Findings of the Ad Hoc Review Committee
Posted August 18, 2010
The comments that follow are submitted on behalf of an Ad Hoc Review Committee that has spent the past seven weeks analyzing and debating the MLO draft released on June 23rd. The Committee is a broadly based group with diverse backgrounds, and its members represent, cumulatively, decades of experience working on dark-sky legislation.
This year the MLO Task Force is requiring that comments be broken down by section and subsection. You will want to have a copy of the MLO draft at hand while reading our findings, which are presented in the same sequence as the draft.
As indicated in our introductory remarks, the Committee finds that a number of severe structural problems in MLO have not yet been corrected. Nevertheless, we have made a good faith effort to recommend improvements to other aspects of the existing draft. Among the recommendations in the detailed pages that follow are:
- An adopting municipality should chose Lighting Zones (if such must be used) based not on existing conditions as MLO suggests but rather on the type of lighting environment the municipality seeks to achieve (page 7 of our comments).
- Low-voltage landscape lighting that is exempted in Section III.B should count toward the applicable Total Site Lumen Limits (p. 8).
- Lighting levels should be reduced 75% post-curfew rather than 30% (p. 8).
- Blue-rich light should be prohibited in both the main body of MLO and in the street lighting section (pp. 10-11, 34).
- Luminaires that are not BUG-rated (of which there will be many) must be fully shielded (p. 15).
- Uplight should be prohibited in all Lighting Zones (p. 16).
- The heavy-handed sales pitch in the User’s Guide pp. 11-15 and 23-26 needs to be toned down (p. 17).
- Lumen bonuses for façade and ornamental lighting in Table E should be eliminated (p. 20).
- Complex and non-conforming uses requiring special permit should comply with “TV illuminance” limits in Table F (p. 24).
- Section XI on street lighting should not be optional (p. 33).
- Since AASHTO is still fighting fully shielded street lighting, its Design Guide should not be recommended as the basis for a Master Lighting Plan (p. 33).
- Table H maximum Uplight rating for ornamental street lighting in Zones 3 and 4 should be U2 (p. 34).
The Committee’s overriding concern, however, is that the MLO Task Force address the fundamental flaws in the present document prior to release of any further drafts or to any further public promotion of MLO.
Due to the complexity of the IDA's comment submission form, we present our findings in a downloadable file in both PDF and Microsoft Word formats.
Download the Committee Findings —» PDF version MS Word version