Call to Action: PURA Public Testimony

Call to Action: Public Testimony Needed in PURA / Eversource Rate Case to Maximize Energy Efficiency and Advocate for a “Dimmable” Streetlight Tariff.

You can help maximize energy efficiency, minimize light pollution, and help make the case for dimmable streetlights in the state of Connecticut by submitting testimony to PURA in the current Eversource rate increase Docket No. 17-10-46. There will be several more public hearings (see below), and the public comment period is open until the middle of February, 2018. To read more about the Eversource Rate request, see articles here, and here.

Connecticut IDA member Leo Smith has been granted intervenor status in the case, and is requesting that Eversource provide documentation about the LED streetlight and other floodlight fixtures it has been installing over the last few years. At issue is whether Eversource has been in compliance with CT statute 13a-110a (Street Lighting) Sub-section (e):

No public utility company may install or replace a permanent outdoor luminaire for roadway lighting, if the cost of operating such luminaire is paid for by municipal funds, unless:
(1) the luminaire is designed to maximize energy conservation and to minimize light pollution, glare and light trespass,
(2) the luminaire’s illuminance is equal to the minimum illuminance adequate for the intended purpose of the lighting,

Our goal is to hold Eversource accountable to this standard in all respects: energy conservation, light pollution, glare, and light trespass. If it is found that Eversource has not acted properly to seek the *most* energy efficient fixtures available at the date of installation, we will request that replacement fixtures, shielding, or other remedies should be installed at Eversource (not ratepayer) expense. We also believe that to take full advantage of the late-night dimming capacity of LED streetlights, Eversource should establish a special tariff for dimmable streetlights.

How to make your voice heard:

Reference Docket number: No. 17-10-46 “Application of The Connecticut
Light and Power Company d/b/a Eversource Energy to Amend its Rate Schedules.”
All correspondence *must* reference this docket number
in the subject line and/or title.

Email should be addressed to:  PURA.executivesecretary@ct.gov

Physical letters, and word doc/pdf testimony should be addressed as follows: Jeffrey R. Gaudiosi, Esq., Executive Secretary, Public Utilities Regulatory Authority, 10 Franklin Square, New Britain, CT 06051

or submitted through the electronic filing system at PURA: http://www.ct.gov/pura/cwp/view.asp?a=3364&q=404110&puraNav_GID=1702

Public comment hearings will be held on the following schedule:
HR-1 New Britain/PURA 1/24/2018  6pm
Stamford Gov’t Center  1/30/2018   6pm
Branford Fire Dept. (45 N. Main)  1/31/2018   6pm
Council Chambers New London  2/06/2018   6pm

Maximize Energy Conservation, Minimize Light Pollution:
Reduce LED Fixture Wattage

In the current Eversource rate tariff (Rate 116), the lowest LED streetlight fixture wattage is listed as 28w (2500 lumen). This is appears to be a replacement for 50w (4000 lumen) HPS fixtures. And yet, other towns here in Connecticut (and around the country) have chosen to install replacement streetlights at dramatically lower “fixture wattage.” West Hartford selected the 14w (1900 lumen) GE Evolve fixture for its LED streetlight upgrade. Not only does the GE fixture conserve energy, it is actually cheaper than other similar fixtures.  There is an emerging consensus that because LED light is more “directional” that legacy light sources (HPS, metal halide, etc.) lumen outputs can be reduced by 50% at minimum, and up to 66% depending on the “lumen efficacy” of a given fixture. (For a discussion of this topic, see the MSSLC newsletter for July 2016.)

One of the great advantages of LED lighting is that you get a lot more light for a lot less energy input. When we’re thinking about light pollution, and the effect of night-time light on humans, animals, plants and insects, one of the great *disadvantages* of LED lighting is that you get a lot more light for less energy input. We can see “Jevon’s Pardox” at work in LED Streetlights when we observe that because the energy cost is relatively less, there is a tendency to deliver *more* light than is necessary for a given task. There is growing scientific concern about dramatically increasing light pollution around the world.

Public responses:

• If you care about energy conservation in the state of Connecticut, please write to request that *all* LED retrofit streetlights meet the standard to maximize energy efficiency.
• If you already have Eversource-installed LED streetlights and feel that they are too bright (or brighter than the old HPS fixtures), please write to request fixtures that meet the requirement to meet the minimum illuminance adequate for the intended purpose of the lighting.
• If you are concerned about the “arms race” in lighting levels, please write to request that all roadway lighting should meet the standard for minimum illuminance adequate for the intended purpose of the lighting.

Glare & Light Trespass—Making Roadway
Lighting Safe for Drivers

The “directionality” of LED output means that LED streetlights provide a distributed, even light on the ground. However, because the source of light is so focused at the point of output, even a momentary glance up at one of those lights can be utterly blinding. This effect is known as “high-angle glare.” While annoying to pedestrians, this effect can be dangerous for drivers. The American Medical Association report on LED streetlights has an extensive discussion of this problem.

Many (if not most) LED fixture manufacturers have snap-on shields that designed specifically to prevent light “trespass” (onto property and buildings) and to reduce high-angle glare. These shields can actually make the light produced by streetlights more effective because shielding the bright source of the light makes it easier to see the light on the ground. This shielding is typically only installed if a particular homeowner or customer complains about light trespass onto their property. As a matter of public safety for drivers, we believe that high-angle glare shielding, and light trespass shielding should be installed on *all* LED streetlights at the time of installation.

Public responses:

• If you’ve ever been temporarily blinded by LED streetlights while driving, walking or cycling please write to describe how it affects you and your ability to drive safely in different weather conditions,
• If you would rather have the light from streetlights shine on the ground rather than into the eyes of drivers, please request that high-angle glare shielding should be required for all LED roadway lighting.

“Future Technology” Here Today — Establish a “Dimmable” LED Rate Tariff
So Municipalities can Maximize Energy Conservation

Cambridge, MA installed a state-of-the art programmable LED streetlight system in 2012. At the time, the technology was new and pretty expensive. Many years later, and 7-pin photocell receptors are standard issue on most LED streetlight luminaires, unlocking the ability for municipalities to dim roadway lighting for late-night hours when pedestrian traffic is finished for the night and auto traffic is very low. Programmable options could mean that lights are dimmed to 30% at 11pm or midnight, but return to full strength at 6am for the morning commute. That kind of flexibility protects public safety but also results in *significant* energy savings. In the six years since Cambridge installed their programmable lights, not a single complaint has been received by the city that not enough light was available at night.

Eversource offers financial incentives for towns to purchase streetlight controllers, but those same municipalities don’t receive any long-term financial benefit from reducing its electricity use because there is no “dimmable streetlight” tariff! Particularly in light of the absorption of energy efficiency funds into the CT general fund, it is incumbent on PURA to provide the regulatory framework to allow municipalities to reap the financial reward for energy efficiency gains achieved through dimmable streetlight controllers.

Public responses:

• If you are concerned about maximizing energy efficiency in the realm of streetlights and roadway lighting, a Dimmable LED rate tariff is the single most effective way to share the benefits of reducing energy use during late night hours with ratepayers and taxpayers. Please request that PURA require Eversource to develop a Dimmable LED rate tariff that will incentivize towns to adopt dimming controls.
• If you care about the effect that light-at-night is having on animals, insects, plants, and trees, late-night dimming is the second most effective way to ameliorate the effects of blue-rich light on our ecosystems after removing unnecessary lights entirely. Please urge PURA to create a regulatory framework that will incentivize towns to provide roadway lighting where and when it is needed, and to reduce energy use when there is no public safety need to provide 100% lighting.