Light Pollution and the protection of Dark Skies

Unique Reference Number:

MYO-C11-709

Status:

Submitted

Author:

Mayo Dark Skies

Consultation:

Draft Mayo County Development Plan 2021-2027

Date Submitted:

16.03.2021 - 15:03

No. of documents attached:

Boundaries Captured on Map:

Author:

Mayo Dark Skies

Cover Letter

We refer to our previous submission to the pre-draft stage of ‘Mayo County Development Plan 2020-2026’ dated June 2018 and thank you for the opportunity to comment on the Draft Mayo County Development Plan 2021-2027.

The Friends of Mayo Dark Skies is a voluntary group, established by local people from Newport, Mulranny and Ballycroy to promote the goals of Mayo International Dark Sky Park and to raise awareness of light pollution. Our motto is “Let’s raise children who can name more stars in the sky, than stars on the screen”.

In recognition of the need to reduce the impact of light pollution within county Mayo and to protect existing areas of natural darkness including Mayo Dark Sky Park, we request the adoption of an ecologically sensitive and dark sky friendly lighting policy. A Dark Sky policy supports several sustainable goals including biodiversity, climate, wellbeing and education and provides a better quality night time environment for residents and communities, whilst maintaining standards required for safety and security concerns.

We are pleased to note the references to importance of Dark Skies and Mayo Dark Sky Park within the new draft plan, however, some clarity is required on lighting specifics and the references to dark sky friendly lighting. One of the key principles of which is the reduction and restriction of blue rich light emissions i.e. a move to warm toned LED lighting of a Correlated Colour Temperature (CC) of less than 2700 Kelvins.

Furthermore, we enclose images of designs for the lighting of the viaduct Seven Arches bridge and St Patrick’s Church in Newport town. These two iconic examples of built heritage for Newport, are currently lit inappropriately, causing light pollution and ultimately causing a threat to the future preservation of the dark sky park. In both cases, the existing lighting fixtures were installed by the council some time ago and are in urgent need of replacement. We urge the council to implement the designs developed in consultation with the community to enhance the town after dark and create a model for best practice across the country.

Our dark sky policy reflects the values of Mayo County Council and we have engaged with Roads Management Office and Transport Infrastructure Ireland (TII) in our research and consultations. We refer to the document ‘Best Practice for Lighting’ in relation to public lighting wish to stress that each local authority has the autonomy to move to correlated colour temperatures even below 2700 Kelvins in order to protect sensitive ecological or dark sky areas.

Guidelines for best practice lighting by local authorities have been published by Prof. Brian Espey of Trinity Collage Dublin as part of Dark Sky Ireland’s resource pool. More specifications can be found here: https://www.darksky.ie/wp-content/uploads/2020/04/BestPracticesInPublicLighting_BEspey2020.pdf

Please find enclosed our comments and observations on the draft as follows:

Observations

Linking Sustainable Development Goals

Chapter:

Volume 1 - Written Statement » 01. Introduction

1.4 UN Sustainable Development Goals

We note the inclusion of the alignment between the NPF, the RSES and the UN Sustainable Development Goals (SDGs). Mayo Dark Skies aligns with a number of the SDGs as follows:

Goal 3: Good Health and wellbeing

Light pollution is detrimental to our health and wellbeing. Dark sky activities can promote improved health through, nature connection, biological rhythms, positive emotions, a sanctuary from technology and the opportunity to enjoy clean air and skies free from light pollution.

Goal 4: Quality Education

Dark skies can provide inclusive and equitable education to promote lifelong learning. It brings new opportunities to Mayo for research on astronomy, light pollution and rural tourism and wellbeing.

Goal 5: Gender equality and women’s empowerment

Bridging the gender divide is especially important in STEM fields and astronomy has been used as catalyst in this process in many countries.

Goal 7: Energy

Light pollution is not just a challenge for astronomy but also affects living things. The Dark Skies Rangers programmes raise of the impact of light pollution on biodiversity, wellbeing and energy consumption.

Goal 8: Decent work and Economic Growth

Dark skies promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all throughout the year.

Goal 9: Industry, Innovation and Infrastructure

Dark skies promotes investment in sustainably managed projects and fosters innovation in rural areas.

Goal 10: Inequality

Dark skies promotes equality in peripheral and remote communities with opportunities for capacity building and training, rural development and sustainable tourism.

Goal 11: Sustainable Communities

Through engagement and outreach programmes, dark sky programmes promote community stewardship and collaborations.

Goal 13: Climate Change

Artificial lighting is a significant part of energy consumption for local authorities, communities and businesses. Adopting dark sky friendly policies can contribute to climate action and reduction of energy waste.

Goal 14: Life under Water/Oceans

Studies have shown that excess artificial light has a detrimental impact on marine species and ecosystems as well as coastal wildlife. Dark Sky programmes promote best practice lighting to reduce this impact and provide informed choices for alternative lighting.

Goal 15: Life on Land / Biodiversity

Light pollution harms many ecosystems; migrating and nesting birds, pollinators, nocturnal species and tree species. Adopting dark sky policies helps reduce this negative impact and restores our natural cycles of day and night.

Goal 17: Partnerships

Mayo Dark Skies project continues to promote inclusive partnerships with community groups, regional authorities, at national and international level built upon shared values and common interests to preserve and protect our night skies for future generations.

Main opinion:

The concept of a dark sky policy aligns with a number of the SDGs and takes an holistic approach to artificial lighting for a nocturnal environment and the community needs. It is appropriate to highlight the applicable connections and recognition of these alignments will assist local authority in future decision making on planning for artificial light in our communities.

Astrotourism & corrections

Chapter:

Volume 1 - Written Statement » 05. Tourism & Recreation

Topics:

Tourism

Corrections:

5. Tourism & Recreation

5.3 National and Regional Planning

Amend “Mayo Dark Sky Reserve” to Mayo Dark Sky Park. Ballycroy National Park to Wild Nephin Ballycroy National Park.

5.4.2 Fáilte Ireland’s Settlement Approach (TRP 3)

The concept of “Always On” hubs, should not extend to strategies that impact biodiversity and /or natural nocturnal ambience. From our perspective, this particularly applies to areas previous unlit at night; such areas should remain naturally dark and alternatives such as reflective markers or paints for signs/curbs and restrict the use of lit signage and permanently installed outdoor lighting.

5.4.3 Key Tourism Pillars

We recommend that Astrotourism is included as a key Tourism Category for the county. Fáilte Ireland has already included Dark Sky themes as a significant part of the Clew Bay Visitor experience Development Plan; “Under Big Skies”, and also as a catalyst project. It would be remiss not to include AstroTourism (or Dark Sky Tourism) as a key category, given significant development plans for this field within the county. Mayo should be leading the way in this emerging and sustainable market and recognising the category accordingly with the appropriate flagship projects and services listed in table 5.1.

5.4.3.1 Tourism Pillar

Cultural and Amenity Tourism

Amend Ballycroy and Nephin National Park to Wild Nephin Ballycroy National Park. However, as above the Mayo Dark Sky Park should be referenced under a separate tourism Category under Astrotourism.

Main opinion:

We recommend that Astrotourism is included as a key Tourism Category for the county. t would be remiss not to include AstroTourism (or Dark Sky Tourism) as a key category, given significant development plans for this field within the county

Main requests:

Fáilte Ireland’s Settlement Approach (TRP 3)

AstroTourism (or Dark Sky Tourism) should be included as a key category, given significant development plans for this field within the county.

Also the concept of “Always On” hubs, should not extend to strategies that impact biodiversity and /or natural nocturnal ambience.

Main reasons:

Astrotourism is a growing market and Mayo should establish its position as a leading county in servicing this market.

Preservation of biodiversity & ecology (in relation to Always on hubs)

Adjustment or wording in relation to "adequate public lighting"

Chapter:

Volume 1 - Written Statement » 06. Movement & Transport

Topics:

Cycling

Walking

Transport

6 Movement and Transport

Sustainable Transport

Pedestrians and cyclists

Mayo Dark Skies supports sustainable transport initiatives such as cycleways and paths as welcomed facility and alternative to taking private vehicles. However, the draft plan implies that a measure of success for pedestrian and cycle facilities includes, inter alia “adequate public lighting”. We strongly recommend the removal of this phrase as there are many examples of successful pedestrian and cycleways that are not lit. There are also examples of lit cycleways and pedestrian facilities that are unsuccessful, in part due to inappropriate lighting and timing and reports of pedestrians feeling they are ‘too exposed’ to potential threats with dusk to dawn lighting. Instead, we recommend the simple use of reflective markers on pathways. The use head torches and cycle lamps is more effective and allows the cyclist and pedestrian to be in control of where light is directed. Where necessary, reflective markers or luminous markers should be used on curbs, edgings or signs.

Health & Wellbeing

Chapter:

Volume 1 - Written Statement » 08. Sustainable Communities

Topics:

Health

8 Sustainable Communities

8.4.5 Health and Wellbeing

This section is duly noted and we would draw your attention to the alignment noted in section one between Dark Skies and the UN Sustainable Development Goal # 3 ‘Health & Wellbeing’. As well as physical participation, Dark and Natural skies provide areas of tranquillity and sanctuary away from artificially lit areas and these areas are part of a rare number of therapeutic landscapes in the country.

8.4.5.1.

Health & Wellbeing Objective

SCO 11

Appropriately serviced footpaths as mentioned herein are not always in need of lighting in order to be well serviced. The council should not connect wellbeing with the need for artificial lighting on all footpaths and allow provision for decision making and justification. When lighting is absolutely necessary it should be warm toned (low CCT as defined elsewhere) and designed adaptively to reduce power output, and be turned off during low use periods.

Lighting on Public Buildings

Chapter:

Volume 1 - Written Statement » 09. Built Environment

Topics:

9.1 Built Environment

9.4.2 Sustainable Building

We note reference to ‘improving air quality and lighting’ and request that “lighting” is clarified to be in keeping with dark sky policies.

We request that the lighting of public buildings especially, be an example of best practice with dark sky friendly lighting (as defined later in this document). This point such be added to the tables of Sustainable Buildings and Structures Policies and Objectives.

9.4.3 Placemaking

Placemaking Objectives Table

BEO 22

“Attractive” – visually pleasing spaces should qualify that lighting should be in moderation and designed appropriately so as not to cause light pollution or use lighting with high blue-rich content. We request this definition be adapted accordingly.

We kindly request the inclusion of “light pollution”(along with noise and air pollution) in the first point of considerations underpinning Green Space Principles.

Main opinion:

Lighting of public buildings should be an example of best practice and not cause light pollution.

Main requests:

In sustainable buildings, the requirement for dark sky friendly lighting policy to be incorporated into planning and especially in relation to public buildings.

Placemaking - 'light pollution' should be a consideration underpinning Green Space Principles.

Main reasons:

Public buildings have a responsibility to demonstrate best practice.

Green Space principles are incomplete without reference to reduction in light pollution.

Climate Action & Renewable Energy - Savings through lighting

Chapter:

Volume 1 - Written Statement » 11. Climate Action & Renewable Energy

Topics:

Renewable Energy

Climate Change

Climate Action

11. Climate Action & Renewable Energy

Our observation on this section is that public lighting in Mayo is currently turned on for approximately 4,100 hours per year (that is six months consistently switched on). This is a considerable use of energy for the local authority. In many cases traffic flow after midnight is minimal to zero. Whilst the savings achieved through dimming is acknowledged, there are further energy savings that can be made through “part night lighting”. This can be carefully controlled with adaptive lighting.

Many authorities in the UK have already cut carbon emissions and preserved the natural environment by adopting a part night lighting policy without evidence of increased crime or traffic incidents.

Also see work conducted by CPRE “Shedding Light” https://www.cpre.org.uk/wp-content/uploads/2019/11/Shedding_light_leaflet.pdf

11.6.5.2 Built Environment

We kindly request that the sentence “ Other projects include the retrofitting of public lighting to LEDs”be amended to include “Other projects include the retrofitting of public lighting to LEDs that are dark sky friendly as well as energy efficient”

11.6.5.2.1 Greening Built Environments

See reference in this section “It also boosts property values and adds to the quality of life by ﬁltering the air, reducing noise and creating attractive places where people can live or spend time.”

Please amend this sentence to:

“It also boosts property values and adds to the quality of life by ﬁltering the air, reducing noise and light pollution and creating attractive places where people can live or spend time.”

11.6.5.5 Nature Based Solutions

Please include the “reduction of light pollution” in this sentence:

“Solutions include but are not limited to the provision/restoration of natural habitat, ecological corridors, increased biodiversity, water treatment and retention, local amenity provision, air quality improvement, cultural and heritage preservation and flood mitigation…”

CAO4. Please include a lighting policy within this check list and guidance document.

Main opinion:

The draft plan should further consider reducing impact of excess lighting emissions, through adaptive lighting. Energy retrofits for LED lighting must also be dark sky friendly.

Light pollution should be included in Greening Built Environments and Nature Based solutions.

Main requests:

Reduction of hours to part night lighting in locations where traffic flows are minimal through the hours of 12am to 5am.

Main reasons:

Evidence of moving to part night lighting has no impact on crime or traffic incidents. https://www.ucl.ac.uk/news/2015/jul/switching-street-lights-night-does-not-increase-car-crashes-and-crime

https://www.cpre.org.uk/wp-content/uploads/2019/11/Shedding_light_leaflet.pdf

Newport - A Dark Sky Friendly Town

Chapter:

Volume 1 - Written Statement » 12. Settlement Plans

Topics:

Newport

12.17 Newport

12.17.7 Heritage and Tourism

Newport is the gateway town to Mayo International Dark Sky Park and Wild Nephin Ballycroy National Park. This offers opportunities for off-season sustainable tourism to Newport and we kindly request that inclusion of dark sky /astronomy related interests are included in the description.

In addition, a Lighting Masterplan for Newport has been prepared in collaboration with community stakeholders (funded by the Heritage council) to provide a lighting plan for the Newport to achieve its goal to become Ireland’s first dark sky friendly town. A Dark Sky policy supports several sustainable goals including biodiversity, climate, wellbeing and education for all. Reference to the lighting masterplan should be included in this document.

12.17.8 Sustainable Communities

Newport is also a registered Sustainable Energy Community with the SEAI and is preparing an Energy Master Plan. This should be noted in the plan.

12.17.9 Placemaking and Regeneration

At the end of the first paragraph after “Barrack Hill”, it should be noted that a redesign of sustainable dark sky friendly lighting is planned for St Patrick’s Church and the Viaduct Bridge. These are critical projects in order to safeguard the future of the nearby Mayo Dark Sky Park.

Finally, we kindly request an additional objective under Newport Settlement Plan Objectives:

NTO 9

To implement flagship lighting designs for St Patrick’s Church and the viaduct bridge, supporting Newport’s Lighting Masterplan and safeguarding the accreditation of nearby Mayo Dark Sky Park.

Main opinion:

Newport as the gateway town to Mayo Dark Sky Park, is the first experience a visitor encounters on travelling to the Dark Sky Park. However, currently its lighting practices are causing light pollution, and affecting the quality of the night sky in the area. A Lighting Master Plan has been drafted and images provided on designs for lighting adjustments which will be a solution to this issue. Their completion will also be an attraction for the town and align with a sustainable town objectives. In the longer term this will be a template for other areas to follow and an example of best practice for other sources of light pollution around the county. It will be Ireland's first dark sky friendly town.

Main requests:

Adoption of Lighting Master Plan and implementation of designs on St Patrick's Church and viaduct bridge to reduce levels of current light pollution.

Main reasons:

To secure the future of the gold tier International Dark Sky Park in Mayo.

To enhance built heritage of the town at night.

To improve safety and wellbeing for residents and visitors to the town at night.

To complement ecology and biodiversity in the area with sensitive, well designed and controlled lighting.

Attachments:

Church & Bridge render_Page_12.png

1.05 MB

LDW_Newport LMP -pictures only 13.png

602.34 KB

Church & Bridge render_Page_24.png

2.09 MB

Church & Bridge render_Page_04.png

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Light Pollution on the Natural Environment

Chapter:

Volume 1 - Written Statement » 10. Natural Environment

Topics:

10.4.8 Landscape

Please replace “Mayo Dark Skies” with “Mayo Dark Sky Park”

10.4.9 Coastal Zone

As noted in the draft plan, Mayo has the longest coastline in Ireland and is home to many sensitive habitats and ecosystems. Research is increasingly showing that light pollution affects the natural night time light in marine and coastal ecosystems (Davies et al, 2014). We call for very careful planning in relation to the installation of artificial lighting in coastal areas or near water bodies.

For example river and estuarine habitats support Atlantic Salmon (Salmo salar), Sea Trout (Salmo trutta) and the Freshwater Pearl Mussel (Margaritifera margaritifera). Both salmon and sea trout have been shown to be sensitive to light conditions, with both smolts and adult salmon being sensitive to light down to 0.2 lux. To put this in perspective, the light from a full moon is 0.3 lux. Other species such as the European eel synchronise migratory patterns with the new moon; the darkest phase of the lunar cycle.

Atlantic Salmon is a species which is already in decline and the Pearl Mussel is an endangered species. These are compelling reasons to restrict the illumination of coastal areas to where absolutely necessary and to engage experts in ecological lighting and marine conservation prior to installation.

10.4.11 Air Quality, Noise and Light Emissions

We note the references to mitigation of light pollution and the detrimental effect it has to Mayo International Dark Sky Park.

Air Quality, Noise and Light Emissions Objectives

Please add after NEO43; To adopt a policy within Mayo County Council for the reduction of light pollution across the county. This should include the reduction of light waste on public buildings and the use of dark sky friendly lighting only, setting examples of best practice in actively addressing light pollution.

Dark Sky Friendly Lighting:

Reduces blue-rich light emissions with recommended Correlated Colour Temperatures (CCT) of 2,700 Kelvin (or less). This is visually warm toned light and is also energy efficient.
Allows no upward light ratio by using full cut or and/or downward directed light to the task intended only.
Shines only in the intensity intended, allowing no light trespass to neighbouring property.
Timing – through the use of timers or sensors, lights should be used only when required.

Main opinion:

The impact of Light pollution emissions on ecology and the natural environment should be recognised in planning for lighting near water bodies and other sensitive habitats. Policy to be formally adopted by MCC on the reduction blue light emissions, timing, direction and quantity of light. Mayo CC to lead with best practice and actively reduce light pollution across the county.

Main requests:

To recognise light pollution policy and the impact on sensitive environments.

Main reasons:

Research is increasing showing the impact of light pollution on ecology. Example of research papers.

Kamiel etc

https://www.researchgate.net/publication/343913486_Artificial_light_may_change_flight_patterns_of_bats_near_bridges_along_urban_waterways

Emma Stone

https://onlinelibrary.wiley.com/doi/abs/10.1111/j.1365-2486.2012.02705.x

Attachments:

rspb.2016.0813.pdf

5.37 MB

BestPracticesInPublicLighting_BEspey2020.pdf

584.92 KB

Limiting Light Pollution through Planning, Policy and Design.

Chapter:

Volume 2 - Development Management Standards

Volume 2 - Development Management Standards

1. Residential (Rural)

We request the addition of light pollution within the key messages on rural house design.

Limiting light pollution

Measures to minimise light pollution spreading into the country side should be incorporated into the building plan. Use of fully shielded lights with no upward light spill and correlated colour temperatures of 2700 kelvin or lower. External lighting should be controlled for when and where needed not trespass beyond the site boundary area.

4.7.1 Location, Siting and Design of Public Open Space

Please adapt the following sentence in this section to include

Public spaces should be safe, therefore appropriate supervision, passive surveillance, appropriate boundary treatments and provision of public lighting (if and where necessary) are all to be considered.

5.6 shopfronts

Design Considerations for Lighting Retail / Commercial Premises

Lighting on shop fronts and on commercial premises is more effective if directed downwards to illuminate window contents and the name of premises.

Low wattage, well-directed lights save money and do a better job.
Use full cut-off fixtures so light does not escape above the horizontal - Unshielded bulkhead lights, no matter how low their luminosity, should never be installed.
Mount lighting for externally illuminated signage at the top of the sign, directed downwards only.
LED Lighting – only chose warm temperature colour tones “warm-white” (less than 2,700 kelvins)
Consider using a Passive Infra Red (PIR) motion sensor light to illuminate an area only when needed.
Angle the light downwards to illuminate to avoid light intrusion onto neighbouring property or allowing glare into the public area.
Security Lights – less than 600 lumens and maximum 150W (higher power creates more glare & dark shadows)
Do not "over" light. This is a major cause of obtrusive light and is a waste of energy.
Dim or switch off lights during times of low footfall such as 12-5am.

7.12.1 Car Parking

Table 7 Car Parking Standards

Car parks are often lit by excessively high poles and glaring white light fixtures. In some cases creating areas to appear darker than intended due to the shadows cast . We recommend using warm correlated colour temperatures of <2700 kelvin or less, and single storey pole heights with fully shielded light only.

8.7 Lighting and Illumination

We request the following good practice should be considered for all development proposals to:

Adequately light the area or object without using more light than is necessary.
Provide lighting that is adequate for safety, health and wellbeing for all users, whether motorists, services, residents, pedestrians or cyclists.
Eliminate glare and excessive lighting.
Limit the amount of shorter wavelength (blue-violet) light to the minimum Correlated Colour Temperature possible; which should be less than 2700 Kelvins.
Prevent light trespass.
Reduce sky glow to a minimum.
Flexibility in the choice of light fixtures to allow for aesthetic considerations.
Use energy efficient, adaptive lighting where possible.
Limit light emissions in ecologically sensitive and dark sky areas.
Signage should be lit in a downward direction to avoid upward direct lights.
Remove unnecessary floodlights and upward lights from publicly owned buildings.
Discourage the use of floodlights or upward lighting on bridges and heritage monuments.
Implement curfews on lighting sports pitches and sports grounds when not in use.
Refuse upward beacon lighting

We also urge Mayo County Council not to permit lighting installations that promote light pollution (such as the Galway/Connemara Savage Beauty Installations). This not only detracts from the work done on preserving our night skies but it sets a precedent that artificial light should encroach on natural settings, when the opposite is the case.

13.5 Architectural Assessment

Section under “Façade”

We refer to the following section:

All external lighting of buildings, trees and other feature illumination should be designed such that it does not contribute to general lighting, result in light pollution and negatively impact on the general rural character of the ACA.

In line with Mayo County Council’s own policy on biodiversity and encouraging green spaces. Directing external lighting to trees causes early or double budding. Trees should never be lit by artificial lighting as it disrupts natural budburst (ffrench-Constant et al, 2016). Please see our recommendations for Heritage Lighting of heritage features:

Avoid floodlighting, spot lighting or “symbolic” beacon lights. Allow the possibility of natural starry light to form the background canvass of architecture. Light should be designed as part of an architectural feature and used creatively.
The light source (eg fixture bulb) should not be visible if light is installed correctly to enhance the features of a building.
Avoid potential inconveniences to other users of the surrounding area (intrusive light, glare).
Consideration for Wildlife (eg. Migratory birds, bats, moths, nesting birds and other species impacted by artificial lighting).
Ornamental lighting position, aiming and optics.
Lighting levels according to recommendations and the colour of the object to be lit.
Energy saving, timers and installation switch-off.
Light fixtures installed near rivers (e.g. bridges) and waterways will need special attention to take account of water reflection and the impact of light on aquatic life.

Main opinion:

Observations and submission on reducing light pollution in Public Open Spaces, Shop Fronts, Car Parks, Light & Illumination, Reducing light pollution on Heritage and Architectural features.

Main requests:

To adopt good practice points listed for development proposals to reduce light pollution.

Measures to limit light pollution in our towns, retail shop fronts and from built heritage structures.

Not to permit installations of artificial light 'beacons' or artistic works where light is shining directly into the sky or or natural objects/environments.

Main reasons:

To reduce light emissions, energy and meet with Mayo CC's own Strategy.

Attachments:

MAYO DARK SKIES additional information submission.docx

384.73 KB

Light Pollution and the protection of Dark Skies

Cover Letter

Observations

Information

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