Public Input Item 1
Call for public inputs on a JCM proposed methodology “Installation of LED street
lighting system with wireless network control” (5 April to 19 April 2016)- Name:Dr Isaac Jamieson- Affiliated Organisation:
Biosustainable Design- E-mail:
isaac@biosustainabledesign.org- Country:
United Kingdom
1. LIGHT AT NIGHT
Night-time light levels
With light pollution prevention in mind, it is suggested that the following mattersshould be taken into consideration:
Reduced spread of light with LED units – This can reduce light pollution butcomplaints have been made about LED streetlights illuminating far narrower
areas than the conventional lamps they often replace. Safety concerns havebeen raised as a result of previously illuminated areas often now being left indarkness. Issues raised include a proposed increased likelihood of accidents
and increased fear of violence, vandalism and crime in poorly lit areas (Lux2014, 2015).

Extra streetlights may be required when LED units are installed - In someinstances the installation of extra streetlights and/or increasing thebrightness of the streetlights is being considered to help address suchpotential shortfalls (Lux 2015, Holden & Swanson 2015).

Should general night-time light levels be reduced? - Contrary to thecommon perception that reducing light levels at night usually increases crimelevels and road accidents, research from the UK reports little evidence ofharmful effects from dimming, part-night lighting, switching off, or changes
to white light/LEDs on crime levels or likelihood of road collisions (Steinbachet al. 2015).
Those authors reported that for areas of reduced lighting, no increase wasobserved for violent assault, auto theft, burglary, robbery or sexual violence.
They also observed that <1% of all night-time traffic collisions arose onstreets which had had their street lights switched off. This may not howeverbe the case in all areas of the world. It generally appears that illuminating
streets at night can, in many instances, actually increase the risks that bothpedestrians and drivers take and make premises more likely to be burgled[Also refer to the video by Vercauteren (2015)].

As can be seen, there are contradictions in research findings on the issue of lightlevels at night. In the present author’s opinion, there is a solution that may permit
the best of both worlds to be obtained. It appears that ‘Dark Sky’ policies could beadopted in many areas, particularly late at night, with a large degree of success. In
a number of these, the additional use of passive infrared motion sensors toprovide safe illuminated passage to pedestrians whilst allowing darkness at otherPage 1 of 6

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times should also be considered. [Passive Infrared speed gauges might be used toensure that vehicles do not accidentally trigger such devices. As documented later inthis commentary, traditional wireless technologies should be avoided whereverpossible].

2. COST EFFECTIVENESS
 Installation of LED street lighting system
The potential savings in energy terms that can arise through the installationof LED street lighting need to be balanced against the costs of such units
themselves and the savings that could be made by retrofitting existing units
to increase their energy efficiency instead of replacing them.
Alternatives to LEDs - An alternative option (put forward by Simon Nicholas),which can save considerable financial output, is retaining existing
conventional streetlights that are still viable and dimming them so they use
less energy (Lux 2015a).
Another alternative that is as efficient as LEDs (as commented by Burrows(2016)) is the use of HID lamps with an energy-efficient electronic ballast,such as that produced by EnLight (www.enlight.co.uk). These can be
retrofitted to existing streetlights and greatly save on potential running costs.

No Light – There are a number of incidences where street lighting may
actually make individuals less safe. Taking into account the findings ofSteinbach et al. (2015), and the comments of Vercauteren (2015), it may
prove far more cost effective, and of greater benefit to communities, toallocate some of the money that would otherwise have been spend on street
lighting to improve the safety of the roads and better educate drivers andpedestrians on how to safely use the roads at night (Refer also to theVercauteren (2015) video).
It is important to note that the residents of the town of Wellington Shire inVictoria, Australia, have rejected the rollout of LED streetlights to keep theirnight sky unlit so they can retain their night-time connection with the naturalenvironment (Waddington-Feather 2015).

3. HEALTH AND ENVIRONMENT
Wireless LED street lighting systems, health and the environment
The potential effects of such systems to health, wellbeing and the environment ingeneral need to be further considered.
There has been much written about the potential health risks from blue-rich lightfrom LEDs and the increased levels of glare such units can create. There is often poor
guidance to specifiers on this issue.

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Where possible, it appears that the specification of units with high colour
temperatures (5000K) should be avoided as they can disturb biological circadianrhythms in humans, animals and vegetation. The specification of LEDs with warmer
colour temperatures (≤2700K) is generally preferable to those with higher colour
temperatures.
Environmental risks from light at night and wireless network control
 Light Pollutiono Light spectra and wildlife - Additionally, it has been indicated that city
planners should use light spectra that are least disruptive to wildlife(Ouyang et al. 2015).
o Insects and light pollution – Research indicates that light pollution
can adversely affect the navigational abilities of migrating birds. It canalso contribute to the marked decline in avian insectivores’ foodsupply. This fact has been recognised for around 120 years: “With theexception of the finches, all the English songbirds may be said to beinsectivorous, …. As the electric light is finding its way for street
illumination … [insects] are slain by thousands at each light every
warm summer evening, battering themselves against the globes until
the ground beneath is strewn with them. The fear is expressed, thatwhen England is lighted from one end to the other with electricity thesong birds will die out from the failure of their food supply,”(Anonymous 1897).
The potential ecological and financial repercussions of street light wireless networks
on birds, insects and humans have yet to be properly addressed by industry andregulatory authorities.
Electromagnetic pollution
Radiofrequency electromagnetic fields are now recognised as a Group 2B
carcinogens (WHO/IARC 2011) and can severely affect wellbeing even at low
levels of exposure (BioInitiative Working Group 2012). There are already callsby some experts to have these upgraded to Group 2A or even Group 1
carcinogens (Hardell & Carlberg 2015, 2013, Sage & Carpenter 2014).
o Insects and electromagnetic pollution - Insects drawn to wirelesscontrolled street lights at night will experience far higher exposuresthan those already shown to induce negative effects in their species.
As an example, exposures to radiofrequencies at intensities as low as
1 µW/cm² have been shown to reduce insects’ reproductive capacities(Panagopoulos & Margaritis 2010).
Reduced insect numbers can greatly contribute to the reduction in
numbers of avian insectivores providing vital ecosystem services.
Reduction in beneficial insect species that also provide vital
ecosystem services too may be expected. In 2006, the value ofPage 3 of 6

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ecological services provided by insects in the United States alone wasestimated at $57 billion (Losey & Vaughan 2006).
o Birds and electromagnetic pollution - Birds are often likely to perch
on wireless street lights during the course of the day and may
experience adverse effects on their health as a result of such
exposures. There are a number of studies indicating adverse effects
on birds as a result of radiofrequency exposures at levels far below
those created by wireless devices on streetlights. Examples of thesecan be provided by the present author.
The sharp decrease in insect and aerial insectivore numbers in recent years has
occurred in parallel with the rapid expansion of both night-time outdoor lighting
and wireless communication.
In addition to providing avian ecosystem services, such as
consumption of carrion, predation of invertebrates and vertebrates,
plant pollination and seed dispensing, which are worth billions to theWorld economy, they also contribute billions to the growing
ecotourism industry (World Migratory Bird Day 2012).
o Effects of low intensity radiofrequency exposures on humans andanimals
Even low-level exposures to radiofrequency electromagnetic fields
have been linked to adverse health conditions in humans and testanimals. For a brief review of some of these studies please refer to:
http://www.hese-project.org/heseuk/en/niemr/power_density_effects.pdf
Please also refer to the present author’s presentation to the EESCcovering some aspects of this important issue, as related to theeffects of environmental exposures to humans:
http://www.eesc.europa.eu/resources/docs/dr-jamieson---revisedpresentation.pdf

There are far safer more cost affective alternatives to standard wireless LED street
lights that can be pursued and specified by authorities. These include the use ofstand alone intelligent lighting. Further details can be provided by the presentauthor.
References
Anonymous (1897), Electricity and English Song Birds. Los Angeles Times, September 14,1897, Page 7. http://www.lightpollution.org.uk/dwnLoads/Anonymous-1897Los%20Angeles%20Times-2.pdf
BioInitiative Working Group (2012), BioInitiative 2012: A Rationale for Biologically-based
Exposure Standards for Low-Intensity Electromagnetic Radiation.

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http://www.bioinitiative.org/report/wpcontent/uploads/pdfs/BioInitiativeReport2012.pdf
Burrows, M. (2016), Comment given about: Lux (2015), The man who's making Britain's
councils look twice at their LED streetlighting specs,
http://luxreview.com/article/2015/01/i-m-not-anti-led-but
Hardell, L. & Carlberg, M. (2015), Mobile phone and cordless phone use and the risk forglioma – Analysis of pooled case-control studies in Sweden, 1997–2003 and 2007–2009.
Pathophysiology, 22, 1-13. http://www.pathophysiologyjournal.com/article/S09284680%2814%2900064-9/pdf
Hardell, L. & Carlberg, M. (2013), Using the Hill viewpoints from 1965 for evaluating
strengths of evidence of the risk for brain tumors associated with use of mobile andcordless phones. Reviews on Environmental Health, 28(2-3), 97-106.
http://www.ncbi.nlm.nih.gov/pubmed/24192496
Holden, J.-P. & Swanson, I. (2015), Streets ‘left in dark’ by energy-efficient bulbs. Edinburgh
Evening News, http://www.edinburghnews.scotsman.com/news/streets-left-in-dark-byenergy-efficient-bulbs-1-3823419
Losey, J.E. & Vaughan, M. (2006), The Economic Value of Ecological Services Provided byInsects. BioScience, 56(4), 311-323.
Lux (2014), Protests mount against streetlight switch-offs, 'dangerous' LEDs,
http://luxreview.com/article/2014/09/protests-mount-against-streetlight-switch-offsdangerous-leds
Lux (2015), Edinburgh residents lash out against LED streetlights that 'leave them in dark',
http://luxreview.com/article/2015/07/edinburgh-residents-lash-out-against-ledstreetlights-that-leave-them-in-darkLux (2015a), The man who's making Britain's councils look twice at their LED streetlighting
specs, http://luxreview.com/article/2015/01/i-m-not-anti-led-but
Ouyang, J.Q., de Jong, M., Hau, M., Visser, M.E., van Grunsven, R.H.A. & Spoelstra, K. (2015),
Stressful colours: corticosterone concentrations in a free-living songbird vary with thespectral composition of experimental illumination, Biology Letters,
doi:10.1098/rsbl.2015.0517 (OA).
Panagopoulos, D.J. & Margaritis, L.H. (2010), The effect of exposure duration on the
biological activity of mobile telephony radiation. Mutation Research, 699(2), 17-22.
http://www.ncbi.nlm.nih.gov/pubmed/20399887
Sage, C. & Carpenter, D.O. (2014), BioInitiative Working Group Comments on 2014 SCENIHR
Preliminary Opinion on Potential Health Effects of EMF,
http://www.bioinitiative.org/potential-health-effects-emf/
Steinbach, R., Perkins, C., Tompson, L., Johnson, S., Armstrong, B., Green, J., Grundy, C.,
Wilkinson, P. & Edwards, P. (2015), The effect of reduced street lighting on road
casualties and crime in England and Wales: controlled interrupted time series analysis.
Journal of Epidemiology & Community Health, 69(11), 1118-1124.
Vercauteren, P. (2015), Street Lights - The truth revealed,
https://www.youtube.com/watch?v=ng9ddb8twAQ
Waddington-Feather, A. (2015), The town that rejected LED streetlights in favour of natural
darkness. Lux, http://luxreview.com/article/2015/06/the-hamlet-that-rejected-ledstreetlights-in-favour-of-natural-darkness
WHO/IARC (2011), IARC classifies radiofrequency electromagnetic fields as possibly
carcinogenic to humans, Press Release No. 208, World Health Organization, May 31, 2011,
http://www.iarc.fr/en/media-centre/pr/2011/pdfs/pr208_E.pdf
World Migratory Bird Day (2012), Migratory Birds in the Economy: Our Economy Depends on
Migratory Birds in Many Ways,

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http://www.worldmigratorybirdday.org/2012/index.php?option=com_content&view=artic
le&id=54&Itemid=37

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