Further to escalating my complaint ref: CCC008762 yesterday, your online complaints procedure does not allow me to add to yesterday’s escalation, it will only allow me to make a new complaint.
Having conducted some Internet research, I have discovered there are many hundreds of people living in Swindon Borough, like me, complaining about the excessive light trespass caused by the new LED street lighting. Perhaps this explains why it took three months and two telephone calls to obtain a response from you. How many complaints relating to the new LED street lighting installation have been made to Swindon Borough Council since the installation programme began to date?
A Mail Online article, dated 4th September 2020, states that Swindon Borough Council cannot control the brightness because they do not have the software to dim the lights and are still waiting for the software to arrive. Why did you embark on the programme knowing you could not control the lumens output? This action shows a complete lack of regard for the safety and wellbeing of the public.
I was informed in the response to my complaint that you have dimmed the lighting on Highworth Road. On which day were the LED street lights dimmed on Highworth Road? By how many lumens did you dim the LEDs on Highworth Road? What is the lumens output now?
Source: https://www.dailymail.co.uk/news/article-8697651/Swindon-street-lights-brighter-SUN- say-residents.html
I have made a brief comparison of four questions and answers provided by neighbouring Wiltshire Council and Swindon Borough Council regarding the installation of new LED street lighting. There is a palpable difference in attitude when considering the impact it might have on people’s lives. Swindon Borough Council is far less empathetic towards its electorate.
Wiltshire Council LED Street Lighting Projects vis à vis Swindon Borough Council LED Street Lighting Upgrade Scheme
Question: Will the new lights give the same light as the existing ones? Wiltshire Council Answer: They will provide similar lighting levels, but the older sodium lights have a greater upward light proportion and much more light spread. This can cause pollution of the night sky but may have benefits in illuminating adjacent properties. It is not always possible to do an exact like for like replacement given the different types of lighting, and the intention is to provide something appropriate for the location. Swindon Borough Council Answer: All areas to be lit with new LED lights will be checked to ensure that the light levels achieved comply with the minimum standards of the minimum British Standards.
Question: Will the new LED lights still light up my driveway and doorway? Wiltshire Council Answer: Street lighting is intended to light the adopted road and pavement. The lighting of private property is the responsibility of the homeowner or tenant. Swindon Borough Council Answer: The purpose of street lighting is to ensure the Public Highway is lit to the appropriate standards. The lighting of private property is the responsibility of the homeowner or tenant.
Question: My street seems a lot brighter since the new lights have been fitted. Why is this? Wiltshire Council Answer: Many Wiltshire Council streets will have been illuminated to differing standards throughout the years. With the introduction of LED lighting a review of the lighting requirements based on location, usage and other factors will be applied. This may result in an increase in light output and light level on the street, but at a level which is appropriate and compliant with standards. Swindon Borough Council Answer: Swindon Borough Council has omitted this question / answer option.
Question: Will I be disturbed by light shining through my windows? Wiltshire Council Answer: Older street lighting tends to spread light in all directions including upwards. LED street lighting is less wasteful and directs the distribution of light down towards the road and pavement. This helps in reducing any light intrusion into homes and gardens. Where appropriate additional dimming or shielding could be applied to further minimise concerns. Swindon Borough Council Answer: (Swindon modified the question to “Will it shine in my window?”) The light produced from an LED lantern is far more directional than existing street lanterns. We can control where it falls, directing it onto footways and carriageways where it is most needed, therefore, reducing light pollution into properties.
Sources: www.wiltshire.gov.uk www.swindon.gov.uk
I have highlighted in grey where Swindon Borough Council states, “We can control where it falls, directing it onto footways and carriageways where it is most needed, therefore, reducing light pollution into properties.” So why haven’t you? Why haven’t you reduced the light pollution into people’s properties?
You have not considered Swindon residents at all as you made your decisions regarding the installation of these new light panels, aside from the potential saving of money, your sole focus seems only to be ensuring you are compliant with government regulation.
Wiltshire Council recommends that one should not look directly at any light source, natural or artificial for any length of time. Swindon Borough Council has directed an LED panel straight at my house and my neighbours’ house and in such a position that it is impossible not to do look at it from inside our homes when we look out of our front windows. You are overwhelmingly violating our private, personal space.
You have the ability to choose the height of the light, direct the light, control the light spill, and minimise glare. You have done none of these things.
Durham County Council Durham County Council, in their conversion to LED street lighting stated that category a), b), and c) roads will mainly be classified as traffic routes and shall be lit accordingly. However, they also stated that, “Glare shall be restricted to CEN Luminous Intensity Class G2/3 but Class G4 used if possible.
Please state the luminous intensity class you have used for Highworth Road and why.
Durham County Council also defined what obtrusive lighting is. 11.) Obtrusive Lighting
11.1 Obtrusive light is lighting, which falls outside the area to be illuminated, which can cause discomfort, annoyance, distraction, or reduces the ability to see. Obtrusive light is referred to as light pollution which can be divided into three main categories; a) Sky Glow Glare b) Light trespass
The obtrusive light should be restricted by: a) The control of the type of light source b) Restricting the level of light emitted at high angles between 70 and 90 degrees c) The use of full horizontal cut off (flat glass) luminaries where appropriate
11.2 Attention is drawn to the ILP Guidance Notes for the reduction of Light Pollution, which includes the recommendation that for road lighting installations, light near to and above the horizontal should be minimised. The use of full horizontal cut off luminaries at 0 degrees uplift will minimise visual intrusion within the landscape as well as upward light. In urban situations luminaries fitted with shallow bowls provide good control of light near to and above the horizontal.
11.3 Within urban locations in areas of medium district brightness glare should be rectified by the use of lanterns with a CEN luminous intensity of 2 or 3.
What is Swindon Borough Council’s definition of obtrusive lighting?
Durham County Council had a plan of action to resolve obtrusive lighting.
Please evidence where Swindon Borough Council has stated its planned strategy for rectifying obtrusive lighting.
Source: https://www.durham.gov.uk/media/3075/Street-Lighting- Specification/pdf/StreetLightingSpecification.pdf?m=636736461026070000
Surrey County Council Surrey County Council’s FAQs asks the question, “Will Light shine through my window? And answers, “No, this should not happen with LEDs…”, “LED street lighting is less wasteful and directs the distribution of light generally down towards the road pavement to minimise any light intrusion into homes and gardens.”
Source: https://www.surreycc.gov.uk/roads-and-transport/roadworks-and-maintenance/street- lights-traffic-signals-and-signs/street-lights/led-street-lighting#affect
Overwhelmingly, as I read through each council’s page on their LED street lighting installation programme, it is stated that the LED light will be directed downwards to minimise light intrusion. Councils state what they will do if the brightness is unacceptable, i.e. dimming, adjustment of the angle of the lantern, and the fitting of a diffuser or shield.
Gloucestershire County Council welcomes the views of its electorate and provides a link to a short survey. Additionally, they provide a direct email address to raise concerns.
North Yorkshire County Council invites their electorate to contact them if they experience any light intrusion following the introduction of the new LED lanterns. It goes further to state that they will strive to minimise the amount of artificial light that will fall on to a bedroom window, saying that this will in general be kept below 1 lux. Since the street light that is aimed at my bedroom window lights my bedroom up as though it was day, it is clear to me that Swindon County Council is not doing this.
Brighton & Hove City Council does the same and provides an email address specifically for street lighting.
Swindon Borough Council https://www.swindon.gov.uk/info/20136/transport_strategy/1133/led_street_lighting_upgrade_sch eme
This is the only document published by Swindon Borough Council on their LED street lighting replacement scheme.
You emphasise the money aspect of the scheme, you use a selective range of questions that all of the councils participating in LED street lighting schemes have access to, and you then expect people to sift through your Highways News newsletter to find out anything else. There is no guidance to help people who are suffering light trespass from the new LED street lighting. Nothing at all.
Swindon Borough Council’s care and consideration of its electorate in regard to its LED street lighting replacement scheme is none existent. You took three months to respond to my complaint and only because I chased the matter up only then to be given a response that did nothing to resolve the light torture I am suffering.
In summary, you have the ability to choose the height of the light, direct the light, control the light spill, and minimise glare. You have done none of these things. You say you can control where the light falls, directing it onto footways and carriageways where it is most needed, therefore reducing light pollution into properties. You say it. Put it into action. Not just for me but for everyone suffering like me.
For the avoidance of any doubt, I ask my questions under the Feedom of Information Act and look forward to both to your answers in full and to the appropriate treatment to the LED panel aimed at my house to eliminate your light trespass.
Yours sincerely, Jose-Ann Shackleton (Mrs)