PURA

I’m a little embarrassed to post this, but here is the testimony I submitted to PURA on Jan. 24. There is further information here about “dimmable” streetlight tariffs that might be useful and my personal thoughts regarding high-angle glare.

January 24, 2018

Jeffrey R. Gaudiosi, Esq.
Executive Secretary
Public Utilities Regulatory Authority
10 Franklin Square
New Britain, CT 06051

Re: Docket No. 17-10-46 Public Comment from Christina Crowder regarding Eversource’s Failure to Comply with §13a-110a Street Lighting Statues

Dear Mr. Gaudiosi and members of the Commission:

My name is Christina Crowder, and I am one of the co-founders of the Connecticut Low-K LED Alliance. We are an advocacy group that has been working over the past year to promote LED streetlight retrofits that meet American Medical Association recommendations in regards to correlated color temperature, and that maximize the outstanding energy efficiency gains that are achievable through the paradigm-shifting technologies of LED lighting and advanced dimming controls.

I am here today to request that PURA enforce existing Connecticut statute in regards to outdoor lighting installed and maintained by Eversource (CL&P). CT statute §13a-110a, subsection E requires that streetlight fixtures maximize energy conservation in addition to minimizing light pollution, glare and light trespass. I would contend that Eversource has failed in its due diligence to select roadway lighting fixtures that meet the standards set out in the Connecticut statue. The result has been that while Tariff rate 117 allows for fixture wattages as low as 14 watts, the lowest LED fixture wattage actually available from Eversource for leased plant installations is 28 watts.

There are numerous examples of LED retrofit installations around the United States where 50 watt HPS fixtures have been replaced with 14-18 watt LED fixtures, cutting the initial lumen output (fixture output) by up to two thirds from the initial lumen output of 50 watt HPS fixtures. I have seen streetlights of this type in Portland, Oregon, and have spoken personally with the Public Works director there. In that example, the city’s mandate was to maximize energy efficiency while providing for public safety for drivers, cyclists and pedestrians[1]. From what I observed, and in speaking with director Koonce, the city has received no more complaints about the new LED streetlights than might be expected given the transition from HPS to LED.

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I would also like to draw the Commission’s attention to the fact that high-angle glare is a real problem with LED streetlights. It is essential for PURA to enforce the standard that all Eversource-installed LED lighting be properly shielded to eliminate high-angle glare. Driving around at night it is impossible not to be blinded by the piercing light of these streetlights. It is actually painful to the eyes to drive in and out of the light pools cast by individual street lights, where you’re alternately bedazzled by the glare of the light, and then momentarily blind as you drive through the darkness beyond. I know that many streetlight luminaires can be fitted with simple, snap-one glare shields that reduce or eliminate this high-angle glare entirely. I have seen these snap-on glare shields in action and it makes a world of difference for me as a driver. When streetlights are shielded this way, you can actually make *better* use of the light shining on the roadway—which is where you need it—because you *don’t* have the intense glare of the light source itself making everything else around it look too dim by comparison.

As a matter of public safety, it should be required that ALL existing LED streetlights be retrofitted with this kind of shielding, and that all new LED streetlights should have this shielding installed from the start. It is incredibly difficult to drive safely in adverse conditions such as rain, snow or fog when the glare from these overhead lights reflects back off of every rain drop and the wet pavement.

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Lastly, I would urge the Commission to require Eversource to offer a dimmable streetlight tariff to all of its municipal customers. It is of little use for Eversource to offer incentives to municipalities to purchase street light controllers when those same municipalities cannot realize the financial benefits of reduced energy use. Dimming streetlights during the hours when pedestrian traffic is largely finished for the night, and when traffic volumes are low is the single best way to achieve energy efficiency savings in the realm of roadway lighting while still providing the municipal benefits of public safety and security.

The California Public Utilities Commission recently required that the San Diego utility SDG&E produce a dimmable streetlight tariff by August, 2018. The CPUC finds that:

“Because dimmable streetlights support California energy policy, the CPUC should tailor the adopted dimmable streetlight rate design to maximize participation. Because the targeted customers for this dimmable option have indicated that SDG&E’s proposed rate design will limit participation, we adopt monthly fees based on wattage as CALSLA proposes, not on a fixed charge per lamp as SDG&E proposes. A wattage-based rate will enable cities with lower-wattage lamps to participate and will provide customers with higher-wattage lamps motivation to implement conservation strategies for their streetlights.”

Dimmable LED controllers aren’t a future technology, they’re a current technology. If Connecticut is to reach its energy efficiency and de-carbonization goals, it is essential that municipalities be incentivized to make use of these currently-existing technologies to maximize the energy savings that are easily achievable with these simple tools.

The statutory language is clear: utility companies are required to provide streetlight fixtures that maximize energy efficiency, while reducing glare, light trespass, and light pollution. There are simple, readily available, and financially feasible technologies available that would allow Eversource to provide roadway and outdoor lighting that meets these statutory requirements.

It is incumbent on PURA to provide the regulatory framework to allow municipalities to fully take advantage of these technologies, and to benefit from the financial savings that come along with reduced energy consumption.

Thank you for your consideration,

Christina Crowder

Co-Founder, Connecticut Low-K LED Alliance,
Co-Founder, Hamden Low-K LED Alliance.

[1] Illumination equivalents are based on the LED conversion experience of the city of Portland (2014-2016) as reflected in the Municipal Solid State Lighting Consortium Newsletter cited here (pp 3-4), and in the Gateway report prepared for the DoE in 2015. During their conversion project, real-world spot illumination measurements across target areas showed that to provide equivalent illumination on target roadways/sidewalks to the replaced HPS (High Pressure Sodium) fixtures, Initial Lumen Output (ILO) could be calculated at one third of the ILO for HPS bulbs. For example, a 50w HPS bulb has a Mean Lumen output of 3,600 (Mean Lumens equals the average maintained lumens over the life of the product). One third of this initial lumen output would be 1,200. The average maintained lumens (mean lumens) from an LED streetlight bulb is calculated at roughly 110 lumens per watt.

Thus:
50w HPS=3,600 Mean Lumen x .33=1,200. 12w LED x 110 lumen/watt=1,320 (more than the HPS).
70w HPS=5,350 Mean Lumen x .33=1,766. 17w LED x 110 lumen/watt = 1,870 (slightly more than the HPS).
100w HPS=8,550 Mean Lumen x .33=2,850. 28w LED x 110 lumen/watt=3,080 (slightly more than the HPS).