Why I object to lighting ordinance changes

By Kai Reed, Ivins resident

I am writing to express my opposition to some of what I consider detrimental changes proposed by the Planning Commission to our lighting ordinance. I watched/listened to all the discussions during the PC meetings regarding these changes and was very concerned with the competency of the process. 

My major concerns are:

  • 1. Changes outside what were asked
  • 2. Did not get expert advice to answer questions they were unsure of
  • 3 Used “safety” to justify changes without statistical support and
  • 4. Approved an ordinance they knew was defective but wanted to “punt” it to City Council.

#1: Changes outside what were asked

I am disturbed the Planning Commission made changes outside the direction given by the City Council. In the Dec. 15th PC meeting Bryan Pack stated “A year ago the City council did give the PC direction on very limited things such as message boards that need to be changed…none of which affected the night sky portion.”  Updating definitions and using the latest technology is appropriate, however, increasing the color temperature, eliminating amber filters and permitting unlimited color temperature of lights is totally uncalled for, outside what they were asked to do and will most definitely have a negative impact on our night sky.  The Commissioners acknowledged over and over again that protecting and preserving the night sky was an important component of the General Plan yet their decisions have weakened those protections. 

#2: Did not get expert advice to answer questions they were unsure of

I also found it extremely troubling that over and over again commission members asked questions about why they should increase color temperature to 4000K and no one was able to provide a satisfactory explanation. In fact it was noted many times that the commission needed an “expert” to help them understand what impact the changes would have.  In the Jan. 5th meeting it was noted we “need an expert to clean up technical language”, “(we need to) get experts to help with numbers and definitions.” At one point one of the commissioners actually said “are we just pulling numbers out of a hat?” Lance Anderson told the other members how they had arrived at the original number by actually going out at night and having a display of different lights and seeing for themselves the impacts the brighter lights had. He suggested the PC members do the same but his advice was ignored. And Dale Coulam told the Commission members there was a process in place to obtain the services of a specialist or expert but again, the Planning Commission never chose to do so.  In another meeting Dale stated “if you are not going to have staff retain an expert, then recommend to City Council the type of expert to be retained and have Staff go through requests for proposals.” Again ignored.

#3: Used “safety” to justify changes without statistical support

Another concern is the focus on “safety” over all other considerations.  It was implied that Ivins is a very dangerous place, that crime is high and we need more and brighter lights to keep everyone safe.  These arguments have been refuted many times.  Kathy Barth submitted a very detailed and comprehensive report (Shedding light on crime trends) to the PC showing that in fact, crime is very low in Ivins. Other studies were submitted that show that just increasing lights does not deter crime.  The PC members either did not read those reports and studies or chose to ignore them and continued to use “safety” as the excuse for weakening the current ordinance. 

#4: Approved an ordinance they knew was defective but wanted to “punt” it to City Council

I feel the Planning Commission knew they were approving and passing a defective ordinance.  Several times the Commission Chair said he wanted “to push this forward to City Council to put this in the realm it needs to be in to tell us yes or no.” “Punt it to them and get it where it needs to be.”  “push this to the City Council for discussion…amongst those who are more directly accountable to the citizenry.”  I feel the PC abdicated their responsibility and just wanted to get the ordinance off their agenda. Even Dale Coulam told them “Give the best recommendation  you can and if you don’t know that specific technical number, recommend the type of expert needed for that to help get them that number.” Again advice not taken.

What I do support

I do support prohibiting electronic message boards, updating definitions and lowering the lighting on state & national flags.

What I do not support

I do not support increasing the kelvin number to 4000, eliminating any upper limit on color temperatures even if they are motion activated with timers or eliminating amber filers. No sufficient reason was ever given in the PC meetings as to why these changes were necessary. I also do not support language that is unenforceable such as “Exterior lighting shall be allowed at levels necessary for safety and security purposes.”

Talking about color temperature raises everyone’s temperature

Should Ivins increase the permitted color temperature for outdoor lights from 2200K for city streetlights, city bollards, and new commercial and 2700K for new residential properties to 4000K for everything? Should Ivins treat all new commercial, new residential, and city streetlights the same or set separate color temperatures for each of these three uses: streetlights and bollards, new commercial properties, and new residential?

People opposed to colder, whiter 4000K lights express concerns about glare and harshness. People opposed to the warmer light from 2000K – 2700K lights express concerns about safety. Safety is important. But a discussion about safety should be based on standards rather than arbitrary opinions. Research by Kathy Barth shows that Ivins is not less safe than other areas.

What does color temperature look like in real life?

We used a professional spectrometer to measure the color temperature of commercial lights in Ivins so we can visualize what the numbers “look like” in real life. I won’t bore you with the dozens of readings we took from around the city.

Instead, an easy side-by-side comparison of the two extremes is Rocky Vista University and the Crimson Cliffs Student Housing next door. Rocky Vista University’s parking lot lights are 4000K LEDs but have amber filters which lowers the color temperature to approximately 2200K. The Crimson Cliffs Student Housing parking lot lights are unfiltered 4000K LEDs.

Amber filters used in Ivins City streetlights and bollards and installed at Rocky Vista University

Other commercial properties have lights near 2200K even though they were added when 4000K was allowed. And others have 4000K lights, which were allowed when they were put in and continue to be allowed, or grandfathered, regardless of changes to the Lighting Ordinance.

50 years of peace and then…

Everything was fine in Ivins for decades. Problems started appearing about four years ago.

  • 1970 – 2017: High-pressure sodium (HPS) lights were used for streetlights and parking lots. Their color temperature is approximately 1900K.
  • ­2017: Ivins started replacing HPS streetlights with 4000K LEDs. The Lighting Ordinance permitted color temperatures up to 4000K. There were a lot of complaints. Solution: The City added amber filters, reducing the color temperature to approximately 2200K.
  • 2019: Rocky Vista University had 4000K parking lot lights. Neighbors complained about the harsh white light and glare. Solution: The University approved adding filters, paid for and installed by local residents, reducing the color temperature to about 2200K. 
  • 2019: Because of the problems encountered in the prior couple of years, the City changed the Lighting Ordinance, lowering outdoor lighting color temperatures, for new construction only, to 2200K for commercial and 2700K for residential properties.

Placement versus intensity

When the filters were added at Rocky Vista University, a couple of areas were not illuminated ideally. But these same areas were a problem before adding the filters because pole placement was not ideal. Determining appropriate placement for lighting is just as important for ensuring safety, if not more so. So maybe the safety issue is really about the proper placement of lighting rather than the intensification of light.

So what’s the big deal?

Ivins is blessed to have Red Mountain block light from any source along its entire northern border. Increasing the color temperature to 4000K interferes with the beautiful dark skies we have now.  Past installations of 4000K lights resulted in an outcry to lower the harsh, glaring white light. Why repeat past mistakes?

The population of Ivins doubled since 2000 and is expected to double again in just over 20 years. What will our night sky look like with twice the light pollution we have today? Will there be nothing left to see for our children to be inspired by, marvel at, and cherish? Will the wonderment of the night sky be just a distant faded memory for those of us who were once lucky enough to gaze upon it? We can’t let that become our fate.

Shedding light on crime trends in Ivins

This is a summary of research conducted in January By Ivins resident Kathy Barth based on FBI and Utah BCI statistics, which was a recommendation by Police Captain Rogers. The data source combines Ivins and Santa Clara. St George data is presented for comparison (see note at bottom).

The Planning Commission appears to assume that more lighting and whiter lighting (higher color temperatures) reduces crime and increases safety.  Based on that assumption, St George should have lower per capita crime rates because they likely have more lighting and certainly have higher color temperature lighting than the Ivins streetlights and bollards.

That is not the case. Santa Clara/Ivins has significantly less crime, even adjusting for population. The statistics do not support the assumption that more and/or whiter lighting increases safety.

Captain Rogers ran a report of the times of calls. It groups “I’ve fallen and can’t get up” calls with “I’ve just been robbed” calls and “My home/equipment have been damaged” calls. Crime data alone wasn’t available.

The graph shows twice as many incidents during daylight compared to after dark. This also does not support the assumption that more and/or whiter lighting increases safety.

What’s the real issue?

Recent public comments expressed a desire for more lighting, so Kathy drove around the city.  Some city streets appear to have fewer streetlights than others. So, the real issue may not be as simple as just more and whiter, but where.

A review of street lighting placement in the city would determine if there are areas where more streetlights and/or bollards may be appropriate and desired by the residents in those locations.

Notes: Additional information available: Data by type of crime; Incidents by hour and by day of week. Captain Rogers said it would take months to gather/collate that data for Ivins only.

Ivins Mayor addresses Planning Commission about its Outdoor Lighting Ordinance discussions

Mayor Hart addressed the Planning Commission last night about the Commission’s discussion about making changes to the Outdoor Lighting Ordinance. Jeffrey Burch, an Ivins resident, listened to the meeting and sent us the following summary of the Mayor’s key comments.

He noted that he was typing quickly and these are not direct quotes. But we listened to the meeting too and his summary appears accurate to us.

Editor’s note: Click here if you want to hear his complete presentation and then click on the second “A” (Discuss existing lighting ordinance). The Mayor’s comments go from approximately the 10 minute point to 23 minutes.

Planning Commissioners are appointed by the mayor, with the advice of the City Council, to perform the crucial planning function for the City Council for action that is ultimately taken and implemented.

Night sky discussions date back a very long time, before I was here.

I am reminding you the purpose of the Planning Commission is to implement the General Plan.  There are several references to the protection of the night sky in the General Plan.  It is part of the vision statement for the city.

As you go through your deliberation and you find your discussion to be in contrast to the principals of the General Plan, this is not what you have been put in place as a Planning Commissioner to do.

I would like to correct some conjecture about the Dark Sky Initiative (Ivins Night Sky Initiative). I feel that having international designation as a Dark Sky Community would be a feather in the cap for Ivins.

I asked the Rocky Vista University to work with the Dark Sky Initiative to filter the 4,000K lights that were obnoxious to look at from below the university, which most of the city is.

They came up with the amber filters to simulate the pleasant illumination of the high-pressure sodium lights that are no longer available for replacement.

High pressure sodium lamps were the global standard of safe lighting for decades.

Bob, I have heard you reference individual property owners about lighting their property as they want, but I would remind you that a city that has a clear vision of itself can establish its own standards.  This is supported all the way up to the Utah Supreme Court.

This discussion at Planning Commission meetings has gone awry and away from the principles of the General Plan.

The City Council CAN revise the General Plan as it is a living document, but it is NOT the role of the Planning Commission to revise the General Plan or any of its principles.

Where’s the research?

The following comments were sent to the Ivins Planning Commission by Jennifer Burch, an Ivins resident, addressing her concerns about proposed changes to the city’s Outdoor Lighting Ordinance.

I object to any changes to the Ivins lighting ordinance until there are facts that warrant a discussion, and tests are completed and studied to prove community impact and confirm alignment with the Ivins General Plan. 

The response received in support of changing the lighting ordinance contains anecdotal information, creating a problem that does not exist.

If public safely, due to our current lighting ordinance in Ivins were a true concern, the police would be involved in the discussion.  There is no correlation between safety in our town and our current lighting ordinance until the Ivins police say that there is.

Local tests have been done, including the lighting tests at the college that has been in place for more than a year.  What are the results of these tests? 

If the lighting ordinance needs to be updated to include new technology, tests need to be done to ensure that any changes do not conflict with the Ivins General Plan.

I do not know what Planning Commissioner Bob Morris’ motivations are.  However, if he were truly concerned about community safety and updating the plan to reference new technologies, he would have gained the support of the police, recommended tests, and be referencing specific data to support his claims. 

On a personal note, any city official stating that voices of any number of townspeople is insignificant is bullying and a misuse of the officials position. (Editor’s note: That’s what Commissioner Morris said at the last meeting about emails expressing concerns from 39 Ivins residents.)

Do not take this lightly.  You are considering that your group recommend the the approval of an ordinance that is in direct conflict with the Ivins General Plan, our city logo/signs and the uniqueness of our precious town.

Planning Commission proposes changes to Outdoor Lighting Ordinance

We have just received a copy of proposed changes to the Ivins City Regulations for Outdoor Lighting. There are some very, very concerning changes that could dramatically impact the quality of our dark skies and contribute more light pollution to our area.

We are not sure why the Planning Commission has proposed such drastic changes. We recommended the City consider making changes to the ordinance last year that would strengthen the protections for a night sky but at that time the City Council decided to leave the ordinance as is with the exception of creating a prohibition for electronic message boards.

Here are some of our immediate concerns:

  • Removed “To preserve, protect, and enhance the natural beauty of the “night sky” under 16.23.101 PURPOSE and have removed ALL references to protecting the night sky throughout the Ordinance.
  • Proposed increasing the correlated color temperature (CCT) of outdoor lamps from 3,000 to 4,000 degrees Kelvin.
  • Have substituted “required” for many provisions that would protect the night sky with disclaimers such as ” unless this will compromise safety or security”
  • Have removed most requirements for amber filters which reduce the amount of light pollution.
  • Are exempting Home Accent Lighting from all provisions. This has the potential to allow homeowners to shine lights throughout their yard with no regard to light trespass.

When our current Outdoor Lighting Ordinance was written it was more respectful and balanced than the ordinances in most, if not all other communities in Utah. But in the past couple of years many communities in Utah, the Southwest, and around the country have surpassed Ivins with new thoughtful and carefully researched changes to their outdoor lighting ordinances. With these proposed changes not only is Ivins missing the opportunity of strengthening their ordinance but are taking huge steps backwards and is losing its vision and distinct identity.

TAKE ACTION NOW

The Planning Commission will be discussing these proposed changes tomorrow, TUESDAY, December 15 at 5:30pm. Write comments TODAY and submit to: Bryan Pack, Planning Commission Chair here or Sharon Allen, Deputy City Recorder here. Attend this meeting via ZOOM.

Click here for a copy of the proposed changes. And click here for information about how to attend tomorrow’s meeting using Zoom on your computer.

January 2020 Sky Quality Survey

Tim Povlick conducted our fifth comprehensive night sky survey in Ivins on January 24th at nine locations. These surveys compare the quality of our night sky at various locations. More importantly, the surveys will track the health of the night sky over time.

Is the quality of our night sky improving or deteriorating? General population growth will likely cause it to deteriorate. But implementing better lighting practices, putting light where it is needed for us on the ground rather than spreading it skyward, can slow or even reverse that deterioration.

The 20.55 average for Ivins indicates we can see about 3,000 stars with the naked eye. If readings drop to 19, we would only be able to see about 800 stars, at most. If it drops to 18, a common reading in many cities, we would only see about 400 stars. That could happen to us.

The report above shows the averages for nine locations in Ivins. Lower numbers mean a brighter sky, and the scale is logarithmic where 1 step (eg. 19 to 20) represents a brightness difference of 2.5 times.

That means the night sky above the Southern Utah Veterans Home (site 9) is more than twice as bight as the sky above the northwest area of Kayenta (site 7).

As you would expect, there is considerable variation in the darkness of the night sky across Ivins. The differences are due only to artificial lighting and not to any circumstances beyond our control. Yes, we are impacted by our neighbors, particularly St. George and Santa Clara. But this survey shows that a lot of the brightness in our night sky is generated right here in Ivins.

A growing population in Ivins and surrounding communities will push us in that direction. And adding poorly designed outdoor lighting will get us there faster. That takes a lot of awe and wonderment out of the sky, not much of a legacy to leave for future generations. On the flip side, if we could improve outdoor lighting, we might bring back some of the darker skies we used to have. Or at least protect what we have now. Don’t we owe that to our children, grandchildren, and future generations?

What if we could improve the quality of our night sky? A reading of 21.5 means we would be able to see more than 5,000 stars with the naked eye. Look up on the next clear night and try to imagine seeing those many stars instead of what we can see now.

If you would like to get involved in this or any other projects, let us know. Send us an email from the Contact us page.

Technical notes: We made measurements using the SQM-L Sky Quality Meter by Unihedron. This is a narrow cone, sensitive low-level light meter recommended by the International Dark Sky Association. It is Model No. _2.18, Serial No. 7914. We followed approved methodology, taking three readings at each site and averaged the results.

September 2019 Sky Quality Survey

Tim Povlick conducted our fourth comprehensive night sky survey in Ivins on September 30th at nine locations. These surveys compare the quality of our night sky at various locations. More importantly, the surveys will track the health of the night sky over time.

Is the quality of our night sky improving or deteriorating? General population growth will likely cause it to deteriorate. But implementing better lighting practices, putting light where it is needed for us on the ground rather than spreading it skyward, can slow or even reverse that deterioration.

The readings shown in the table and graph below are averages from our December, March, July, and September surveys of the “quality” of the sky in units commonly accepted by the astronomical community (magnitudes per arc second). The larger the number, the darker the night sky.

The chart shows the averages for nine locations in Ivins. Lower numbers mean a brighter sky, and the scale is logarithmic where 1 step (eg. 19 to 20) represents a brightness difference of 2.5 times.

That means the night sky above the Southern Utah Veterans Home (site 9) is more than twice as bight as the sky above the northwest area of Kayenta (site 7).

As you would expect, there is considerable variation in the darkness of the night sky across Ivins. The differences are due only to artificial lighting and not to any circumstances beyond our control. Yes, we are impacted by our neighbors, particularly St. George and Santa Clara. But this survey shows that a lot of the brightness in our night sky is generated right here in Ivins.

The 20.6 average for Ivins indicates we can see about 3,000 stars with the naked eye. If readings drop to 19, we would only be able to see about 800 stars, at most. If it drops to 18, a common reading in many cities, we would only see about 400 stars. That could happen to us.

A growing population in Ivins and surrounding communities will push us in that direction. And adding poorly designed outdoor lighting will get us there faster. That takes a lot of awe and wonderment out of the sky, not much of a legacy to leave for future generations. On the flip side, if we could improve outdoor lighting, we might bring back some of the darker skies we used to have. Or at least protect what we have now. Don’t we owe that to our children, grandchildren, and future generations?

What if we could improve the quality of our night sky? A reading of 21.5 means we would be able to see more than 5,000 stars with the naked eye. Look up on the next clear night and try to imagine seeing those many stars instead of what we can see now, or the 400 we might be leaving our children with.

Fortunately, there are solutions. We discuss those in our Position Paper (see the sidebar link above). And we’re doing more than talking about solutions. We’re working on them. Look at the “Activities” menu for current projects we are working on.

If you would like to get involved in this or any other projects, let us know. Send us an email from the Contact us page.

Technical notes: We made measurements using the SQM-L Sky Quality Meter by Unihedron. This is a narrow cone, sensitive low-level light meter recommended by the International Dark Sky Association. It is Model No. _2.18, Serial No. 7914. We followed approved methodology, taking three readings at each site and averaged the results.

Here is last week’s City Council presentation

Marc Deshowitz discussed health concerns that accompany the evolution of lighting (Incandescent, HPS, LPS CFL and LED) at last Thursday’s City Council meeting. He also talked about the consequences of the use of energy efficient lighting and safety issues relating to nighttime driving and crime. 

Click here to download a PDF of the slides from Marc’s presentation. And click here to listen to Marc’s presentation (go to item 2A if you want to skip other parts of the meeting.)

Marc Deshowitz giving a presentation to the Ivins City Council about outdoor lighting issues on September 19, 2019

Marc and his wife Chrystal retired in 2008 and are currently employed by Dixie Road Scholar where they jointly lead educational excursions across the Colorado Plateau and beyond.

Marc’s interest in preserving our night sky, and background as a scientist, has led him to perform independent research on light pollution over the past ten years and he has experience in the design and implementation of light retrofitting projects in our area. He has provided presentations and advice on night sky preservation at local and state levels in both Utah and Nevada.