Chapter Expresses Concerns About Light Pollution

Director Jeff Marootian
D.C. Department of Transportation

Dear Director Marootian:

I am writing on behalf of the D.C. chapter of the Sierra Club regarding plans to replace all of the District’s street lights with LED fixtures. The Sierra Club has over 3,000 dues paying members in the District of Columbia with an active interest in energy use and efficiency.

The Sierra Club strongly supports the District's planned street lighting LED conversion project because energy-efficient LEDs are responsive to the Clean Energy DC Omnibus Act of 2018 and promise to reduce greenhouse-gas emissions and advance the goals of the Sustainable DC plan. We have several concerns, however, related to consumption of electricity for street lighting:

■ To capture the full benefit of LED technology and avoid wasted light, lighting levels should not exceed what is necessary for traffic and pedestrian safety. What plans does DDOT have to establish a cap on light levels in the District of Columbia?

■ The optical properties of LED lighting are very different than what DDOT has used for many decades. Will the people responsible for setting specific light levels on each street have the necessary expertise and experience with LED streetlights to avoid over-lighting? Will computer modeling be used to help establish appropriate light levels?
 
■ LED fixtures can be dimmed to reduce electricity usage. What criteria will be used to trigger dimming of streetlights? Will DDOT consider dimming streetlights in low-traffic areas during off-peak hours? Will motion-detector technology be used to further limit electricity usage?

■ Federal funding of the LED conversion project implicates the National Environmental Policy Act. Has the Federal Highway Administration determined the appropriate level of environmental review for the project?

■ Will the project’s Request for Proposals include detailed technical specifications for LED installations, including the amount of light on each street? If not, when and by whom will such specifications be determined? Will there be an opportunity for public comment on the RFP before it is submitted to the D.C. City Council for approval? When do you anticipate submitting the RFP to the council?

Thank you for considering our concerns. Members of the Sierra Club are eager to learn more about the LED conversion project and look forward to hearing from you.

Sincerely,

Catherine Plume
Chair, Sierra Club DC Chapter

cc:
Councilmember Mary Cheh
DOEE Director Tommy Wells
Kathryn Roos, Interim Director, OP3