ed.boik@peoriaaz.gov
Tab Bommarito
Arizona Game and Fish Division
(928) 341-4069
tbommarito@azgfd.gov
Amy Bratt
Greater Phoenix Chamber of Commerce
(602) 495-6464
abratt@phoenixchamber.com
Stacey Bridge-Denzak
City of Avondale
(623) 333-4015
sbridgedenzak@avondale.org
Daniel Brocious
Smithsonian Institution Whipple Observatory
(520) 670-5706
dbrocious@cfa.harvard.edu
Patrick Burkhart
Alliance for the Advancement of Science Through
Astronomy
(602) 619-6441
pjburkhart@cox.net
Michael Buschbacker II
CBS Outdoor
mbusch@myurbanedge.com
Jennifer Cannon
ADOT
(602) 712-4142
jcannon@azdot.gov
James Carpentier AICP
Carpentier Consulting LLC
(480)773-3756
jbcconsultant@gmail.com
John R 'JC' Clements
CBS Outdoor
(602) 246-9569
jc@cbsoutdoor.com
Lisa Collins
City of Tempe
(480) 350-8989
Lisa_collins@tempe.gov
Angela Cotera
City of Avondale Planning Commission
(602) 315-1899
ascotera@gmail.com
Dale Crandell
City of Tolleson
(623) 936-7111
dcrandell@tollesonaz.org
Katrin de Marneffe
Clear Channel Outdoor
(602) 957-8116
katrindemarneffe@clearchannel.com
Steve Dodder
Stone Haven Observatory
sdodder@hotmail.com
Cliff Ehlers
(602) 672-7128
cmehlers@cox.net
Ken Galica
City of Avondale Development Services Dept
(623) 333-4019
kgalica@avondale.org
Patty Gallagher
City of Mesa
(480) 644-2033
patty.gallagher@mesaaz.gov
Jami Garrison
MAG
(602) 452-5006
jgarrison@azmag.gov
Stan Gorodenski
Blue Hills Observatory
(602) 978-9690
Eric Gorsegner
Sonoran Institute
(602) 393-4310
egorsegner@sonoran.org
Kent Grantham
SmithCraft
(602) 268-1349
kgrantham@smithcraftsigns.com
Richard Green
Large Binocular Telescope Observatory
(520) 626-7088
rgreen@as.arizona.edu
Mark Greenawalt
Illuminating Engineering Society
(602) 265-2200
president@iesarizona.org
Steve Gross
MAG
(602) 452-5065
sgross@azmag.gov
Robert Gubser AICP
City of Peoria Community Development Dept.
(623) 773-7405
rob.gubser@peoriaaz.gov
Don Hadder
City of Scottsdale
(480) 312-2352
dhadder@scottsdaleaz.gov
Don Happ LC, CEM
DH Lighting Solutions
(602) 867-4263
dhls@cox.net
Trish Hart
Law Offices of John K. Mangum, PC
(602) 252-5222
tkhart@mangumlaw.com
Dan Heim
Desert Foothills Astronomy Club
(623) 465-7307
dan@heimhenge.com
Jake Hinman
Arizona Multihousing Association
(602) 712-1121
jake@capitolconsultingaz.com
Jeff Hopkins
Hopkins Phoenix Observatory
phxjeff@hposoft.com
Richard R. Hubbard
Valley Partnership
(602) 228-1590
rhubbard@valleypartnership.org
Art Hushen
National Institute for Crime Prevention
(864) 608-4893
ahushen@aol.com
Laura Hyneman
City of Mesa
Laura.Hyneman@mesaaz.gov
45
Howard Israel
International Dark Sky Association
(480) 893-7523
howmad1@cox.net
sectionleader@phoenixdarkskies.org
Buell Jannuzi
Kitt Peak National Observatory
(520) 318-8353
jannuzi@noao.edu
Rolf A Jansen
Arizona State University
(480) 727-7119
rolf.jansen@asu.edu
Carol R Johnson AICP
City of Phoenix Planning Department
(602) 261-8289
carol.johnson@phoenix.gov
John Jolly
GLHN Architects and Engineers
(520) 881-4546
jjolly@glhn.com
Sarath Joshua
MAG
(602) 452-5031
sjoshua@azmag.gov
Vineetha Kartha
City of Surprise
(623) 222-3155
vkartha@surpriseaz.gov
Gordon Keig
Kornwasser Shopping Center Properties LLC
(602) 889-2072
gkeig@kornwasserproperties.com
Patricia King
Arizona Sign Association
(602) 375-3909
info@arizonasign.org
Keith Krueger
International Dark Sky Association
pinalida@q.com
Justin Lalley
CBS Outdoor
(602) 477-3063
Justin.lalley@cbsoutdoor.com
Stacey Langford
Arizona Bankers Association
(602) 258-1200
slangford@azbankers.org
Walt Laramie
Salt River Project
(602) 236-8052
walt.laramie@srpnet.com
Ian Lewin
Lighting Sciences
(480) 948-4088
lsi@lightingsciences.com
Gene Lucas
geneluca@ix.netcom.com
Chris Luginbuhl
United States Naval Observatory Flagstaff Station
(928) 779-5132
cbl@nofs.navy.mil
Alisa Lyons
Valley Partnership
(602) 266-7844
alisa@sloanlyons.com
Andrea Martincic
Arizona Petroleum Marketing Association
(480) 460-1561
apma@cox.net
Mike Mayhew
Southern RM/CA Commercial Regional Manager
(602) 909-7379
michael.mayhew@Daktronics.com
Samuel McAllen
City of Glendale
(623) 930-3610
smcallen@glendaleaz.com
Michael McCauley
Town of Queen Creek
(480) 358-3085
michael.mccauley@queencreek.org
Jamsheed Mehta
City of Glendale
(623) 930-2940
jmehta@glendaleaz.com
John Mickel
(623) 412-4265
jjmickel@cox.net
Kyle Mieras AICP
Town of Gilbert
(480) 503-6705
kyle.mieras@gilbertaz.gov
Bob Millis
Lowell Observatory
(928) 774-3358
rlm@lowell.edu
Kevin Morrow AIA
American Institute of Architects
kmorrow@gdasw.com
Kenneth Peskin
International Sign Association
(703) 836-4012
kenneth.peskin@signs.org
Jennifer Polakis
(480) 967-1658
m24@cox.net
Nathan Pryor
MAG
(602) 452-5007
npryor@azmag.gov
James Rhoads
Arizona State University
(480) 727-7133
james.rhoads@asu.edu
Thomas Ritz AICP
City of Glendale
(623) 930-2588
tritz@glendaleaz.com
Larry Robinson Jr
Bob Rodgers
Town of Fountain Hills
rrodgers@fh.az.gov
Lise Rodgers
liserodgers@q.com
Paul Scowen
Arizona State University
(480) 965-0938
paul.scowen@asu.edu
William Shaheen
(623) 255-6247
wjshaheen@aol.com
Gordon Sheffield AICP
City of Mesa Planning Division
(480) 644-2199
gordon.sheffield@mesaaz.gov
Michael Sills-Trausch
City of Glendale
(623) 930-2019
msills@glendaleaz.com
Michael Slupinski
(480) 894-4197
michael.slupinski@safeway.org
Troy G Smith
Arizona Game and Fish Division
(928) 341-4068
trsmith@azgfd.gov
Bill Trainor
Tel Tech Networks
(602) 463-3609
Richard Travis
Nexxus
(602) 258-5858
rtravis@nexxusconsulting.com
James S Truman
Truman Ranch
(602) 320-3355
jstruman@msn.com
Natalene Tso
LSW Engineers
(602) 249-1320
ntso@lswphx.com
Nathan Williams
Town of Gilbert Planning and Development Svcs
(480) 503-6805
nathan.williams@gilbertaz.gov
Scott Woods PE
Arizona Pinnacle Engineering
(623) 594-9049
swoods@az-pe.com
Amanda Wright
Mario E Diaz and Associates
(602) 224-0210
amanda@medandassociates.com
Patrick Young
Arizona State University
patrick.young.1@asu.edu
Patty Zaricor AICP
Maricopa County Planning & Development Dept
(602) 506-8358
pattyzaricor@mail.maricopa.gov
Scott Zipprich
Town of Buckeye Town Engineer's Office
(623) 547-4661
scott@scoutten.com
46
Internet Resources
Dark Sky Ordinances: How to Separate the Light from the Darkness
(530 Kb)
MAG Presentation of Economic Impact on behalf of Sign Industry
(81 Kb)
The Economic Value of On-Premise Signage
(5 Mb)
Process and Methodology for Economic Value of On-Premise Signs Resarch
(367
Kb)
Arizona’s Aerospace and Defense Commission Annual Report - See Pages 3, 10, 12,
and 14
(722 Kb)
Joint IDA-IES Model Lighting Ordinance (MLO)
(2 Mb)
Web Links to Member Agency Lighting Ordinances
(96 Kb)
Safety Impacts of the Emerging Digital Display Technology
(1 Mb)
Impact of the Kitt Peak Ordinance on Streetlight Rates 1984
(1 Mb)
Outdoor Light Pollution Standards Presentation
(4 Mb)
IDA Outdoor Lighting Code Handbook
(978 Kb)
Outdoor Lighting Codes
(3 Mb)
MAG Draft Pattern Outdoor Lighting Code, Version Six
(521 Kb)
MAG Dark Sky Initiative Status Update
(51 Kb)
MAG Dark Skies Stakeholders Group
Efforts toward an updated Pattern Outdoor Lighting Code
Rolf Jansen (Arizona State University, SESE)
East Valley Astronomy Club — Apr 15, 2011
Page 0
with contributions from:
Dan Brocious, F.L. Whipple Observatory / International Dark Sky Associa-
tion
Christian Luginbuhl, US Naval Observatory, Flagstaff Station
Elizabeth Alvarez, Kitt Peak National Observatory
Richard Green, Large Binocular Telescope Observatory
Nathan Pryor & Heidi Bickart, Maricopa Association of Governments
Tab Bommarito, Arizona Game and Fish Department, Yuma
Jodi Shi, Stanford University, Dept. of Civil and Environmental Engineering
Page 1
Outline
G The end of the dark night sky?
G The importance of dark skies for Arizona astronomy
G Dark skies... not just for astronomy!
G The importance of astronomy for Arizona ($$$)
G The Maricopa County Association of Governments (MAG)
G Toward an updated Pattern Outdoor Lighting Code
G How you can help in your local municipal government
G On misinformation & derailing of the process
Page 2
The End of the Dark Night Sky?
Page 3
The End of the Dark Night Sky?
C. Mayhew & R. Simmon (NASA/GSFC), NOAA/NGDC, DMSP Digital Archive
Page 4
The End of the Dark Night Sky?
Page 5
The End of the Dark Night Sky?
Lights as seen from above
(e.g., from the ISS) looking
down.
The landscape out-
side of the cities looks dark.
But this is misleading...
When looking up, light pollu-
tion spreads to far from the
cities.
You can be 50 or
100 miles from the Phoenix
metropolitan area and still
see the effects of city lights...
Page 6
The End of the Dark Night Sky?
When looking up — Light pollution in Arizona
Cinzano, Falchi, & Elvidge 2001
Page 7
The End of the Dark Night Sky?
Phoenix at night as seen from the International Space Station
NASA, ISS CEO project; ISS’s altitude is ∼220 miles.
Page 8
The End of the Dark Night Sky?
Population growth in SW means increased scattered light (airglow)
C. Luginbuhl
Page 9
The End of the Dark Night Sky?
Page 10
The End of the Dark Night Sky?
One century of population growth near Mt. Wilson, CA
Views of Los Angeles and Pasadena from Mt. Wilson, CA, in 1908 (total population 350,000) and in
2008 (nearly 5 million).
Page 11
The End of the Dark Night Sky?
c⃝2003 Todd Carlson
In the US, 2 out of 3 people can only see the Milky Way with their naked eyes in
the event of a massive power outage!
Page 12
The End of the Dark Night Sky?
The dangers of an artificially bright night are becoming apparent
Page 13
The Importance of dark skies for
Arizona astronomy
Page 14
Importance of dark skies for AZ astronomy
G = professional observatories with large-aperture telescopes.
Page 15
Importance of dark skies for AZ astronomy
Sites particularly impacted by Maricopa County light pollution:
G Lowell Observatory
G US Naval Observatory
G Discovery Channel Telescope
G Mt. Graham Observatory (LBT+VATT)
G ... but Kitt Peak National Observatory is affected too
Page 16
Importance of dark skies for AZ astronomy
Site protection is a regional issue
G Phoenix/Casa Grande sky glow as seen from Kitt Peak National Observatory
on March 28, 2008. (KPNO photo by J. Glaspey)
Page 17
Importance of dark skies for AZ astronomy
Site protection is a regional issue
G ISS pass over Kitt Peak at ∼8 p.m. on April 11, 2007. The orange glow is
not twilight but from Phoenix and Casa Grande city lights! (photo by J. Scotti, LPL)
Page 18
Importance of dark skies for AZ astronomy
Site protection is a regional issue
® Someone paid for all that wasted light — I’ll bet it’s us!
Page 19
Importance of dark skies for AZ astronomy
Site protection is a regional issue
G At Mt. Graham, light domes from metro Tucson (70 miles, pop-
ulation 1 million) and metro Phoenix (130 miles, 4 million) dom-
inate the western horizon (photo by Marco Pedani, LBTO)
Page 20
Importance of dark skies for AZ astronomy
Site protection is a regional issue
G On a clear moonless night, the sky in the west at 45◦above the
horizon is 10% brighter than in the opposite (dark) direction
G When thin clouds are present, the increase due to scattered
light from the cities toward the mountain is 50% over dark sky!
G Physical model of light scattering from metro Tucson and metro
Phoenix predicts increases of 9.7% and 8.3%, respectively.
® Equal contributions, consistent with measurements (10% each).
Page 21
Importance of dark skies for AZ astronomy
Large Binocular Telescope, Mt. Graham (AZ), with its twin 8.4 m (27.6 ft) primary mirrors (photo
by M.-A. Besel & W. Rujopakarn)
Page 22
Importance of dark skies for AZ astronomy
(photo by A. Ceranski)
Page 23
Importance of dark skies for AZ astronomy
Page 24
Importance of dark skies for AZ astronomy
Economic impact to LBT of light pollution
G For a 10% increase over natural night sky brightness, 20%
more exposure time is needed to record the same level of in-
formation about any celestial object fainter than the natural sky
glow.
G Light pollution from Phoenix and Tucson metro already costs
the LBT international partnership the equivalent of $ 18,000
per night.
G Equivalently, light pollution from Phoenix (and Tucson) metro
degrades the capital value of the facility by ∼40 million.
Page 25
The importance of astronomy for Arizona
($$$)
Page 26
Importance of astronomy for Arizona
G APSS research represents a
substantial capital investment
(in excess of $ 1 billion) in, and
economic return (more than a
quarter of a billion dollars an-
nually) for Arizona.
G Stargazing nets $ 250 million a
year for Arizona economy
The Arizona Republic,
January 17, 2008.
UofA, Eller College of Management, 2007
Page 27
Importance of astronomy for Arizona
G Astronomy is worth billions to Arizona
® Data also suggest untapped potential of these research fields
to expand the State’s economic base.
® Levels of active research funding well exceed other fields
in the State, such as bioscience funding from the National
Institutes of Health.
Page 28
Importance of astronomy for Arizona
VERITAS – High Energy Gamma Ray Observatory
F.L. Whipple Observatory, Mt. Hopkins, AZ
— $ 20 million new observatory, April 2007
— International Partnership (not just AZ tax dollars!)
— Funded primarily by the Department of Energy and the Na-
tional Science Foundation
Page 29
Importance of astronomy for Arizona
Page 30
Importance of astronomy for Arizona
Page 31
Importance of astronomy for Arizona
Page 32
Importance of astronomy for Arizona
Page 33
Importance of astronomy for Arizona
... and more $$$ flow to Arizona from outside the state!
Page 34
Importance of astronomy for Arizona
Page 35
Importance of astronomy for Arizona
Page 36
Dark skies... not just for astronomy!
Page 37
Dark skies... not just for astronomy!
Impacts of Artificial Night Lighting on Wildlife
G Disorientation or unnatural stimulus
G Disrupt reproduction for many species
G Increase and/or decrease competition between species
G Benefit some predators to the detriment of their prey species
(and/or other predators)
Arizona Game and Fish Department
Page 38
Dark skies... not just for astronomy!
Mammals
G Reduction in activity, movement, and food consumption of rodents (Vasquez
1994; Kramer & Birney 2001; Brillhart & Kaufman 1991; Clarke 1983; Falkenberg & Clarke 1998)
— Responded to 0.1 lux (half moon) and 0.3 lux (full moon)
— Roads use a minimum level of 3 lux
G Seed harvest in desert rodents declined 21% (Kotler 1984)
— Illumination from 1 camping lantern
Ords kangaroo rat
Western harvest mouse
Page 39
Dark skies... not just for astronomy!
Mammals
G Mountain lions avoided urban glow (Beier 1995)
— Resulted in movement through unfavorable topography and habitat
G Bats avoided illuminated areas (Stone et al. 2009)
— Increased predation
— Disrupts normal 24 hr pattern of light and dark
Mountain lion
California lead-nosed bat(s)
Page 40
Dark skies... not just for astronomy!
Humans are mammals too!
G Blue light can disrupt biological processes that rely upon natural cycles of
daylight and darkness, such as the circadian rhythm
Page 41
Dark skies... not just for astronomy!
Reptiles and Amphibians
G Predation on snakes increased with elevated illumination levels (Bouskila 1995)
G Snake prey reduced foraging activity in response to increased illumination
(Bouskila 1995; Bowers 1988)
G Ability of navigation through corridors can be impaired (Beier 2006); implicated
in the decline of reptile populations (Perry & Fisher 2006)
G Disorientation of sea turtle hatchlings (instinctively attracted to the brightest
source of light) decreases survival rates (Witherington & Martin 1996)
Shovelnose snake
Sea turtle hatchlings
Page 42
Dark skies... not just for astronomy!
Reptiles and Amphibians
G Eastern newts’ orientation and homing behavior can be disrupted during
migration (Phillips & Borland 1992,1994)
Eastern newt
Page 43
Dark skies... not just for astronomy!
Birds
G Nocturnally migrating birds disoriented by red and white light (Poot et al. 2008)
— Mortalities from collisions with towers and buildings (Gehrinig et al. 2009)
G Robins initiated morning chorus on average 116 min. before civil twilight
(Miller 2006)
— i.e., at average light levels of 3.91 lux (0.3 lux = full moon)
Page 44
Dark skies... not just for astronomy!
Luxor, Las Vegas
Twin Tower Memorial, NY
Page 45
Dark skies... not just for astronomy!
Wildlife Economics
G Combined hunting, fishing, and wildlife viewing in Arizona, 2000–2003:
— $ 100 million in trip items (food, fuel, lodging)
— 1,936 positions (employement)
— $ 829 million in non-trip items (souvenirs, hunting supplies, entertain-
ment)
— 16,217 positions
Page 46
The Maricopa County Association of
Governments (MAG)
Page 47
Maricopa County Association of Governments
G In 2008, the director of KPNO gave a presentation on the issue of light pol-
lution to the Maricopa County Association of Governments. Recommenda-
tion:
— The Arizona Legislature, counties, municipalities, and Tribal Nations should
revisit the adequacy and enforcement of existing statutes and ordinances
in a new effort to reduce light pollution associated with rapid industrial
and population growth as well as old lighting installed before effective
codes were in place.
— Arizona Title 49, Chapter 7 calls for the elimination of mercury vapor
lighting fixtures by 2011. All counties in the State and many munici-
palities have used the 1973 State law to enact light control ordinances.
However, the sheer rate of population growth, particularly in Maricopa
County, and more recently in Pinal County, as well as lax enforcement of
many existing ordinances, threaten to undo that protection.
Page 48
Maricopa County Association of Governments
— New lighting technologies, not covered in existing ordinances
(LEDs).
G 2008 paper by C.B. Luginbuhl & G.W. Lockwood studied the
potential energy savings and carbon dioxide emission reduc-
tions if lighting standards similar to Flagstaff’s could be applied
to all commercial outdoor lighting within the state of Arizona.
® Statewide energy use would be reduced by >360,000 MWh
per year. This corresponds to a reduction by 190 kilotons of
CO2 emissions per year and an energy cost savings of $ 30
million per year.
G So what exactly is MAG?
Page 49
Maricopa County Association of Governments
Page 50
Maricopa County Association of Governments
Page 51
Maricopa County Association of Governments
Page 52
Maricopa County Association of Governments
Page 53
Maricopa County Association of Governments
Page 54
Maricopa County Association of Governments
Page 55
Maricopa County Association of Governments
Page 56
Maricopa County Association of Governments
Page 57
Maricopa County Association of Governments
Page 58
Maricopa County Association of Governments
Page 59
Maricopa County Association of Governments
Page 60
Maricopa County Association of Governments
G Current outdoor lighting control provisions (Section 1112 of the Maricopa
County Zoning Ordinance) were adopted in 1984. In the quarter-century
since, more effective outdoor lighting standards have been devised, and
new technology has emerged.
G January 14, 2009 – the MAG Management Committee approved convening
a Dark Sky Stakeholders Group.
G Its purpose is “to collect information on outdoor light pollution, review best
practices in lighting codes, and to develop a Pattern Outdoor Lighting Code”
(comprehensive guide describing issues relevant to de control of the obtru-
sive aspects of outdoor lighting, and list of effective regulatory approaches
to mitigate these aspects).
® http://www.azmag.gov/Projects/Project.asp?CMSID=1082
Page 61
Toward and updated Pattern Outdoor
Lighting Code
Page 62
Toward and updated Pattern Outdoor
Lighting Code
Purpose of a Lighting Code
G Promote good lighting practice; limit obtrusive lighting
G Promote good business
G Promote the community
G Help everyone see better
G Save energy, save money; discourage waste
G Preserve dark skies for all.
Page 63
Toward and updated Pattern Outdoor
Lighting Code
Basic considerations for lighting
G What is the task/purpose — is light needed and why?
G How much?
® Use rational lighting levels
® Only the amount needed for the task at hand
® Dependent on location: Environmental Zones
G Where? What exactly needs to be illuminated?
® Directional control and shielding
G When?
® Only use the light when it is needed
Page 64
Toward and updated Pattern Outdoor
Lighting Code
Keys to quality lighting
G See the effect, not the source!
G Shine the light down
G Avoid glare!
G Light only Where and When needed
G Do not over-light
G Use energy efficient (total system) light sources.
Page 65
Toward and updated Pattern Outdoor
Lighting Code
Biggest complaints resulting from bad lighting:
G Too much light −→neighbor’s light
G Glare −→wall packs, ‘security’
lights, floodlights
G Can’t see well anymore
G Light trespass
G Not comfortable; obtrusive light
Page 66
Toward and updated Pattern Outdoor
Lighting Code
Page 67
Toward and updated Pattern Outdoor
Lighting Code
Page 68
Toward and updated Pattern Outdoor
Lighting Code
Page 69
Toward and updated Pattern Outdoor
Lighting Code
Page 70
Toward and updated Pattern Outdoor
Lighting Code
Page 71
Toward and updated Pattern Outdoor
Lighting Code
Improvements/updates to MAG outdoor lighting codes:
® All lighting fixtures above a given brightness should be fully
shielded −→all light directed downward to where it is useful
® Implement standards to address the amount of outdoor lighting
used −→limit over-lighting and save energy
® Separate residential lighting standards to address the specific
issues encountered in residential zones −→limit light
tresspass, while relieving homeowners and builders from hav-
ing to implement the more complex standards for non-residential
development
Page 72
Toward and updated Pattern Outdoor
Lighting Code
Improvements/updates to MAG outdoor lighting codes:
® Re-work code definitions and standards using terminology and
methods more easily implemented by planning staff and light-
ing users
® Permit reasonable uses of outdoor lighting for nighttime safety,
utility, security, and enjoyment, while preserving the ambiance
of the night
® Minimize glare and obtrusive light by limiting outdoor lighting
that is misdirected, excessive, or unnecessary
Page 73
Toward and updated Pattern Outdoor
Lighting Code
Improvements/updates to MAG outdoor lighting codes (cont’d):
® Conserve energy and resources to the greatest extent possible
® Help protect the natural environment from the damaging ef-
fects of night lighting
Page 74
Toward and updated Pattern Outdoor
Lighting Code
Page 75
Toward and updated Pattern Outdoor
Lighting Code
Good and responsible lighting is
® Good for people
® Good for neighborhoods
® Good for business
® Good for the economy
® Good for wildlife
® And, yes, good for astronomy, too
Page 76
How you can help in your local municipal
government
Page 77
How you can help in your local municipal
government
G Pattern Outdoor Lighting Code, with its set of options for each
article, will be passed on to your local city or municipality gov-
ernment for consideration. This is a non-binding, strictly advi-
sory document.
G Your local government can accept the pattern lighting code, or
reject it, or can pick and choose from the articles and options
as applicable locally and as it sees fit.
G Expect misinformation, whether intentional or resulting from
lack of expertise, being put on the meeting record. But speak
up if you know the information to be factually incorrect.
Page 78
How you can help in your local municipal
government
® If and when public input is invited, your presence would be
valuable if you care for a dark night sky. Participation by lo-
cal residents tends to be valued more than outside propo-
nents/opponents.
® Highly paid lawyers and lobbyists to avoid, delay, or dismantle
any effective outdoor lighting code are certain to be present at
such meetings no matter what.
Page 79
On misinformation & derailing of the process
Page 80
On misinformation & derailing of the process
G Myth: more light is safer
® Glare from an unshielded light fixture can interfere with vision and hide a
potential backyard intruder in shadows.
Page 81
On misinformation & derailing of the process
G Myth: shielding will require more luminaries to be erected so energy con-
sumption will increase
® Effect of shielding parking lot lights in Branford, CT, before (left) and after
(right). Same number of luminaries, improved visibility.
Page 82
On misinformation & derailing of the process
G Misinformation: (clear sky clock) final hours of night are darkest, so no need
for evening curfew
® ’darkness’ reflects only contributions from Sun and Moon; Moon contribu-
tion changes during its ∼28 day lunation
Page 83
On misinformation & derailing of the process
Page 84
On misinformation & derailing of the process
G More myths/misrepresentations (Independence Institute, report IP-4-2006):
— Light is a good, not a form of pollution
® It can be good or bad, depending on how it is used; just like CO2 and
even mercury can be both a good and a bad thing, depending on its use
and quantity
— Urban lighting in the U.S. is not harming advanced astronomical research
(based on false premise that advanced research happens only from space)
® The verifiable facts show otherwise (e.g., LBT, LSST, etc.)
— Dark Sky ordinances benefit mainly solitary, casual, urban stargazers
® Impact on human health and impact on wildlife are increasingly well doc-
umented; astronomy & aerospace, and wildlife bring billions of dollars to
Arizona.
Page 85
On misinformation & derailing of the process
® Gilbert Rotary Centennial Observatory already drew 41,647 visitors from
its opening in 2006 through March 2011 (not counting school groups). East
and West Valley Astronomy Clubs, Saguaro Astronomy Club are active am-
ateur astronomy clubs with strong, well established, and well attended com-
munity outreach and public observing programs.
Page 86
On misinformation & derailing of the process
G More myths/misrepresentations (Independence Institute, report IP-4-2006):
— Research shows that improved street lighting reduces crime by 20%
® Improved lighting and more lighting are quite a different thing. Dark Sky
ordinances promote good lighting
Page 87
On misinformation & derailing of the process
G More myths/misrepresentations:
— Research shows that well-lit (traffic) signs reduce accidents
(where sign industry lobbyist invariably omit ”traffic” and use this to advo-
cate for bright advertising signs!)
® The lighting code has no issue with well-lit (not necessarilly brightly lit)
traffic signs, nor other lighting that demonstrably improves safety.
— Lighting codes hurt small businesses.
® The overwhelming majority of small business lighting and advertising
signs comply with the proposed pattern outdoor lighting code.
Big corporate LED billboards and some large shopping malls do not.
® A lighting code levels the playing field and prevents big business from
outcompeting small business by outshining them
Page 88
MAG Dark Skies Stakeholders Group
Thank you
http://www.azmag.gov/Projects/Project.asp?CMSID=1082
Page 89
From:
Robert Branscomb
To:
ray.baker@maricopa.gov
Cc:
Rachel Applegate (PND)
Subject:
***Planning and Zoning Commission June 17, 2021-Please register my opposition to the Text Amendment (TA) -
TA2018001 – Off-site Advertising (Billboards).***
Date:
Wednesday, June 16, 2021 4:29:26 PM
Attachments:
FBA40826504844C1861DB4629D75C4EA.png
To Planning and Zoning Commissioners:
This TA seeks to permit billboards across county lands, allowing these signs to be as high as 80 feet
tall, as close as 500 feet apart and as near as 150 feet from residential property.
Most significantly, this proposed TA would allow digital billboards within the county. Currently the
county does not allow this use. This would be a major increase in intensity and use with messaging
changing as often as 8 seconds on digital faces double the size of current billboards.
If approved, the process for challenging a billboard would be just one public hearing. Residents and
other stakeholders deserve a fair and open process to voice our concerns to the county. I do not
want intrusive light to trespass into residential areas. I do not want to see more billboards on our
highways distracting drivers and compromising driver safety.
I do not want advertising technology to rob our public views and beautiful scenery during the day
and our dark skies at night.
Please reject the proposed Text Amendment –TA2018001.
Thank you.
Robert
Robert Branscomb
Office: 602-995-8888
Cell: 480-648-9882
Fax: 602-995-0352
Email: Robert@rebagency.com
Web: www.rebagency.com
From:
G.G. George
To:
Ray Banker (PND); Rachel Applegate (PND)
Subject:
Opposition to digital signs on County Roads
Date:
Wednesday, June 16, 2021 4:53:28 PM
Dear Mr. Banker and Ms. Applegate,
Please register the opposition of the Phoenix Historic Neighborhoods Coalition (PHNC) to Text
Amendment TA-2018001, Off-site advertising-Billboards.
Our State is renown for its scenic vistas. The adoption of this TA would significantly mar a
great many of those vistas. There are many reasons to oppose this TA, such as light trespass
that could compromise driver safety, the dark skies mandate for which cities strive, wildlife,
but most of all the preservation of Arizona's scenic vistas.
The Phoenix Historic Neighborhoods Coalition knows this amendment will benefit one
company, Becker Boards, at the expense of all Maricopa County residents.
Please oppose this Text Amendment.
Thank you for your time and attention to this letter, as I do not wish to speak.
G.G. George, President
Phoenix Historic Neighborhoods Coalition
1102 W. Palm Lane
Phoenix, AZ 85007
602-252-3151
Governor's Heritage Preservation Honor Award for Lifetime Achievement - 2019
3361 East 23rd Street Tucson, Arizona 85713 (520) 326-4522
Scenic Arizona is an affiliate of Scenic America
June 16, 2021
Maricopa County Planning & Zoning Commission
c/o Maricopa County Planning Staff
301 West Jefferson Street
Phoenix, Arizona 85003 (via electronic mail to: ray.banker@maricopa.gov; rachel.applegate@maricopa.gov )
RE: Maricopa Planning & Zoning Commission Meeting, June 17, 2021. Agenda Item #15,
TA2018001, Off-Site Advertising Signs (Billboards)
Honorable Chair Arnett & Members of the Commission:
Scenic Arizona hereby registers its opposition to the draft ordinance being put forward in the above-
referenced case. This ordinance was not promulgated in response to any groundswell of public wishes,
but rather only to benefit those who would profit from the further degradation of the visual
environment. We would urge that you do not set this item for public hearing, and either take no action
or continue the item so that there is an opportunity to rebut the one-sided documentation provided by
the applicant, particularly such documentation that largely relies on self-interested sources.
We note that the allowance of electronic displays on billboards for the first time runs contrary to past
involvement of the major astronomical observatories with Maricopa County and there is no indication
that they have been contacted or engaged in the current process. We further note that there is no
mention in the draft ordinance of potential conflict with state law (ARS Sec.28-7902), prohibiting
electronic billboards within certain radii of observatories that extend well into Maricopa County.
These radii were established as part of a legislative compromise in 2012, subsequent to successful
litigation in which Scenic Arizona was a plaintiff and in which the court upheld the Arizona Highway
Beautification Act prohibition of electronic billboards on state and federal jurisdiction highways.
More particularly, we oppose the following as being harmful to the visual environment: 1) any
allowance of electronic displays on billboards; 2) increasing the area allowance of freeway billboards
from 300 to 672 square feet; 3) increasing the heigh allowance of freeway billboards from 30 feet to
48 feet (or more in some cases); and 4) turning nonconforming use law on its head by allowing
increases in intensity (adding electronic displays, decreasing separation requirements, or otherwise).
Again, we would urge that this item not be set for public hearing at this time.
Sincerely,
Mark Mayer
Government Affairs & Outreach Coordinator
From:
Bill Leal (OBM)
To:
Rachel Applegate (PND); Ray Banker (PND); Darren V. Gérard (PND)
Cc:
Kathy Semder (COA)
Subject:
FW: Online Form Submittal: Citizen Comments
Date:
Wednesday, June 16, 2021 4:25:55 PM
Fyi.
From: noreply@civicplus.com <noreply@civicplus.com>
Sent: Wednesday, June 16, 2021 4:22 PM
To: PND Regulatory <PNDRegulatory@maricopa.gov>; Kathy Semder (COA)
<Kathy.Semder@Maricopa.Gov>; Andy Linton (OBM) <Andy.Linton@Maricopa.Gov>; Bill Leal (OBM)
<Bill.Leal@Maricopa.Gov>; Kathryn Garcia (OBM) <Kathryn.Garcia@Maricopa.Gov>; Blanca
Caballero (ENV) <Blanca.Caballero@Maricopa.gov>
Subject: Online Form Submittal: Citizen Comments
Citizen Comments
Each Regulatory Department is committed to providing opportunities for
stakeholder input regarding the adoption and amendment of all regulatory
requirements. Your input will be collected and forwarded to the appropriate
department. You will receive a written response from the applicable department
within two business days. We appreciate your comments and your time.
Case Number/Rule
TA2018001 - Off-Site Advertising Signs (Billboards)
Department
Field not completed.
I would like to
Express opposition
First Name
Nicole
Last Name
Rodriguez
Organization
Citizen
City
Phoenix
Zip
85014
Email
nrrphx@gmail.com
Phone Number
6029204945
Phone Type
Mobile
Would you like someone to
contact you?
No
Comments
Field not completed.
If applicable, attach
supporting documentation
associated with your
comment. The only file
types supported are MS
Office and Adobe Acrobat.
Field not completed.
Email not displaying correctly? View it in your browser.
From:
B F
To:
Rachel Applegate (PND)
Cc:
Dan Penton
Subject:
Opposition to the Text Amendment (TA) - TA2018001 – Off-site Advertising (Billboards)
Date:
Wednesday, June 16, 2021 10:00:56 PM
Attachments:
BillboardIssue_2021.pdf
Good evening Ms. Applegate:
Please see the attached letter in opposition of billboards in our community. We cannot emphasize
enough that the approval and implementation of these would sacrifice what the Laveen community
represents, aside from its rural heritage, and the beauty of the landscape which Arizona never fails
to provide us who choose to live here.
Kindly yours,
Ben
Benjamin W. Fisher
4745 W. Piedmont Drive
Laveen, AZ 85339-9644
602.617.6143 – Cell
benjamin_fisher@hotmail.com
16 June 2021
To Planning and Zoning Commissioners:
Please register my opposition to the Text Amendment (TA) - TA2018001 – Off-site Advertising
(Billboards).
This TA seeks to permit billboards across county lands, allowing these signs to be as high as 80 feet tall,
as close as 500 feet apart and as near as 150 feet from residential property; and no setback requirement
from residential zoning districts, when along a freeway.
Most significantly, this proposed TA would allow digital billboards within the county. Currently the
county does not allow this use. This would be a major increase in intensity and use with messaging
changing as often as 8 seconds on digital faces double the size of current billboards.
If approved, the process for challenging a billboard would be just one public hearing. Residents and other
stakeholders deserve a fair and open process to voice our concerns to the county.
I do not want intrusive light to trespass into residential areas. I do not want to see more billboards on our
highways distracting drivers and compromising driver safety. I do not want advertising technology to rob
our public views and beautiful scenery during the day and our dark skies at night.
Please reject the proposed Text Amendment – TA2018001.
Overall, I do not want to see billboards obstructing the view of the Estrella Mountain Range along South
Mountain Loop 202 (AKA, Ed Pastor Freeway).
Thank you kindly in advance for your attention.
Benjamin W. Fisher
4745 W. Piedmont Drive
Laveen, AZ 85339-9644
602.617.6143
From:
Sandy Grunow
To:
Ray Banker (PND); Rachel Applegate (PND)
Cc:
Phoenix Mid-Century Modern Neighborhood Assoc.
Subject:
Maricopa County Text Amendment – TA2018001
Date:
Wednesday, June 16, 2021 9:26:18 PM
Ms. Applegate and Mr. Banker:
I represent the Phoenix Mid-Century Modern Neighborhood Association. Although we are located in
Phoenix proper, the suggestion of digital signs on county roads is met with great shock.
Our surrounding county with beautiful desert, mountain and wildlife is treasured. Drives to the outskirts of
Phoenix are a treat, removing us from the city noise and pollution. It is appalling that Maricopa County
would even consider digital signs on the Maricopa County roads. Our wildlife is already in danger, then
you add light pollution. This move will endanger the lives of nocturnal animals and upset the eco system.
Is this proposal deemed acceptable by Arizona Game and Fish, Southwestern Wildlife and the contiguous
counties? I don’t believe so.
How dare this be considered in effort to make money. You are asked to vote down this harmful Text
Amendment.
Sandy Grunow
Co-Chair
Phoenix Mid-Century Modern Neighborhood Assoc.
From:
John Hathaway
To:
Ray Banker (PND); Rachel Applegate (PND)
Subject:
Opposition to TA2018001 – Off-site Advertising (Billboards).
Date:
Thursday, June 17, 2021 12:05:24 AM
Dear Mr. Banker and Ms. Applegate,
I am sending this letter to express my opposition to the Text Amendment (TA) - TA2018001 – Off-
site Advertising (Billboards).
This amendment dramatically relaxes the rules associated with the placement and size of
billboards on county lands. These signs could be as high as 80 feet tall, as close as 500 feet apart
and as near as 150 feet from residential property.
The biggest problem with this proposal is that it would allow digital billboards within the county.
Currently the county does not allow this use. This would be a major increase in intensity and use
with messaging changing as often as 8 seconds on digital faces double the size of current
billboards. Digital billboards are designed to be attention attracting which ends up making them
driving distracting which, in turn, creates a potential safety issue.
If approved, the process for challenging a billboard would be just one public hearing. Residents
and other stakeholders deserve a fair and open process to voice our concerns to the county.
Billboards are a business – a business that creates a product with both upsides and downsides.
This text amendment will have the net effect of ignoring all of the downsides for the sake of gaining
some minimal upsides. This is a bad gamble!
Please reject the proposed Text Amendment – TA2018001.
Thank you.
John E. Hathaway
125 E Maryland Ave
Phoenix, AZ 85012
(602)769-2598
jehath@aol.com
From:
Stacie Jackson
To:
Rachel Applegate (PND)
Subject:
Case number – TA2018001/Off-site advertising signs (billboards)
Date:
Thursday, June 17, 2021 6:59:51 AM
Case number – TA2018001/Off-site advertising signs (billboards)
Stacie Ricks
Phoenix resident
Staciejackson3@gmail.com
480-432-3433
I am strongly opposed to this proposal of digital billboards.
From:
Mary Mulligan
To:
Ray Banker (PND); Rachel Applegate (PND)
Subject:
TA2018001 (opposition)
Date:
Thursday, June 17, 2021 12:13:11 AM
To Whom It May Concern:
Please note my opposition to TA2018001 (Billboards/Off-site Advertising).
I can hardly believe that this text amendment is even under consideration, given the
intrusive height (as tall as 80’), the ridiculously close spacing between signs (as close
as 500’), and proximity to residences (as near as 150’) across county lands.
Please do not prostitute our roadways for the financial gain of a relatively few
billboard companies and landowners.
Please do not exploit digital technology at the expense of driver safety on our roads.
Drivers have enough distractions as it is these days, taking into account hazards on
the road, the increase in traffic that goes along with Maricopa County being the
fastest growing county in the nation (per the US Census Bureau), and, oh yes,
cellphones.
Please do not rob future generations of the opportunity to step outside at night to
gaze at the stars in beautiful dark skies.
Please do not make a decision that will subject residents to bright lights and
messages that change as often as every eight seconds that can be seen for miles.
Dark starlit night skies are one of nature’s gifts that are free to be enjoyed by all, rich
or poor, across the globe.
Views of our distinctive Arizona Sonoran desert and wildlife do not merit being tainted
by the visual pollution of digital signs.
There is no public benefit should this TA be passed, yet proponents apparently
believe they deserve special consideration.
Please deny the demands of special interest groups, and act in favor of the public.
Advertisers can convey their messages in other ways than through digital billboards,
but private citizens cannot easily regain dark starry skies, natural views, and peace of
mind in their homes and yards once these are “lost” to a proliferation of digital signs.
Please reject this text amendment.
Sincerely,
Mary K. Mulligan
125 E. Maryland Ave.
Phoenix, AZ 85012
Sent from my iPhone
From:
Oliver, Amy
To:
Ray Banker (PND); Rachel Applegate (PND)
Cc:
Green, Richard F - (rgreen)
Subject:
Response to proposed TA2018001 from Arizona Observatories
Date:
Thursday, June 17, 2021 6:37:13 AM
Attachments:
MaricopaCounty_TA2018001_20210617.pdf
Hello Ray and Rachel,
My name is Amy C. Oliver and I am writing to you today on behalf of the Arizona Astronomy
Consortium, which represents the many large observatories in Arizona.
We would like to register an official written response with the Maricopa County Planning &
Zoning Commission regarding today's ZIPPOR Agenda Item #15: TA2018001 -- Off-site
Advertising (Billboards) Draft Ordinance. We oppose the proposed revisions, and in
particular, are deeply concerned with the proposal to convert traditional static billboards to
digital billboards (or EMDs), as this would have a significant negative impact on Arizona's
observatories.
Please find our official response to TA2018001 attached.
Amy
--
Amy C. Oliver, FRAS, CPM
Public & Government Affairs Officer Visitor & Science Center
Manager
Fred Lawrence Whipple Observatory
Center for Astrophysics | Harvard & Smithsonian
Office: +1 (520) 879-4406 | Cell: +1 (801) 783-9067
670 Mt. Hopkins Rd. Amado, AZ 85645
cfa.harvard.edu | Facebook | Twitter | YouTube | Newsletter
Lowell Observatory
University of Arizona
Steward Observatory
University of Arizona
Planetary Sciences Department
Kitt Peak National Observatory
Fred Lawrence Whipple Observatory
Vatican Observatory
June 17, 2021
Maricopa County Planning & Zoning Commission
c/o Maricopa County Planning Staff
301 West Jefferson Street
Phoenix, Arizona 85003
Re: June 17th Meeting Agenda Item #15 — TA2018001 — Off-site
Advertising (Billboards) Draft Ordinance
via electronic mail to: ray.banker@maricopa.gov; rachel.applegate@maricopa.gov
Dear Maricopa County Planning & Zoning Commissioners,
As representatives of the professional observatories in the State of Arizona, we are opposed to
the major revisions proposed in the Text Amendment (TA2018001) of Chapter 2, Definitions,
and Chapter 14, Articles 1403 and 1404 of the Maricopa County Zoning Ordinance (MCZO)
relating to Off-Site Advertising Signs (Billboards).
As a reminder, Arizona hosts the world’s largest optical telescope and 10% of all the world’s
largest telescopes. The Department of Energy, the National Science Foundation, the
Smithsonian Institution, US Navy, and NASA, along with US universities and foreign
institutions, invest tens of millions of dollars annually in the operation and upgrade of the
Arizona observatories. A basis for their long-term scientific investment strategy is their
perception of the commitment of local government to protecting that national and international
investment.
The proposed revisions to TA2018001 include a provision to allow conventional billboards to
be converted to digital billboards (also referred to as electronic message displays), which are
particularly damaging to dark skies at observatory sites. State statute bans digital billboards near
scenic corridors precisely because their operation is so detrimental to dark sky preservation. We
further note that there is no mention in the draft ordinance of potential conflict with state law
(ARS Sec.28-7902), prohibiting electronic billboards within certain radii of observatories that
extend well into Maricopa County. These radii were established as part of a legislative
compromise in 2012. Allowing electronic displays in billboards countywide runs contrary to
past involvement of the major astronomical observatories with Maricopa County, and we were
not contacted or engaged in the current process.
All current EMD technologies directly radiate at least 30-percent of the light above horizontal—
older technologies up to 30 degrees, newer technologies limited to ~15 degrees. The light
radiated directly within 20 degrees above horizontal is shown in the published literature and
cited in professional lighting engineering guidance to be the strongest contributor to artificial
sky glow at observatories impacted by the urban area. For that reason, luminaires have
generally been required to emit no light above horizontal since the first lighting codes in the
1970s, and current state statutes ban EMDs as billboards in much of Arizona.
Lowell Observatory
University of Arizona
Steward Observatory
University of Arizona
Planetary Sciences Department
Kitt Peak National Observatory
Fred Lawrence Whipple Observatory
Vatican Observatory
We propose to work with you on a strategic approach to arrest the growth of artificial sky glow
from Maricopa County. The protection of the natural desert sky would benefit not only
astronomy but also tourism and residential property values, core elements of the economic
vitality of Arizona and all of its cities and counties.
Dr. Richard F. Green
Assistant Director for Government Relations
Steward Observatory
University of Arizona
Ms. Amy C. Oliver, FRAS
Dr. G. Grant Williams
Public & Government Affairs Officer
Director, MMT Observatory
Fred Lawrence Whipple Observatory
Smithsonian Astrophysical Observatory
Dr. Donald R. Davis
Fr. Paul Gabor, S.J., Ph.D.
Director Emeritus
Vice-Director, Vatican Observatory
Planetary Sciences Institute
Dr. Jeffrey C. Hall Dr. Lori Allen
Director
Director, Mid-Scale Observatories
Lowell Observatory NSF’s National Optical-Infrared Astronomy
Research Laboratory
06/12/2021
To Planning and Development Department;
& Planning and Zoning Commissioners:
Please register my opposition to the Text Amendment (TA) - TA2018001 – Off-site
Advertising (Billboards)
TA2018001 Proposes significant changes to the MCZO Sign Ordinance which are less
restrictive than those authorized by ARS 28-7912. If approved, the ordinance would impair
Maricopa County’s ability to effectively regulate and control outdoor advertising along interstate,
primary and secondary highways.
TA2018001 Proposes significant changes in billboard quantity and intensity. If the TA is
approved, it would fundamentally alter highways in a negative way throughout Maricopa County;
the only ones that are served by this significant change to the MCZO would be billboard
companies and landowners where the billboards are leased. There is no public benefit.
The TA is intended to be Maricopa County wide in many zoning districts. If passed, the following
are a few major points on what the draft TA will do to the current zoning ordinance:
1.
Allow for billboards to go to a maximum height of 80 feet at grade. Currently,
certain zoning districts are allowed a maximum of 48 feet and others only 30 feet at road
level. The new definition of grade would include both natural grade and the grade of an
elevated freeway.
2.
Allow for a reduction in spacing between billboards. Currently, they need to be
1,000 feet apart. The TA would allow for only 500 feet of separation.
3.
Allow for billboards to go from static to digital. This would greatly increase the
intensity of a billboard’s impact on any given location. Currently, Maricopa County does
not allow for digital billboards.
4. Allow for an increase of the square footage of a sign face from 300 square feet
to 672 square feet. This would increase the size of a board to the larger 14’ x 48’
industry standard.
5. Allow for an administrative approval process for new billboards with only one
public meeting for residents and other stakeholders to voice their concerns.
6. Remove the “Take Down” requirement of Legal Non-Conforming Off-Premise
Signs (Billboards) to allow conversion of Static to digital. This would violate the FSA
and contradict effective control of outdoor advertising.
Section R17-3-701-C-3 Nonconforming signs shall be in violation if:
a. A sign is enlarged (increased in any dimensions of the sign face or structural support),
b. A sign is replaced (an existing sign is removed and replaced with a completely
different sign),
c. A sign is rebuilt to a different configuration or material composition beyond normal
maintenance,
d. A sign is relocated (moved to a new position or location without being lawfully
permitted), or
e. A sign which was previously non-illuminated has lighting added.
06/12/2021
While the proposed TA does not change the ordinance as it pertains to Scenic Corridors and
overlays, it does permit billboards within 660 feet of a scenic corridor. This made sense when
billboards were only static (conventional). Digital billboards are designed to be viewed from
1,000 feet or more. Also, the definition of Scenic Corridors needs to be expanded, as do other
definitions, but scenic corridors should include any scenic route/road and historic sites adopted
or recognized by the municipalities.
Many changes proposed, all bad.
Most significantly, this proposed TA would allow digital billboards within the county to be as high
as 80 feet tall, as close as 500 feet apart and as near as 150 feet from residential property.
Currently the county does not allow this use. This would be a major increase in intensity and
could and likely will double or triple the number of billboards with messaging changing as often
as 8 seconds on digital faces double the size of current billboards.
The proposed TA also fails to address lighting and illumination standards that would mitigate the
harmful impacts on Arizona’s Dark Sky communities and Astronomy and Space Industry
If approved, the process for challenging a billboard would be just one public hearing. Residents
and other stakeholders deserve a fair and open process to voice our concerns to the county.
I do want intrusive light to trespass into residential areas.
I do not want to see more billboards on our highways, distracting drivers and compromising
driver safety.
I do not want advertising technology to rob our public views and beautiful scenery during the
day and our dark skies at night.
Please reject the proposed Text Amendment – TA2018001.
Thank you for allowing me the opportunity to participate in this regulatory process
Daniel Penton
8216 S 42ND AVE
LAVEEN, AZ 85339
From:
Kathryn Royer
To:
Ray Banker (PND); Rachel Applegate (PND)
Cc:
Bruce Arlen
Subject:
Oppose Text Amendments, TA 2018001, Offsite Advertising, Billboards
Date:
Thursday, June 17, 2021 5:11:40 AM
Dear Mr. Banker and Ms.Applegate,
I am Kathryn Royer, an elected Town Council Member from Cave Creek and a firm supporter of dark skies in
Arizona. I believe that a text amendment that is before you to expand billboards across all county lands would
blatantly disregard the values that my constituents in Maricopa County hold true. We cherish what little is left of the
starlit skies over our desert stretches and canyons. Approving an extension of intrusively digitized lit advertising
billboards is not only unnecessary, it is a stark invasion of our personal space, senses and quality of life.
There is enough advertising on social and traditional media to get us to spend every dime in our pocketbooks. Please
do not cave to the advertising industry and their lobbyists. This expansion is absolutely not necessary. Billboards are
an outdated, unsafe form of advertising and everyone knows it. I was in the Communications business for 40 years.
We did very little to none of our business on billboards.
Your constituents implore you to reject these TA based on the common sense and taxpaying voices of homeowners
who implore you not to bombard us any more with tasteless, needless, soul-sucking bright white ads in our dark,
peaceful, incomparable Sonoran desert.
Sincerely,
Kathryn Royer, Council Member
Town of Cave Creek
Sent from my iPad
From:
Caitlin Brady (DOT)
To:
Jaclyn Sarnowski (PND)
Cc:
Darren V. Gérard (PND)
Subject:
FW: Online Form Submittal: Citizen Comments
Date:
Thursday, June 13, 2019 9:45:25 AM
Caitlin Brady
602.372.1176
From: noreply@civicplus.com [mailto:noreply@civicplus.com]
Sent: Thursday, June 13, 2019 9:03 AM
To: regulations@mail.maricopa.gov
Subject: Online Form Submittal: Citizen Comments
Citizen Comments
Each Regulatory Department is committed to providing opportunities for
stakeholder input regarding the adoption and amendment of all regulatory
requirements. Your input will be collected and forwarded to the appropriate
department. You will receive a written response from the applicable department
within two business days. We appreciate your comments and your time.
Case Number/Rule
TA2018001 - Off-Site Advertising Signs (Billboards)
Department
Planning and Development
I would like to
Other
First Name
Hannah
Last Name
Bleam
Organization
City of Phoenix, Planning and Development
City
Phoenix
Zip
85003
Email
hannah.bleam@phoenix.gov
Phone Number
602-256-4242
Phone Type
Work
Would you like someone
to contact you?
No
Comments
I am the Signs Supervisor for the City of Phoenix and I
appreciate the opportunity to review this draft. After my review, I
have a few comments: In one section it notes that a billboard can
have a maximum height of 80 feet because of freeway grade. We
oppose billboard height above 70 feet, so we propose reducing
the maximum height to 70 feet, from 80 feet. If 80 feet is
adopted, it is likely going to be something that billboard
companies will try to achieve outside of the county limits as well.
The City of Phoenix ordinance allows billboard heights of 70 feet
through a use permit process that requires the applicant to prove
they their proposed billboard will be visually impacted because of
grade, etc. The current County text amendment draft does not
outline a process where the applicant must prove that they need
the height because of freeway grade. I would suggest that the
conditional use permit process (that is outlined for digital
billboards) also be used to have a billboard height of up to 70
feet. In addition, there is a provision about notifying surrounding
municipalities for a digital billboard proposal (conditional use
permit process) only when the property is within a municipal plan.
However, I would recommend including notifications to
municipalities when the digital billboard proposed is within 1 mile
of city limits. It is helpful for cities/towns to know of the digital
billboards that are in close proximity of the municipalities and not
only that are within plans.
If applicable, attach
supporting documentation
associated with your
comment.
Field not completed.
Email not displaying correctly? View it in your browser.
May 30, 2019
Darren V. Gerard, AICP
Maricopa County Planning and Development Department
501 North 44th Street, Suite 200
Phoenix, AZ 85008-6526
Re:
TA2018001 – Off-site Advertising
(Surprise Case # PS19-016)
Dear Mr. Gerard,
In March of 2018, the Surprise City Council adopted a new Sign Code, which included a prohibition on
billboards. With that in mind, we would ask that you consider the following changes to the proposed
revisions:
1.
The definition of “Freeway” references “U.S. Highway 60”, but then states “(U.S. 60 - Superstition
Freeway)”. Given that the definition of “Scenic Corridor” points to Chapter 10 of the MCZO, and
Section 1008 of the MCZO discusses the Wickenburg Scenic Corridor, we would ask that the
language clarify that no portion of U.S. 60 from Bell Road north is included in the definition of
“Freeway”.
2.
Also regarding the definition of “freeway”, there is only a small segment of Loop 303 that is
located both in unincorporated Maricopa County and within the Surprise Planning Area. We
would ask that this segment be deleted from the definition of Freeway. This would be consistent
with the aforementioned Wickenburg Highway Scenic Corridor and would avoid confusion as the
result of conflicting language.
3.
Section 1403.3 .1.A.1.a requires a 3,000 foot separation between billboards if located within 3
miles of any incorporated city or town; however, Section 1403.3 .1.A.1.b reduces that separation
distance to 1,000 feet if located fewer than 3 miles from an incorporated city or town. Our
preference would be to maintain 3,000 foot separation regardless.
4.
Section 1403.3 .1.A.2.a discusses a pole cover that identifies the “nearest City”; however, the
language is somewhat confusing. Also, in as much as the City of Surprise prohibits billboards, we
would not want a pole cover that includes reference to the City of Surprise as it would infer the
city’s support for billboards within the City’s planning area. We would ask this language be
clarified in this regard.
5.
Section 1403.3.1.B.1 requires that billboards be setback from any rural or residential zoning
district boundary or use by a distance of not less than 100 feet. Our preference would be to
increase that setback distance to 300 feet.
6.
Section 1403.3.1.B.2 requires that illuminated billboards be setback from any rural or residential
zoning district boundary or use by a distance of not less than 150 feet. Our preference would be
to increase that setback distance to 300 feet.
7.
Section 1403.3.1.J.5 requires minimum 8-second hold time; however, this does not comport to
the Level 3 or Level 4 EMD as elsewhere defined. We would suggest some clarifying language as
to when Level 3 and Level 4 EMDs are allowed to exceed the 8-second rule.
We appreciate the opportunity to comment and would ask that you keep us apprised of any changes.
Respectfully,
Robert H. Kuhfuss, AICP, MPA
Current Planning Supervisor
City of Surprise
Cc:
Lloyd Abrams, Assistant Community Development Director
Chris Boyd, Acting Community Development Director
File