American Medical Association
https://www.ama-assn.org/sites/default/files/media-browser/public/about-ama/councils/Council%20Reports/council-on-science-public-health/a16-csaph2.pdf

· Report indicates blue point sources lead to discomfort and disability glare.  

· The core concern is disruption of circadian rhythmicity. 

· AMA does recognize the favorable aspects of LEDs (i.e. maintenance, energy efficiency, ability to dim lights)

· 3000 Kelvin is the recommended light temperature, meaning the AMA report would have concerns with Flat Screen TV’s 7000 - 9000 Kelvin, Computer Monitors 6500 – 8500 Kelvin, Smart Phones 6300 – 8300 Kelvin and 4000 Kelvin LED Streetlights. Distance from source is a key factor to exposure.

Department of Energy
https://energy.gov/sites/prod/files/2016/06/f32/postings_06-21-16.pdf

· Report indicates, there’s nothing inherently different about the blue light emitted by LEDs; that are, same power and wavelength, same electromagnetic energy, regardless of source type.

· The potential for undesirable effects from exposure to light at night emerges from evolving research, the implications apply to all light sources —including, but by no means limited to, televisions, phones, computer displays, other such devices and LED’s.

· It’s important to direct the light only where it’s needed; to make sure the emitted spectrum supports visibility, safety, and the health of humans and other living creatures.

· The “blue” spectrum of visible light covers a range of wavelengths, from blue-violet to blue-green. If one compares the blue content of an LED source with that of any other source, with both sources at the same CCT, the LED source emits about the same amount of blue.

· At extremely low CCTs, such as the 2200K of high-pressure sodium, the light no longer appears white, and colors can be substantially distorted, reducing visibility. Low CCTs may be beneficial for reducing nonvisual impacts, but they may also reduce the effectiveness of the lighting, which may completely negate the effects of reducing the relative amount of blue light emission.

Illuminating Engineering Society
https://www.ies.org/policy/position-statements/ies-board-position-on-ama-csaph-report-2-a-16-human-and-environmental-effects-of-light-emitting-diode-led-community-lighting/

· While the principal motivators for the AMA report are understandable, the CSAPH 2-A-16 report filed as background for these statements does not provide sufficient evidence to substantiate these statements, and a more comprehensive analysis of the public health impacts of outdoor and roadway lighting should be considered prior to adopting policies that could have a negative effect on the safety of drivers and pedestrians.

· The IES also disagrees with 2016 AMA on the basis that Correlated Color Temperature (CCT) is inadequate for the purpose of evaluating possible health outcomes; and that the recommendations target only one component of light exposure (spectral composition) of what are well known and established multi-variable inputs to light dosing that affect sleep disruption, including the quantity of light at the retina of the eye and the duration of exposure to that light. A more widely accepted input to the circadian system associated with higher risk for sleep disruption and associated health concerns is increased melanopic content, which is significantly different than CCT. LED light sources can vary widely in their melanopic content for any given CCT; 3000 K LED light sources could have higher relative melanopic content than 2800 K incandescent lighting or 4000 K LED light sources, for example. Common household incandescent lighting could therefore have significantly higher melanopic dosing than 3000 K outdoor or roadway lighting at night due to relatively higher melanopic content, higher light levels and longer durations of exposure. For all the listed reasons, the upper CCT limit of 3000 K contained in AMA Policy H-135.927 lacks scientific foundation and does not assure the public of any certainty of health benefit or risk avoidance.

· The Illuminating Engineering Society is the American National Standards Institute (ANSI) Standards Development Organization for illuminating engineering. Our standards development process is based on the consensus of technical committees that serve the lighting profession and general public, and are not bound by AMA policy.

National Electrical Manufacturers Association
https://www.nema.org/news/Pages/NEMA-Comments-on-American-Medical-Association-Community-Guidance-Advocating-and-Support-for-Light-Pollution-Control-Efforts.aspx

· NEMA and its lighting manufacturer Members support the proper application of light at the right placement, right time and in the right amount.  NEMA Member products are readily available for a wide array of solutions.

· 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.

· 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.

Seattle LED Adaptive Lighting Study – Clanton & Associates / Virginia Tech Transportation Institute
https://neea.org/docs/default-source/reports/seattle-led-adaptive-lighting-study.pdf?sfvrsn=4

· The study was designed to test the idea that a lower quantity of better-quality light provides equal or better detection distance. This would create an opportunity for savings from luminaire lumen reductions and from dimming.  Although the focus of the study was adaptive lighting, the detection distance trials with different light types and Kelvin temperatures was compelling.

· A test 4100K LED light consuming 105 watts significantly outperformed all other fixtures in the study including 3500K LED, 5000K LED (both consuming same wattage as the 4100K), 250-watt HPS, and 400-watt HPS.  Additionally, the 4100K LED at 25% output performed roughly on par with the 3500K in terms of detection distance, although the study notes that around 100 feet the vehicle headlamps begin to play a significant role in the target detection.

· Indicating 4100 Kelvin LED light is the safest temperature for traffic drivers in detecting roadway objects such as pedestrians crossing streets. Safer for pedestrian and safer for driver.

Does architectural lighting contribute to breast cancer? – Journal of Carcinogenesis (2006)
http://www.carcinogenesis.com/article.asp?issn=1477-3163;year=2006;volume=5;issue=1;spage=20;epage=20;aulast=Figueiro

The paper makes mention of street lighting as follows:

“It is also worth mentioning concerns expressed about the possible impact of light from the street or from adjacent properties entering the bedroom at night after lights in a residence have been turned off. These light levels rarely exceed 10 lux at the cornea outdoors [Table 1]. Indoors, behind closed curtains, the levels would be likely to be much lower. Further, the human eyelids transmit only about 1% to 3% in the short wavelength region of the visible spectrum [61], so 1000 to 3000 lux at the closed eyelid would be needed for one hour to reach the threshold for melatonin suppression in humans. In fact, Jean-Louis and colleagues [62] showed that a one-hour exposure of 1700 lux of white light at the eyelids (delivered via a light mask) did not suppress nocturnal melatonin in humans… Arguments for using black-out shades to limit light in the home at night because of its possible link to cancer risk have no quantitative foundation for melatonin suppression within the context of people living normal lives and working day-shifts. Of course, light trespass in our bedrooms should be avoided, but for the right reasons: light trespass is annoying and wasteful.”

· In summary, light level exposure from outside a residence and a distance from residence is not capable of attaining a lux level to cause melatonin.

· Westar Energy engineers designated 4,000 Kelvin to mimic white moonlight.  For reference:

o Moonlight = 4,000 Kelvin

o Fluorescent lights = 5,000 Kelvin

o Sunlight = 6,500 Kelvin

o TV's, computer monitors, cell phone screens = 6,300 – 9,000 Kelvin

· From the studies we have seen, 3,000K does not allow true color rendering and would not be as effective for traffic safety of driver or pedestrian.

· Westar researched the best light level that allows people to see true, clear colors.  This helps identify colors of cars, clothing, etc. which has helped lower crime in other areas.

· We take what the AMA listed about proper lighting fixture design to heart, while also weighing in reports and studies from nationally recognized organizations.

· Light spill is much less than the predecessor fixtures to LED, including HPS that the AMA specifically cites as being 5 times less circadian impact.  This may be true for the same quantity of light, but we would be inclined there should be much less light with LEDs versus our HPS fixtures outside of the area they are designed to light. 

· Still, we would be happy to review on a case-by-case basis any customer complaints about the fixtures in their neighborhood.  We can usually take care of the problem with additional shielding, or reducing the power delivered to the LED chips onboard the fixture. 

· We will continue to monitor organizational standards, peer utilities, and various interest groups to continue to make the determination that every day we are serving our customers the best.