Zoning Update - Lighting code could be better

[PonderInc]

In the proposed zoning code, we finally get a section dedicated to lighting. 

Currently, our zoning code pretty much ignores the topic.  This is one of only two references to lighting standards I could find in the current code:
Lighting used to illuminate an off-street parking area shall be so arranged as to shield and direct the light away from properties within an R District which do not contain uses for which the parking is being provided. Shielding of such light shall be designed so as to prevent the light-producing element of the light fixture from being visible to a person standing in an R District.

Perhaps that's why we have such terrible glare in Tulsa...

In any case, the new code takes a whack at lighting in Section 65.090
http://zoningcode.planittulsa.org/sites/default/files/documents/Tulsa%20Zoning%20Code%20PublicReviewDraftFebruary2015.pdf

Here's the proposed "General Standards."
All outdoor lighting must comply with the following general standards:

1. Safety
Lighting must provide sufficient and safe illumination for motorized and nonmotorized circulation on the subject lot.

2. Canopy-Mounted Lights
Canopy lighting must be by recessed fixtures with diffusers that do not extend below the canopy surface.

3. Shielding
Light sources must be concealed or shielded with cutoffs so that no more than 2.5% of the light emitted directly from the lamp or indirectly from the fixture is projected at an angle of more than 90 degrees above nadir and no more than 10% of the light emitted directly from the lamp or indirectly from the fixture is projected at an angle of more than 80 degrees above nadir.

4. Spillover Light
Illumination along the lot line of the subject property may not exceed 0.5 foot-candles when abutting an agricultural or residential zoning district and may not exceed 3.0 foot-candles when abutting any other zoning district or public right-of-way. Maximum illumination levels are measured 3 feet above grade or from the top of any screening fence or wall along the property line.

Questions/concerns:
1. Why is our first priority providing lighting for motorized circulation? Don't cars have headlights?
2. Why can't we say that the light should be designed to prevent any spillover to adjacent properties?

A note about spillover light and footcandles.
I would like to hear Patric's thoughts on this stuff, but from a quick google search, it looks like there are industry standards for illuminating different spaces for different activities.  For example, they recommend 0.9 footcandles to illuminate "high intensity pedestrian foot traffic" in a parking lot. And less than that for lower intensity traffic.  The Dark Skies association recommends 0.2 footcandles for illuminating sidewalks.

So why would Tulsa allow more than that to simply spillover to adjacent properties?  Doesn't that seem incredibly wasteful?  If we allow more than we need in the actual subject lot to "spillover" then how bright are those areas going to be?

[patric]

Its definitely a step in the right direction.
Ive been busy, so I havent been timely with sharing my markup with the group.

Has anyone else had problems getting the Comment Logs on the PlaniTulsa site to work?  The links seem to just go in circles.

[AquaMan]

"Questions/concerns:
1. Why is our first priority providing lighting for motorized circulation? Don't cars have headlights?"

I drove a commercial vehicle at 6:15 am through the heavy fog on Thursday. A few things became apparent. About a third of drivers don't turn on their headlights. They seem to be straining to see the road yet never think to turn on their headlights! Combine that with about half of drivers who also don't use their turn signals (in fear that someone may deduce their intentions I guess) and you start to understand why cars are moving towards pre-programmed, self parking, self driving features.

I also was able to judge the difference between well lighted roadways, dimly lighted roadways and stretches of highway that were unlighted due to drivers knocking out the light poles. Basically from far north Tulsa, on the Tisdale and south to I-44 off 75. Surprisingly the dimly lit stretches seemed much easier to drive.

With those two observations in mind, one wonders why we even bother to light other than dim markers along the sides of the road.

[PonderInc]

Its definitely a step in the right direction.
Ive been busy, so I havent been timely with sharing my markup with the group.

Has anyone else had problems getting the Comment Logs on the PlaniTulsa site to work?  The links seem to just go in circles.

I think they want to receive comments on the http://www.feedbacktulsa.org site. Have you tried that?

[dsjeffries]

Has anyone looked at all the properties exempt from the section on Outdoor Lighting standards??

• 1. Outdoor lighting on lots occupied by residential buildings containing fewer than 4 dwelling units;
• 2. Public street lights;
• 3. Airport runway and aviation safety lights required by the FAA (e.g., warning lights on radio, communication and navigation towers);
• 4. Lighting of official government flags;
• 5. Outdoor lighting used exclusively for public recreational activities, sporting events at stadiums and ball fields or other outdoor public spaces or venues;
• 6. Outdoor lighting used for emergency equipment and work conducted in the interest of law enforcement or for public health, safety or welfare;
• 7. Outdoor lighting used for a temporary event lasting no more than 10 days; and
• 8. Temporary holiday light displays.

Why would we NOT include single-family homes or residential buildings with fewer than 4 dwelling units? A majority of our city is composed of this one building type, and it's in the best interest of everyone in the city to have better lighting standards. From safety and visibility (think in terms of the effects of glare and unshielded lights on people walking, people driving, people riding a bike, etc - not the old "criminals don't like bright lights" myth) to economic (better lighting usually reduces utility bills) and environmental (better lighting usually means reduced energy consumption - you can more light on the ground with a lower-wattage bulb), the reasons to include residential properties in these standards are overwhelming.

Public street lights are excluded? They're some of the worst offenders in our city! Because they're exempt from any kind of standard, we taxpayers pay much more to keep these bad lights on. These are lights which send more light sideways and up than they do to the ground; they're lights that create an enormous amount of glare, which is dangerous for people walking, people driving cars, and people riding bikes, not to mention that they create a nuisance for people living nearby. These lights also contribute to (more like detract from) the aesthetics of our city. Our existing street lights, save for small pockets of good lighting in places like the Brady District and one section of Yale next to St Francis, make Tulsa look like it belongs in a developing country (our above-ground power lines and telephone poles also contribute to this shabby look).

Lighting of official government flags is excluded, as well. Our official flags should be properly illuminated, but it's not 1966 anymore -- there's more than one way to illuminate flags, and some are very good. Don't exclude flags from the requirements - make better requirements for flag illumination.

Outdoor lighting used for emergency equipment and work conducted in the interest of law enforcement or for public health, safety or welfare. This could get tricky. Does this mean police stations, fire stations and government buildings can use the worst lighting design with a claim of public health and safety? Part of what can improve public health and safety in the immediate vicinity of these buildings is better lighting. So-called "security packs" often adorn these public institutions, and these oh-so ironically named lighting fixtures actually can make an area less safe. They project light out, directly into people's eyes. Not only does this create glare (which is dangerous for all people) but it actually reduces visibility at the ground level or against the building, which is presumably the part they intended to light.

Outdoor lighting used exclusively for public recreational activities, sporting events at stadiums and ball fields or other outdoor public spaces or venues. I understand that stadiums require different kinds of lighting, but still, there are better lighting options than having absolutely no standards. There are shielded stadium lights that reduce light pollution and glare. Why not encourage better lighting instead of just saying, "well, looks like those lights are different, so we can't do anything about it because we only have one cookie cutter to use."


"Safety - Lighting must provide sufficient and safe illumination for motorized and nonmotorized circulation on the subject lot."
Why must we use "motorized and nonmotorized" when what we really mean is "people driving vehicles", "people walking", and "people riding a bike"? The term "nonmotorized" insinuates that there's something wrong, something lacking.

"Canopy-Mounted Lights - Canopy lighting must be by recessed fixtures with diffusers that do not extend below the canopy surface."
There's nothing in here that defines what exactly constitutes "the canopy surface," and I think we need that definition clearly articulated. For instance, the Sonic Drive-In on Brookside has lights mounted to the canopy. The whole fixture is beyond what I would consider the "canopy surface". But here's the catch: there is a lip at the edge of all these canopies that looks like it might extend to below or equal to the light fixture. It's still a horrible lighting situation, and light spills out of there from all angles, but I wonder if technically, this kind of thing would be allowed under a loophole in the new zoning code.

[patric]

I also was able to judge the difference between well lighted roadways, dimly lighted roadways and stretches of highway that were unlighted due to drivers knocking out the light poles. Basically from far north Tulsa, on the Tisdale and south to I-44 off 75. Surprisingly the dimly lit stretches seemed much easier to drive.

Most of those expressway outages are from thieves stealing copper and aluminum.

The absence of glare makes all the difference in the world.  Its easy to do, and cheaper to operate and maintain, but the barrier here is politics, not science.

As far as unlighted stretches of highway, most highways are unlit, yet we safely drive on them at much higher speeds than "well-lighted" city roads.
Absence of traffic conflicts play a big role (like no at-grade cross-traffic), but passive illumination (in the form of well-maintained reflective signs and markings)  makes a lot of that possible.  Conversely, imagine how insanely expensive it would be to light every mile of highway in America.

[patric]

Some recommendations I would like to propose...

Ill do the markup in sections so its easier to discuss.
strikeout for text to omit,  ALL CAPS for new language to be included.  (My comments in Red)



Section 65.090 Outdoor Lighting 131
65.090-A Applicability and Exemptions

The outdoor lighting regulations of this section apply to all outdoor lighting installed after the effective date specified in Section 1.030, except that they do not apply to any of the following:

1. EXISTING Outdoor lighting on lots occupied by residential buildings containing fewer than 4 dwelling units; (no reason for this exemption; new or replacement lights should be conforming).
2. EXISTING Public street lights; (Any new or replacement lighting should be conforming...the city should be setting the good example).
3. Airport runway and aviation safety lights required by the FAA (e.g., warning lights on towers and tall buildings); (this is covered by federal law and not within city jurisdiction)
4. Lighting of official government flags, PROVIDED NARROW SPOTLIGHTING IS CONTAINED WITHIN THE AREAS EACH FLAG OCCUPIES; (spotlighting should be used in lieu of floodlighting for better control of spill and glare)
5. Outdoor lighting used exclusively for AND DURING public recreational activities, sporting events at stadiums and ball fields or other outdoor public spaces or venues, PROVIDED THEY DO NOT CREATE A NUISANCE OR HAZARD;
6. Outdoor lighting used for emergency equipment and TEMPORARY work conducted in the interest of law enforcement or for public health, safety or welfare;
7. Outdoor lighting used for a temporary event lasting no more than 10 days; (adjust for State Fair and similar venues)
8. Temporary holiday light displays; and
9. Lighting fixtures with a light output less than 1000 Lumens. (mom and pops 60w porch light is safe, barring any complaints)




65.090-B General Standards

All outdoor lighting must comply with the following general standards:
1. Safety Lighting must provide sufficient and safe illumination for motorized and non-motorized circulation on the subject lot. (This section fails to define "sufficient and safe illumination" and may counter-productively compel the addition of lighting systems where none were legally required or needed.).

STREET LIGHTING SHALL NOT BE REQUIRED, BUT WHERE DESIRED, ILLUMINATION LEVELS SHALL CONFORM TO NATIONALLY RECOMMENDED VALUES, AS DEFINED BY THE ILLUMINATING ENGINEERING SOCIETY OF NORTH AMERICA (IESNA).
ILLUMINATED RESIDENTIAL STREETS WITH LOW PEDESTRIAN CONFLICT SHALL HAVE A MAINTAINED AVERAGE ILLUMINANCE LEVEL OF 0.3 FOOTCANDLES; ILLUMINATED MAJOR STREETS WITH HIGH PEDESTRIAN CONFLICT (EXCLUDING ENTERTAINMENT DISTRICTS) SHALL HAVE A MAINTAINED AVERAGE ILLUMINANCE LEVEL OF 1.2 FOOTCANDLES
(IES publication RP-8-00 "American National Standard Practice For Roadway Lighting" pp5-8 tables 1,2)

WHEN LIGHTING OF PUBLIC PLACES OR RIGHT-OF-WAYS IS DESIRED, IT SHALL BE BY MEANS OF STEADY WHITE LIGHT, DEFINED AS HAVING A CORRELATED COLOR TEMPERATURE BETWEEN 2700 AND 3200 DEGREES KELVIN (2700K-3200K).  NEW AND EXISTING INSTALLATIONS OF HIGH-PRESSURE SODIUM (HPS) ARE ALSO PERMITTED.
Blue-rich light sources (over 3,200K) shall not be used for street illumination, nor shall Monochromatic light sources (such as Low-Pressure Sodium).



Figure 65-1: Required Shielding


21. Canopy-Mounted Lights
Canopy lighting must be by recessed fixtures with diffusers that WHERE NEITHER THE LAMP(S), REFLECTOR, REFRACTOR, NOR FOCUSING OR DIFFUSING OPTICS  do not extend below the canopy surface.  SUCH FIXTURES ARE COMMONLY REFERRED TO AS "FULL CUTOFF" OR "FULLY SHIELDED."


32. Shielding
Light sources must be concealed or shielded with cutoffs so that no more than 2.5% of the light emitted directly from the lamp or
indirectly from the fixture is projected at an angle of more than 90 degrees above nadir and no more than 10% of the light emitted
directly from the lamp or indirectly from the fixture is projected at an angle of more than 80 degrees above nadir.

IN AREAS WHERE STREET LIGHTING IS DESIRED, ALL NEW OR REPLACEMENT LUMINAIRES (FIXTURES) WITH A LIGHT OUTPUT OVER 1000 LUMENS INTENSITY MUST BE SHIELDED IN SUCH A WAY THAT NO LIGHT EMITTED DIRECTLY FROM THE LAMP OR INDIRECTLY FROM THE FIXTURE IS PROJECTED AT AN ANGLE OF MORE THAN 90 DEGREES ABOVE NADIR AND NO MORE THAN 10% OF THE LIGHT EMITTED DIRECTLY FROM THE LAMP OR INDIRECTLY FROM THE FIXTURE IS PROJECTED AT AN ANGLE OF MORE THAN 80 DEGREES ABOVE NADIR.  SUCH FIXTURES ARE COMMONLY DESCRIBED AS 'FULL CUTOFF'


This is a variation of the IESNA Luninaire Cutoff Classification known as "Cutoff" (CO), which is less strict than "Full Cutoff" (FCO).  To qualify as Full Cutoff, zero light is allowed above 90 degrees.  (American National Standard Practice for Roadway Lighting, ANSI/IESNA RP-8-00, p.6)

Typical street lighting in Tulsa falls under the "Semi-Cutoff" (SCO) or "Non-Cutoff" (NC) categories where there is little or no intensity limits for "glare zone" or uplight, so requiring either CO or FCO luminaires would be a vast improvement over what we have now.
"Nadir" means the ground directly below the fixture.

http://www.holophane.com/led/fco-utility/gfx/cutoffs.jpg



4. Spillover Light
Illumination LIGHT TRESPASS along the lot line of the subject property may not exceed 0.5 0.25 footcandles when abutting an agricultural or residential zoning district OR RESIDENTIAL ROADWAY and may not exceed 3.0 foot-candles when abutting any other zoning district or public right-of-way. Maximum illumination levels are measured 3 feet above grade or from the top of any OPAQUE, PERMANENT screening fence or wall along the property line.


This is an adaptation of the "Kennebunkport Formula," which is a tool designed to help developers and property owners plan lighting systems that adaquately serve their needs while respecting the property rights of their neighbors.

The formula
H = 3 + (D/3)    or inversely, D = 3(H-3)   
describes the calculation necessary to light with minimal waste beyond the intended area.  

Where:
H = height of fixture,
D = distance to fixture from a property line

Example 1: Symmetrical fixture 15-ft inside a property line would be mounted at 8 ft.
Example 2: Symmetrical fixture atop a 15-ft pole should be 36 ft inside a property line.
Example 3: Symmetrical fixture atop a 30-ft pole should be 81 ft inside a property line.

The Kennebunkport Formula assumes use of symmetrical Full-Cutoff Optics (FCO) fixture with a common optical cutoff slope of 70 degrees, allowing planners and architects more realistic choices in specifying mounting height based on optical performance (rather than arbitrary pole height limitations that may hamper effective lighting design).    

The fixtures MUST be shielded for this to work.  A typical, unmodified PSO leased "security light" (NEMA) would not have the cutoff necessary.

RESIDENTIAL ROADWAY should be added because there are usually residences across them that would definitely notice the intrusion of 3 footcandles (about three side-by-side 100W sodium residential streetlights)

[PonderInc]

Hey Patric -

What do you think about incorporating the following language from the Form Based Code...

Blue-rich light sources, over 3,200K, shall not be used for street illumination. Monochromatic light sources, such as Low-Pressure Sodium shall not be used for street illumination. High-Intensity Discharge or Fluorescent, except Compact Fluorescent lamps shall not be used on the exterior of buildings.

[patric]

Hey Patric -

What do you think about incorporating the following language from the Form Based Code...

Blue-rich light sources, over 3,200K, shall not be used for street illumination. Monochromatic light sources, such as Low-Pressure Sodium shall not be used for street illumination. High-Intensity Discharge or Fluorescent, except Compact Fluorescent lamps shall not be used on the exterior of buildings.

Absolutely.  We first need to make the case that municipal street lighting needs to be a part of the new code, so the best I can do on this end is offer some workable language.  My time is spread thin now so this comes in spurts...

[patric]

A couple small details I noticed in the new draft;
aside from mandating minimum lighting (which is currently not mandated in the city ordinances), the new draft eliminates the only city ordinance that directly addresses (non-signage) light trespassing into residences from commercial properties.

The current law says

"Lighting used to illuminate an off-street parking area shall be so arranged as to shield and direct the light away from properties within an R District which do not contain uses for which the parking is being provided.
Shielding of such light shall be designed so as to prevent the light-producing element of the light fixture from being visible to a person standing in an R District."
(Title 42, Chapter 13, Section 1303C. DESIGN STANDARDS FOR OFF-STREET PARKING AREAS.)

and replaces it with a more general section on lighting that now permits certain amounts of light trespass... up to 3 footcandles, of trespass if you are unfortunate to be across a street (or a ROW) from the offender.

ONE footcandle is approximately the amount of light that falls on the street directly beneath our current residential streetlights, for example.

Given the stated purpose of the draft (and research they have done sofar), I dont believe this was their intent, so hopefully the tweaks I will propose are taken in the same spirit.

[patric]

Looking over the most recent draft
http://zoningcode.planittulsa.org/document/public-hearing-draft
they pretty much ignored most of the public recommendations on lighting, although they did add another exception for fixtures under 1,000 Lumens.

The "light trespass" (spillover) allowances are outrageous.  They dont seem to understand the 0.5 footcandles allowed into your bedroom window is roughly half the illumination you would measure standing directly under a residential Sodium streetlight.

[PonderInc]

Looking over the most recent draft
http://zoningcode.planittulsa.org/document/public-hearing-draft
they pretty much ignored most of the public recommendations on lighting, although they did add another exception for fixtures under 1,000 Lumens.

The "light trespass" (spillover) allowances are outrageous.  They dont seem to understand the 0.5 footcandles allowed into your bedroom window is roughly half the illumination you would measure standing directly under a residential Sodium streetlight.

Please submit your concerns to the TMAPC and the City Council. This will not be on anyone's radar unless you raise it.  And you probably need to raise your concerns prior to the public meetings.  You might reach out to your city councilor and help them understand the issue, and provide some technical details to back it up. If you can get a councilor to be an advocate for smart lighting regulations, it will have a chance.  They will have the final say over what's in the zoning code.

[patric]

Please submit your concerns to the TMAPC and the City Council. This will not be on anyone's radar unless you raise it.  And you probably need to raise your concerns prior to the public meetings.  You might reach out to your city councilor and help them understand the issue, and provide some technical details to back it up. If you can get a councilor to be an advocate for smart lighting regulations, it will have a chance.  They will have the final say over what's in the zoning code.

For some reason I thought  http://www.feedbacktulsa.org/portals/121/Forum_355/Issue_2362  was intended to serve that purpose... did all that public feedback simply go nowhere?

Blake is my Councilor, so I have as good if not better chance of a sincere hearing as any.

[patric]

Has anyone looked at all the properties exempt from the section on Outdoor Lighting standards??


(exempted) 1. Outdoor lighting on lots occupied by residential buildings containing fewer than 4 dwelling units;

Why would we NOT include single-family homes or residential buildings with fewer than 4 dwelling units? A majority of our city is composed of this one building type, and it's in the best interest of everyone in the city to have better lighting standards. From safety and visibility (think in terms of the effects of glare and unshielded lights on people walking, people driving, people riding a bike, etc - not the old "criminals don't like bright lights" myth) to economic (better lighting usually reduces utility bills) and environmental (better lighting usually means reduced energy consumption - you can more light on the ground with a lower-wattage bulb), the reasons to include residential properties in these standards are overwhelming.

Im going to ask the city to revisit that, and I'd like to know firsthand if anyone has any insights as to how that language came about.
Its not in any other city's lighting ordinance I have read or consulted on, so im curious as to how it ended up here.

Anyone know where that came from?  Ive got some nice pictures from bedroom windows of a neighbor who thought it would be neat to install blue-white LED floodlights at them.  Sure, there is the nuisance ordinance:

TITLE 24 - NUISANCES
CHAPTER 1. - NUISANCES CLASSIFIED
Section 100. - Nuisances defined.
A public nuisance consists of unlawfully doing an act or omitting to perform a duty, which act or omission:
   A. Annoys, injures or endangers the safety, health, comfort or repose of others;

...but it should be just as simple to have an ordinance that already defines and codifies "Light Trespass" to not exempt one of the very offenses the term almost universally describes.