STATEMENT
June 24, 2016
NEMA Comments on American Medical Association Community Guidance:
Advocating and Support for Light Pollution Control Efforts and Glare
Reduction for Both Public Safety and Energy Savings
NEMA is a long-time proponent of good quality lighting design and application with technical standards and guidance for manufacturers and their end-use customers. The American Medical Association’s community guidance on LED outdoor lighting is aligned with lighting manufacturers’ long-standing recommendations on how to safely and efficiently design light for night, including:
- Using lighting control options such as motion or dusk-to-dawn sensors
- Shielding the light source to curtail excessive uplight, sidelight, and glare
- Designing for the minimum light levels and energy necessary for the task
NEMA and its lighting manufacturer Members support the proper application of light at the right placement, right time and in the right amount. NEMA Members actively assist installers and customers with the best application and maintenance of their products. Consequently, there are few technical reasons or limitations to stand in the way of preventing misdirected light and glare. NEMA Member products are readily available for a very wide array of solutions.
The AMA makes further recommendations regarding the spectral content of outdoor lighting installations that raise serious concerns for electrical manufacturers. NEMA agrees that spectral content should be one factor in effective lighting for outdoor installations. However, a single solution is simply not appropriate for all situations. NEMA also questions the wisdom of assigning significant weight to this recommendation since outdoor lighting design requires a complex analysis of many criteria. Outdoor lighting systems will vary depending on the application and local conditions. Tradeoffs in the considerations of visibility, environmental impacts, energy efficiency, cost, personal safety and security need to be optimized, which cannot be achieved with a single solution.
The AMA recommendation encouraging the use of 3000K correlated color temperature (CCT) or lower may compromise the ability of the lighting system to meet all critical design criteria for each unique application. As indicated by the U.S. Department of Energy (DOE) in its June 21, 2016, statement, CCT does not explicitly characterize the potential for nonvisual effects, which also depend on quantity and duration of exposure to light. DOE further clarifies than an LED light source with the same CCT as a non-LED source has about the same amount of blue spectral content. The AMA recommendation for 3000K or lower is not an appropriate solution for all applications, nor is it is supported by the current body of research. NEMA will issue additional technical guidance specific to the issues and tradeoffs related to the spectral content of lighting solutions.
NEMA welcomes the opportunity to work with AMA and other organizations on projects to further research the complexities of night lighting. We are committed to science-based improvements to night lighting so that people the world over can safely and efficiently enjoy the extension of their living space as well as the beauty of the nighttime natural world.
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The National Electrical Manufacturers Association (NEMA) represents nearly 400 electrical, medical imaging, and radiation therapy manufacturers on the forefront of electrical safety, reliability, resilience, efficiency, and energy security. Our combined industries account for more than 400,000 American jobs and more than 7,000 facilities across the United States. Domestic production exceeds $117 billion per year.