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October 30, 2001
A letter has been sent to Bob Higgins, the Pacific Highway Project Manager informing him of the results of the meeting on the 15th October 2001
Tyagarah Progress Association Inc
Bob Higgins, Pacific Highway Project Manager, RTA, Grafton
30th October 2001
Dear Mr Higgins
I am writing to you on behalf of the Tyagarah Progress Association, who recently called a public meeting about the lighting issue attended by three of your staff.
The Progress Association wishes to register our concern at the Pacific Highway "Tandys Lane Upgrade".
Our first concern is the lack of consultation with the local community, despite the appearance of a consultative procedure, it appears to have been driven by a need to get the proper stamps of approval rather from any consideration of the needs and wishes of the local community.
The RTA produced several inches of documents relating to this upgrade, but neglected to mention anything about the lighting impact, the community only discovered this omission recently at which time it is informed that it is too late to delay the construction. When we request a meeting, it is attended by three well-intentioned staff members who know nothing at all about the lighting, and haven't even read the Environmental report, and can only tell us that they have to build it as it is designed. This is not a community consultation process.
In the documents we have finally received from the RTA - after almost a month of asking - we are informed that all junctions over a 1000 vehicles by day have to be lit in accordance with AS1158. We believe this number is nowhere near enough vehicles to justify the serious environmental impact of 30 lights on a rural intersection. We suspect that the same standards are being applied to rural interchanges as they are to major cities. It is clear from our conversations that the RTA has never considered that lighting might be considered to be a negative as well as a positive. That the possibility of marginal changes in safety considerations need to be balanced against the substantial environmental impact caused by over-large road developments.
We are concerned about a number of specific impacts.
There are a number of residences in the immediate area of the interchange, and a substantial proportion of the lighting will be on the level of the overpass, so that even if properly cowled lights are used, a significant amount of stray light will be projected down towards houses.
Adverse effects on occupant's range from sleep disturbance and sleep loss to discomfort glare and disability glare. Apart from the quality of life issues, the quality of sleep has a powerful effect on health, for example: "The quality of sleep has a powerful effect on health.....and artificial light at night often produces a carbohydrate craving.....,leading to obesity and consequent related diseases. Melatonin production by the pineal gland in rats during sleep at night is reduced by the presence of artificial light (eg Shah, Mhatre and Kothari 1984). Melatonin is also known to suppress tumours and to influence estrogen levels. Rates of breast cancer in women fall with increasing degrees of blindness. Breast cancer rates are about five times greater in developed countries than in third world countries. These facts together have strengthened the hypothesis that artificial light at night, including dim light in bedrooms, is a risk factor for mammalian breast cancer (eg summaries in Science Service (1998) and The Independent (1999))." 
Effects on wildlife.
There are significant numbers of nocturnal species in the area, some threatened, including koalas, bandicoots, flying foxes and tawny frogmouth.
It is known that light pollution can adversely affect animals and plants eg. migratory birds navigate erroneously and the activities of nocturnal land mammals are disturbed. Birds are disoriented and dazzled and animal sleeping times are curtailed. 
Outdoor lighting has reduced moth numbers favouring pest species such as flies and cockroaches. 
The question of safety is of course a concern, but we find little evidence that lighting to this intensity improves safety, even a cursory look at the Ewingsdale interchange - which we are informed is lit to the same standard - shows that a fraction of the lights would be sufficient. We also find reports that question this for example:
"Illuminance criteria have been proven to be inadequate predictors of the effectiveness of lighting systems.....for example there have been some reports of accident rates increasing after installation of fixed lighting systems....some lighting systems actually reduce the average contrast even though they meet specifications based on illuminance."[3.]
We would appreciate any references that show that there is a significantly increased safety at this level of intensity compared to for example half or a third of this intensity of lighting.
Visual Amenity is impacted in two ways. Directly it is impacted because an interchange lit like this, in the middle of an unlit rural area, becomes the most prominent visual feature at night. No longer does the scenic lookout at Coolamon drive provide beautiful night views of Byron Bay and its lighthouse, instead it provides a view of the bright yellow Ewingsdale interchange.
Indirectly, loss of a clear, dark Night Sky due to unnecessary glare is a significant environmental impact and would adversely affect the rural character of the area. This would impact residents at a considerable distance from the interchange, as evidenced by the glare from the Ewingsdale lights.
Unnecessary waste of energy and increase in greenhouse emissions.
In consideration of greenhouse and light spill issues, the illuminance provided should equal the minimum illuminance for purpose of the lighting. Our association feels stongly that that extent of lighting planned substantially exceeds that which is necessary.
Additionally, from viewing other road lights, such as at the Brunswick Head turn off, the absence of proper cut offs to direct the light downwards means that a substantial percentage of the light is emitted above the horizontal plane of the light source and by definition performs no useful purpose. The energy wasted by light travelling above the horizontal results in greenhouse emissions which could be reduced by using full cutoff light fittings, where no light is emitted above the horizontal (Upward Waste Light Ratio or UWLR =0). As a responsible government authority, in a state which has been leading Australia on greenhouse action, the public expects RTA to take reasonable steps, such as this, to reduce greenhouse emissions. A number of states in USA now require full cut off lighting on roadways.
Thankyou for your email about lighting policy, 97M5904 BH:JC dated 30/10/01. We had asked for a copy of any printed RTA lighting policy document, which was used as a reference for RTA projects, as we were given the impression at the meeting that such a document existed within RTA. Your emailed summary, it appears that RTA does not actually have a written policy regarding lighting. Clearly you would rely on standards, but a written comprehensible public policy on lighting would greatly assist the public in understanding what to expect in regard to lighting. It would also provide a point of reference when RTA is consulting with the public.
In relation to the immediate issue of Tandys Lane lighting, we ask the RTA to :-
* Not extend lighting down the actual freeway itself. We were assured by RTA staff at the meeting that as a general policy interchange lighting is not installed on the freeway itself. Yet, at the southern Brunswick Heads turnoff lighting extends south along the actual freeway for approximately 150 metres.
* Maximize the strategic planting of high foliage density trees which over time can significantly reduce visual impact on local residents
* To review the lighting plan for Wreckers Corner with a view to ensuring that the lighting does not exceed the minimum to meet the illuminance requirements.
* Consult with the Progress Association with regard to the changes being made.
In conclusion we strongly urge the RTA integrate lighting issues into its policy and consultation processes, particularly to
* Ensure lighting is always included in an EIS.
* Carry out genuine community consultation with regard to lighting
* Through consultation, develop a lighting policy which is made public, which may include :-
o a commitment to making a genuine attempt to reduce light pollution while addressing safety issues using best available technology
o Review its policy as it applies to rural interchanges
o Consider and minimize impact on previously rural environments
o Consider alternatives such as reflectorized road markers where suitable
o Maximizing the strategic planting of high foliage density trees which over time can significantly reduce visual impact on local residents
On behalf of the Tyagarah Progress Association
Enclosed are a few letters from other local residents
(1) B.A.J. Clark BSc. MAppSc. PhD. DipMechEng.
Outdoor Lighting Principles for Australia in the 21st Century
(2) Simon, D. J. and Babcock, S. R. (1999) Vanishing Night Skies: The Effects of Light Pollution on the National Park System. Washington DC, USA: National Parks and Conservation Association, March. (Available via a CNN report at <http://www.cnn.com/NATURE/9903/29/light.pollution.enn/>
(3) U.S. Department of TransportationHighway. Highway Lighting and Driver Performance
Posted at October 30, 2001 12:00 AM
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