TA2018001 BOS REPORT_PART4.PDF

Maricopa County — Formal (2021-10-06)

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William J. Shaheen 
10919 E Silver Mine Rd 
Gold Canyon, AZ 85118 
WJShaheen@aol.com 
(480) 671-7707 
 
April 20, 2011 
 
Ms. Jami Garrison, GISP 
302 North 1st Ave, Ste 300 
Phoenix, AZ 85003 
 
Re: Dark Skies Stakeholders Group 04/19/2011 Meeting 
 
Dear Jami, 
 
Again, thank you and Nathan for the opportunity to participate in yesterday’s 
meeting. As such, I would like to submit my observations and thoughts overall. 
 
It may be convenient to believe that proponents of the Pattern Outdoor Lighting 
Code are reclusive astronomers wanting to covet and hoard to themselves the 
night skies, at the expense of the businesses affected and at the reduction of 
safety. That was the picture that the uncompromising opponents of the code 
attempted to paint in yesterday’s meeting.  
 
From our perspective, astronomers are in effect the “canaries in the coal mine” 
who can’t help but be the first to notice the very apparent and readily visible 
effects of a more fundamental underlying process: the conspicuous and gluttonous 
consumption of energy. Light pollution is just one by-product of an overall social-
economic system in which we are consuming natural resources and polluting the 
environment at an unsustainable rate. Therefore, it is a community obligation of 
all citizens, private and corporate, to engage in efficient practices that use as much 
as necessary but as little as possible. 
 
The last thing this community needs is yet another issue to polarize us. And it is 
unfortunate that the POLC opponents failed to see that intelligently planned 
lighting is both efficient and effective and consequently a win-win proposition for 
the community as a whole.

Now, I would like to address the specific issue of cost that was raised by the 
representatives from the business community. And, mind you, we are not 
unsympathetic, since we live, work and shop here as well. 
 
In general, one does not get to defray cost by impinging on the rights of others.  
The business community does not have the right to pollute my environment so 
they can avoid expense, just as I, for example, do not have the right to dump my 
garbage in the desert just because it would be a cost to dispose of it properly. 
Expense is not an excuse. It’s simply the cost of doing business. 
 
I’m sure the auto industry incurred increased costs when they were required to 
install features we now take for granted. Few of us recall “padded dashboards” 
being an amenity, much less seat belts, air bags and disk brakes. A better analogy 
may be the catalytic converter – for those who do not recall the odor of a passing 
car before the converter was required, again, reluctantly by the auto industry. 
 
Also, there were several issues identified that can be easily mitigated.  For 
example, the issue of what to do about a sign board in a shopping mall in which 
all the stores don’t close at the same time. There assertion that the sign casing 
would have to be taken off its concrete foundation and be retrofitted is a stretch to 
say the least. The ruling could simply be turn off the entire sign when the last 
store closes. And even at that, the modern sign boards really are not the issue they 
once were. In fact, many of the facilities they showed as having to be replaced 
already comply with the code, due to their recent development. Not one of the 
signs that were presented as effective by the Arizona Sign Association is the 
problem.  There are, however, some newer signs that could be a problem.  
 
It is unfortunate, but not surprising, that at the close of yesterday’s meeting the 
business representatives chose such a staunch and uncompromising position. 
Hopefully, we can work with them, as well as community managers, to arrive at 
solutions that we can all live with, and breathe a little better about. 
 
 
Sincerely, 
 
 
William J. Shaheen 
Superstition Mountain Astronomical League 
 
Cc: Nathan Pryor, MPA

1
Jami Garrison
From:
Bob Christ [bchrist@tolisgroup.com]
Sent:
Monday, April 25, 2011 3:44 PM
To:
Jami Garrison
Subject:
Phoenix dark sky issue
Hello Heidi, I am providing the following content  FYI.  I am sending it to our politicians and others that may 
have influence to protect our night sky.  Thank you. 
--------------------------------------------- 
 
The following message is time-gated, my apologies.  Action before May 17th is requested. 
Who cares about unfettered visual access to the wonders of the night’s sky?  Clearly anyone that simply does 
not care, or those individuals willing to prostitute themselves to make the almighty dollar (a much more 
dangerous group).  In this camp the organizations of: Arizona Association of Retailers, Arizona Food 
Marketing Alliance, Arizona Bankers Association, Arizona Sign Association, and International Council 
of Shopping Centers must be included. 
The sky cannot speak for itself, and we as prudent human stewards must provide the “voice.” 
The Maricopa Association of Governments (MAG) Dark Sky Stakeholder Group is actively engaged in 
discussions regarding initiatives that will have a severe impact on the ability to view the night sky.  
The scary part is the rationale and misstated facts of parties interested to press their agendas forward 
at the cost of further losing access to a dark sky.  I was told one mall developer simply stated “there is 
no light pollution issue” and summarily dismissed the topic. 
Why should we care? 
Significant research has been published that proves both humans, and other animals, need darkness at nighttime 
to achieve optimal mental and physiological health.  Want to bet some of the behaviors we are seeing with 
increased frequency are not environmentally induced – I will not. 
Too, dark skies are needed to perform important research, including that of the early identification of asteroids 
that can send us into extinction should the Earth be impacted before we can react.  This is a very real issue, not 
science fiction. 
One only needs to drive eastward from California toward Phoenix on Route 10 to view the impact to our sky.  
Over 100 miles from Phoenix, the visible light generated by ambient and misdirected light fixtures already 
creates a parabolic dome that extends some 30 degrees above the horizon, totally obscuring that portion of the 
sky.  One in the Valley needs only look outside in the late evening to see how few stars (less than 100) are 
visible in contrast to those that should be visible (thousands). 
When we moved into the Valley some 12-years ago my family and I attended an astronomy presentation in the 
White Mountains.  Following the presentation the lights were turned-off for telescope viewing and the Milky 
Way became visible like a long, cloud band in the sky.  Oooohs and ahhhhs of amazement were uttered by most 
everyone.  That same exercise today results in a delivered sky that is slight darker than Phoenix and no Milky 
Way is visible.  The shame of it; we are losing the night sky.

2
The USA was once a technology leader but this cannot be said now; especially regarding astronomy.  Future 
astronomers are not germinated because the wonder of the sky is now not part of a young person’s 
consciousness.  They have never seen a truly dark sky and there is no wonderment generated.  This too is a 
shame. 
From a purely mercenary perspective, Arizona benefits significantly from the research and attendant dollars 
spent to conduct astronomy-related research.  Light up the Arizona sky, and the resources and dollars will flow 
elsewhere. 
Correcting the light-pollution ills already facing us is a task that will take time and support to achieve.  Such 
corrections are, and have been, implemented by forward-thinking cities and countries around the globe.  The 
immediate need is to prevent further encroachment on our night skies, here, in our Phoenix backyard.  
The next MAG meeting is scheduled for May 17th, and the group is looking for input prior to the session. 
I ask for your support to help assure the concerns I raise as well as those supplied to you by others “in the 
know” are understood and brought to “good light.”  Otherwise, the future of access to the sky will be mortgaged 
for the benefit of a few in the short-term. 
And this would certainly be a shame from many perspectives.  
Thank you kindly, 
Bob Christ 
bchrist@tolisgroup.com 
480.473.0966 
A concerned citizen that must “remember” the beauty of the sky versus view it. 
  
  
            
  
     
   
 
Bob Christ 
TOLIS Group, Inc. 
bchrist@tolisgroup.com 
Ph: 480.505.0488 x228 
Fax: 480.505.0492 
www.tolisgroup.com 
The Data Backup & Recovery Experts

Keith J. Krueger 
 
 
 
 
 
 
 
 
 
11181 E. Peralta Canyon Dr. 
 
 
 
 
 
 
 
 
Gold Canyon AZ, 85118 
 
 
 
 
 
 
 
 
August 8, 2011 
 
 
 
Ms. Jami Garrison 
Socioeconomic Research Program Manager 
Maricopa Association of Governments 
302 N. 1st Ave, Ste 300 
Phoenix, AZ 85003 
 
Dear Ms. Garrison, 
 
I have reviewed the Resource Guide and Report that was developed for the MAG Dark 
Sky Stakeholder’s group and distributed last month, and I attended the Dark Sky 
Stakeholder’s meeting that was held on July 26th, 2011.  
 
The Arizona Sign Association asserts in their letter of October 2010 that the Model 
Lighting Ordinance published by the International Darksky Association, and the 
Illuminating Engineering Society, proposes to exempt sign lighting from curfew 
requirements. I am attaching a copy of the final adopted version of this MLO, so that you 
can confirm for yourself that there is no such exemption proposed for sign lighting. The 
relevant portion can be found on page 10 of the ordinance text.  
 
During the meeting that occurred on July 26th, Tab Bommarito, of Arizona Fish and 
Game, made the constructive observation that perhaps our discussion has focused too 
much on the benefits to the astronomical community that well enforced lighting codes 
provide. In addition to preserving dark skies, which itself draws people to our state and 
increases business, dark skies also lay the foundation for a healthy habitat environment 
that people come to our state to enjoy in the daytime. In addition, lighting codes offer the 
opportunity for communities create warm, welcoming, and aesthetically pleasing night 
time environments by doing away with “glare bomb” lighting, that make a community 
look like a prison yard or junk yard at night.  
 
Tab also made reference to the increasingly well documented negative effects that light 
pollution can have on human health. In support of this observation, I am attaching a 
research article that was done at the University of Connecticut and a letter from Dr. 
Steven Lockley, of the Harvard Medical School. It has long been known that women in 
industrialized and urbanized counties are much more likely to develop breast cancer. 
What was not well known until recently is the mechanism behind this correlation. The 
past 15 years have produced a mountain of evidence pointing toward light pollution.

The fact is that life on our planet, at least life that exists on or near the surface of the 
planet, including human life, is adapted for functioning in an environment that 
experiences both light, and darkness. This is the way the Earth was formed, and man can 
not improve upon it.  
 
It is said that when Teddy Roosevelt was brought to the Grand Canyon, he gazed out over 
the vista and, after a long pause, said: “Leave it as it is. Just leave it as it is”. “Leave it as 
it is” describes the prescription most suitable to the night sky as well. As trustees for 
those who will follow us, it is incumbent upon us to act as faithfully as did those who 
preserved that Grand Canyon for us, as it is.  
 
Sincerely, 
 
Keith J. Krueger 
Section Leader 
International Darksky Association  
 
 
Attachments: 
1 – Coalition Response to Resource Guide 
2 – International Dark Sky Model Lighting Ordinace (MLO) (page 10 excerpt) 
3 – Artificial lighting in the industrialized world: circadian disruption and breast cancer 
4 – Dr. Steven Lockley letter on effects of street lighting

July 25, 2011 
 
To:  Dark Sky Stakeholders Group 
From: The Coalition for Safe and Responsible Lighting 
Re:  The Proposed Resource Guide and Report 
The Coalition for Safe and Responsible Lighting has some serious concerns with the Proposed Resource Guide and 
Report.  The following is a summary of our concerns for your consideration: 
 
The Resource Guide and report does not take into account the costs to businesses that would be incurred to 
comply with the changes provided by the model code. 
 
The Coalition has some serious concerns with proposed sign regulations, including the proposed color 
limitations, sign curfews, and the restrictive night time illumination level for electronic message centers. 
 
The Resource Guide should be based on environmentally, safety and fiscally responsible lighting standards, not 
just to protect the astronomy community’s interests.  The approach in the Resource Guide will create an undue 
hardship and economic impact on the business community. 
 
Business stakeholders have strong concerns that the Resource Guide does not provide for the safety and 
security of customers. 
 
The Resource Guide does not address the primary cause of “light pollution” such as freeways, streetlights and 
ball fields. 
 
The Resource Guide holds businesses accountable for costly changes but does not require the municipalities to 
comply with these standards. 
 
The Pattern Outdoor Lighting section of the Resource Guide is unnecessary as cities are currently working well 
with local businesses to address responsible lighting practices and light pollution in the their cities.   
 
The Coalition for Safe and Responsible Lighting appreciates your consideration of our concerns. 
 
 
President  and CEO 
Greater Phoenix Chamber of 
Commerce 
Richard Hubbard 
Richard Hubbard 
CEO/President 
Valley Partnership 
 
Tim McCabe  
President 
Arizona Food Marketing  
 
 
 
 
 
 
Steve Helm 
Arizona State Director 
International Council of 
Shopping Centers 
 
 
Michelle Ahlmer 
Executive Director 
Arizona Retailers Association 
 
 
Stacey J. Langford 
V.P. Member Services 
Arizona Bankers Association 
James Carpentier 
James B. Carpentier, AICP 
State & Local Government 
Affairs Manager 
International Sign Association 
Michael Mayhew 
Southern RM/CA Commercial 
Regional Manager 
Daktronics 
Raymond Owens 
Raymond Owens 
President 
Arizona Sign Association

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).
References
1. Parkin DM, Bray FI, Devesa SS (2001) Cancer burden in the year
2000: the global picture. Eur J Cancer 37:S4–S66
2. Nagata C, Kawakami N, Shimizu H (1997) Trends in the inci-
dence rate and risk factors for breast cancer in Japan. Breast
Cancer Res Treat 44:75–82
3. Madigan MP, Ziegler RG, Benichou J, et al. (1995) Proportion of
breast cancer cases in the United States explained by well-
established risk factors. JNCI 87:1681–1685
4. Stevens RG, Rea MS (2001) Light in the built environment:
potential role of circadian disruption in endocrine disruption and
breast cancer. Cancer Causes Control 12:279–287
5. Stevens RG, Davis S, Thomas DB, Anderson LE, Wilson BW
(1992) Electric power, pineal function, and the risk of breast
cancer. FASEB J 6:853–860
6. Pukkala E, Auvinen A, Wahlberg G (1995) Incidence of cancer
among Finnish airline cabin attendants, 1967–92. Brit Med J
311:649–652
7. Tynes T, Hannevik M, Andersen A, et al. (1996) Incidence of
breast cancer in Norwegian female radio and telegraph operators.
Cancer Causes Control 7:197–204
8. Hansen J (2001) Increased breast cancer risk among women who
work predominantly at night. Epidemiology 12:74–77
9. Davis S, Mirick DK, Stevens RG (2001) Night shift work, light at
night, and risk of breast cancer. JNCI 93:1557–1562
10. Schernhammer ES, Laden L, Speizer FE, et al. (2001) Rotating
night shifts and risk of breast cancer in women participating in
the Nurses’ Health Study. JNCI 93:1563–1568
11. Hahn RA (1991) Profound bilateral blindness and the incidence
of breast cancer. Epidemiology 2:208–210
12. Feychting M, O¨ sterlund B, Ahlbom A (1998) Reduced cancer
incidence among the blind. Epidemiology 9:490–494
13. Verkasalo PK, Pukkala E, Stevens RG, Ojamo M, Rudanko S-L
(1999) Inverse association between breast cancer incidence and de-
gree of visual impairment in Finland. Brit J Cancer 80:1459–1460
14. Kliukiene J, Tynes T, Andersen A (2001) Risk of breast cancer
among Norwegien women with visual impairment. Br J Cancer
84:397–399
15. Stevens RG (1987) Review and Commentary. Electric power use
and breast cancer a: hypothesis. Am J Epidemiol 125:556–561
16. Cohen M, Lippman M, Chabner B (1978) Role of the pineal
gland in the aetiology and treatment of breast cancer. Lancet
2:814–881
17. Shah PN, Mhatre MC, Kothari LS (1984) Effect of melatonin on
mammary carcinogenesis in intact and pinealectomized rats in
varying photoperiods. Cancer Res 44:3403–3407
18. Brzezinski A (1997) Melatonin in humans. N Engl J Med
336:186–195
19. Penny R, Stanczyk F, Goebelsmann U (1987) Melatonin: data
consistent with a role in controlling ovarian function. J Endo-
crinol Invest 10:499–505
20. Kauppila A, Kileva¨ A, Pakarinen A, Vakkuri O (1987) Inverse
seasonal relationship between melatonin and ovarian activity in
humans in a region with a strong seasonal contrast in luminosity.
J Clin Endocrinol Metab. 65:823–828
21. Baumgartner A, Dietzel M, Saletu B, et al. (1993) Influence of
partial sleep deprivation on the secretion of thyrotropin, thyroid
hormones, growth hormone, prolactin, luteinizing hormone, fol-
licle stimulating hormone, and estradiol in healthy young women.
Psychiatr Res 48:153–178
22. Sanchez-Barcelo EJ, Cos S, Fernandez R, Mediavilla D (2003)
Melatonin and mammary cancer: a short review. Endocr-Relat
Cancer 10:153–159
23. Pawlikoski M, Kolomecka M, Wojtczak A, Karasek M (2002)
Effects of six months melatonin treatment on sleep quality and
serum concentrations of estrtadiol, cortosil dehydroepiandroster-
one sulfate, and somatomedin C in elderly women. Neuroendo-
crinol Lett 23(suppl 1):17–19
24. Graham C, Cook MR, Gerkovich MM, Sastre A (2001) Examina-
tion of the melatonin hypothesis in women exposed at night to EMF
and bright light. Environ Health Perspect 109:501–507
25. Schernhammer ES, Rosner B, Willett WC, Laden F, Colditz GA,
Hankinson SE (2004) Epidemiology of uriniary melatonin in
women and its relation to other hormones and night work. Cancer
Epidemiol Biomark Prev 13:936–943
26. Stevens RG (2005). Circadian disruption and breast cancer: from
melatonin to clock genes. Epidemiology 16:254–258
27. Dauchy RT, Blask DE, Sauer LA, Brainard GC, Krause JA
(1999) Dim light during darkness stimulates tumor progression
by enhancing tumor fatty acid uptake and metabolism. Cancer
Lett 144:131–136
28. Blask DE, Dauchy RT, Sauer LA, et al. (2003) Growth and fatty
acid metabolism of human breast cancer (MCF-7) xenografts in
nude rats: impact of constant light-induced nocturnal melatonin
suppression. Breast Cancer Res Treat 79:313–320
29. Travis RC, Allen DS, Fentiman IS, Key TJ (2004) Melatonin and
breast cancer: a prospective study. J Natl Cancer Inst 96:475–482
30. Key TJ, for the The Endogenous Hormones, Breast Cancer
Collaborative Group (2002) Endogenous sex hormones and
breast cancer in postmenopausal women: reanalysis of nine
prospective studies. J Natl Cancer Inst 94:606–616
31. Fu L, Lee CC (2003) The circadian clock: pacemaker and tumor
suppressor Nature Reviews. Cancer 3:350–361
32. Blask DE, Pelletier DB, Hill SM, et al. (1991) Pineal melatonin
inhibition of tumor promotion in the N-nitroso-N-methylurea
model of mammary carcinogenesis: potential involvement of
antiestrogenic mechanisms in vivo. J Cancer Res Clin Oncol
117:526–532
506
Cancer Causes Control (2006) 17:501–507
123

33. Blask DE, Wilson ST, Zalatan F (1997) Physiological mela-
tonin inhibition of human breast cancer cell growth in vitro
evidence for a glutathione-mediated pathway. Cancer Res
57:1909–1914
34. Hill SM, Spriggs LL, Simon MA, Muraoka H, Blask DE (1992)
The growth inhibitory action of melatonin on human breast
cancer cells is linked to the estrogen system. Cancer Lett 64:249–
256
35. Sephton S, Spiegel D (2003) Circadian disruption and cancer: a
neuroendocrine-immune pathway from stress to disesase. Brain
Behav Immun 17:321–328
36. Amir S, Stewart J (1999) The effectiveness of light on the circa-
dian clock is linked to its emotional value. Neurosci 88:339–345
37. Wirz-Justice A, Krauchi K, Cajochen C, Danilenko KV, Renz C,
Weber JM (2004) Evening melatonin and bright light adminis-
tration induce additive phase shifts in dim light melatonin onset. J
Pineal Res. 36:192–194
38. Lewy AJ, Wehr TA, Goodwin FK, et al. (1980) Light suppresses
melatonin secretion in humans. Science 210:1267–1269
39. Brainard GC, Hanifin JP, Greeson JM, et al. (2001) Action
spectrum for melatonin regulation in humans: evidence for a
novel circadian photoreceptor. J Neurosci 21:6405–6412
40. Khalsa SBS, Jewett ME, Cajochen C, Czeisler CA (2003) A
phase response curve to single bright light pulses in human
subjects. J Physiol 549:945–952
41. Hebert M, Martin SK, Lee C, Eastman CI (2002) The effects of
prior light history on the suppression of melatonin by light in
humans. J Pineal Res 33:198–203
42. Jo¨chle W (1964) Trends in photophysiologic concepts. Ann NY
Acad Sci 117:88–104
43. Lucas RJ, Freedman MS, Mun˜oz M, Garcia-Ferna´ndez JM,
Foster RG (1999) Regulation of the mammalian pineal by non-
rod, non-cone, ocular photoreceptors. Science 284:505–507
44. Khaetski IK (1965) Effect of hypothalamo-pituitary lesions in-
duced by constant illumination on development of induced
mammary tumors in rats. Vopr Exp Oncol (Kiev) 1:87–93
45. Anisimov VN (2002) The light-dark regimen and cancer devel-
opment. Neuroendocrinol Lett 23(suppl 2):28–36
46. Anderson LE, Morris JE, Sasser LB, Stevens RG (2000) Effect of
constant light on DMBA mammary tumorigenesis in rats. Cancer
Lett 148:121–126
47. Russo IH, Russo J (1996) Mammary gland neoplasia in long-term
rodent studies. Environ Health Perspect 104:938–967
48. Russo IH, Mailo D, Morris JE, Anderson LE, Stevens RG (2004)
Artificial Light and Circadian Rhythms: Influence of Age and
Length of Exposure to Constant light on Mammary Gland
Development and Cancer Risk. meeting abstract, ‘Emerging
Topics in Breast Cancer and the Environment’. Organized by
Breast Cancer and the Environment Research Centers, NIH.
Princeton, NJ, November 4–6, 2004
49. Trichopoulos D (1990) Hypothesis: does breast cancer originate
in utero?. Lancet 335:939–940
50. Potischman N, Troisi R (1999) In utero and early life exposures
in relation to risk of breast cancer. Cancer Causes Control
10:561–573
51. Horne JA, O¨ stberg O (1976) A self assessment questionnaire to
determine morningness-eveningness in human circadian rhythms.
Int J Chronobiol 4:97–110
52. Griefahn B, Ku¨nemund C, Golka K, et al. (2002) Melatonin
synthesis: a possible indicator of intolerance to shiftwork. Am J
Indus Med 42:427–436
53. Griefahn B (2002) The validity of the temporal parameters of the
daily rhythm of melatonin levels as an indicator of morningness.
Chrono Int 19:561–577
54. Schernhammer ES, Laden F, Speizer FE, et al. (2003) Night-shift
work and risk of colorectal cancer in the Nurses’ Health Study.
J Natl Cancer Inst. 95:825–888
55. Zhang Y, Felson DT, Ellison RC, et al. (2001) Bone mass and the
risk of colon cancer among postmenopausal women. Am J Epi-
demiol 153:31–37
56. Nelson HD, Humphrey LL, Nygren P, Teutsch SM, Allan JD
(2002) Postmenopausal hormone replacement therapy. JAMA
288:872–881
57. Stokkan KA, Yamazaki S, Tei H, Sakaki Y, Menaker M (2001)
Entrainment of the circadian clock in the liver by feeding. Sci-
ence 291:490–493
58. Damioloa F, Minh NL, Preitner N, Kornmann B, Fleury-Olela F,
Schibler U (2000) Restricted feeding uncouples circadian oscil-
lators in periferl tissues from the central pacemaker in the sup-
rachiasmatic nucleus. Gene Devlop 14:2950–2961
59. Baird TJ, Briscoe RJ, Vallett M, Vanecek SA, Holloway FA,
Gauvin DV (1998) Phase-reponse curve for ethanol: alterations in
circadian rhythms of temperature and activity in rats . Pharmacol
Biochem Behav 61:303–315
60. Allen GC, West JR, Chen WA, Earnest DJ (2004) Develop-
mental alcohol exposure disrupts circadian regulation of BDNF
in the rat suprachiasmatic nucleus. Neurotox Teratol 26:353–
358
61. Farnell YZ, West JR, Chen WA, Allen GC, Earnest DJ (2004)
Developmental alcohol exposure alters light-induced phase shifts
of the circadian activity rhythm in rats. Alcohol Clin Exp Res
28:1020–1027
62. Beral V for the Collaborative Group on Hormonal Factors and
Breast Cancer (2002) Alcohol, tobacco and breast cancer –
collaborative reanalysis of individual data from 53 epidemio-
logical studies, including 58515 women with breast cancer and
95067 women without the disease Brit J Cancer 87:1234–1245
63. Stevens RG, Hiatt RA (1987) Alcohol, melatonin, and breast
cancer. N Engl J Med 317:1287
64. Stevens RG, Hilakivi-Clarke L (2001) Alcohol exposure in utero
and breast cancer risk later in life. Alcohol Alcoholism 36:276–
277
65. Hilakivi-Clarke L, Cabanes A, De Assis S, Khan G, Shoemaker
WJ, Stevens RG (2004). Low In Utero alcohol exposure increases
mammary tumorigenesis in rats. Brit J Cancer 90:2224–2230
66. Moolgavkar SH, Day NE, Stevens RG (1980) Two-stage model
for carcinogenesis: epidemiology of breast cancer in females.
JNCI 65:559–569
67. Colditz GA, Rosner B (2000) Cumulative risk of breast cancer to
age 70 years according to risk factor status: data from the Nurses’
Health Study. Am J Epidemiol 152:950–964
68. Zhu Y, Brown HN, Zhang Y, Stevens RG, Zheng T (2005)
Period3 structural variation: a circadian biomarker associated
with breast cancer in young women. Cancer Epidemiol Biomark
Prev 14:268–270
69. Hill AB (1965) The environment and disease: association or
causation? Proc Royal Soc Med 58:295–300
70. Kawachi I, Colditz GA, Stampfer MJ, et al. (1995) Prospective
study of shift work and risk of coronary heart disease in women.
Circulation 92:3178–3182
71. Hansen J (2001) Editorial: light at night, shiftwork, and breast
cancer risk. JNCI 93:1513–1515
Cancer Causes Control (2006) 17:501–507
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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.
 
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