20220808Avista Comments.pdf

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Avista Corp.
l4l I East Mission P.O. Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
August 8,2022
JanNoriyuki, Secretary
Idaho Public Utilities Commission
ll33l W. ChindenBlvd. Bldg.8, Ste.20l-A
Boise,Idaho 83714
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RE: Case No. GNR-E-22-02 - Soft Lights Foundation Petition for the Regulation of Light
Emitting Diode (tED) Streetlights
DearMs. Noriyuki:
Avista Corporation dba Avista Utilities (Avista or the Company) provides the following comments
in Case No. GNR-E-22-04 regarding Soft Lights Foundation Petition for the Regulation of LED
Streetlights ("Soft Lights Petition").
The Soft Lights Petition raises a number of issues that are simply not relevant to the Commission
or to the utilities under its regulation. These issues include:
1. FDA Regulation ofLED's -the Soft Lights Petitionprovides a loose history of sorts related
to the regulation or lack thereof of LEDs. In short, the Commission and Avista are not
regulated by the FDA. r It is a faulty premise at best that "any utility that sells, installs, or
operates LED streetlights is doing so without FDA approval".2
2. The Soft Lights Petition describes aspects LEDs generally, including, "Health, Safety and
Comfort", and "Eye Health, Safety, and Comfort". Neither the Commission nor Avista
have expertise in these areas, so we cannot comment on the validity of what is stated. As
such, the validity of such issues Soft Lights notes should be taken up with the FDA. It is
that venue that these issues should be reviewed and studied (assuming that there already
isn't sufficient evidence negating the claims of Soft Lights). If there is a harm that needs
to be addressed in the short-term, the remedy for Soft Lights would be to seek a stay from
the FDA related to the sale of such lights by vendors. The Commission is not empowered
to do so, having no jurisdiction over street lighting vendors.
I The FDA is responsible for protecting public health by regulating human drugs and biological products, animal
drugs, medical devices, tobacco products, food (including animal food), cosmetics, and electronic products that emit
radiation. https://www.fda.eov/consumerJconsumer-updates/it-reallv-fda-
approved#:-:texFThe%20FDA%20is%2Oresponsible%20for.electronic%20products%20that%20emit%20radiation
2 Soft Lights Petition, p.2,ll.19-20.
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3. There is infonnation provided by the Federal Government that counters many of the claims
of Soft Lights. The Office of Energy Efficiency and Renewable Energy under the U.S.
Department of Energy posted "5 Common Myths about LED Street Lighting" on June 6,
2017 .3 Below are the 5 common myths and selected portions of the response provided (the
full version can be found at the link in the footnote)
Myth: LED streetlights are more harrrful to humans and animals than other kinds of
streetlights.
LED streetlights are no more harmful to humans and animals than other kinds of
streetlights. The concem is not the type of light source, but the amount of emitted light
that falls in the short-wavelength, often referred to as the "blue" part of the spectnrm.
And, unlike other types of streetlights, LED streetlights actually offer the potential to
control the amount of short-wavelength light that they emit...
Myth: All short-wavelength light is harmful to humans and animals.
On the contrary, short-wavelength light is a fundamental component of the natural
world. It's present in sunlight and has been shown to play an important role in a number
ofphysiological processes, such as affecting circadian rhythm (our 24-hour "biological
clock" that controls sleep/wake cycles).
Myth: LED lighting emits more short-wavelength light than do other lighting
technologies.
... LEDs can be designed to emit as little, or as much, short-wavelength light as desired,
without excessive drop-off in efficiency or other aspects of performance. LEDs also
offer much greater control over where the light falls. This means they can often meet
the same illumination requirements as conventional streetlights while emitting much
less light - thus reducing even further any short-wavelength content.
Myth: Street lighting should never emit any short-wavelength light.
Most street lighting situations benefit from having at least some amount of short-
wavelength content. Short wavelengths are a key component of the visible light
spectrum, with benefits ranging from aesthetics to safety. White light sources that
contain short wavelengths, for example, can show the colors of objects more naturally,
aid in identification ofpeople and objects, improve the contrast between an object and
its background, and enhance peripheral vision at the low levels of illuminance that
typically characterize street lighting.
Myth Communities are better offwith conventional street lighting.
3 https://www.energy.gov/eere/articles/5-common-myths-about-led-streerlighting
2lP age
For the last several decades, most street lighting in the United States has used high-
pressure sodium (HPS) technology, which emits orange-yellowish light. HPS street
lighting is being replaced by street lighting technologies that emit "white" light -
primarily LED, due to its higher efliciency and longer life. All whiteJight technologies
- including LED - emit more short-wavelength light than HPS. In addition to lasting
longer and being more efficient - which by the way provide substantial energy and cost
savings - LED street lighting also offers other potential benefits. For example, unlike
other types of street lighting, LED systems can be adjusted to provide only the level of
illumination needed at any given time, and can also offer a high degree of control over
the direction in which light is emitted. This makes it much easier to reduce glare, light
trespass (the spillover of light into areas where it's not wanted), and uplight (which
contributes to the phenomenon of "sky glow" that reduces visibility of stars in the night
skv).
There are other spurious claims included in the Soft Lights Petition that the Commission need not
address. For example, on p. 17 refening to Energy Effrciency, Soft Lights notes that replacing "a
100-watt HPS with a 50-watt HPS would be a 50%o energy savings without sacrificing safef. . .".
Such a reduction to a lower wattage bulb of the same type is not energy efficiency. Energy
efficiency "is the use of less energy to perform the same task or produce the same resulf'.4
Reducing the wattage of a bulb of the same technology, HPS in this example, will result in less
light, plain and simple - which is not energy efficiency.
It is clear from the Soft Lights Petition that issues will be taken with the comments provided here,
or in the referenced information. In the end, however, in reviewing the same Statutes noted in the
Soft Lights Petition:l. Idaho Code 61-302 - there is no proof that Avista's equipment and facilities do not promote
the safety, health, comfort or any other portion of that Code.
2. IdahoCode6l-334B-withoutanyevidencethatAvista'sequipmentandfacilitiespromote
harm, no order under this code is necessary prohibiting the use of LED lighting.
In summary, there is no need for the Commission to require Avista to wait "for FDA approval and
regulation of LED products" nor "inform consumers" about LED lights and the spurious claims
noted.s Given that the Commission is not the right venue for the adjudication of the claims set
forth, Avista believes the Commission should dismiss Soft Lights Petition.
Please direct any questions regarding these comments to me at 509-495-8620 or
P atrick. ehrb ar @av istacorp. com
Sincerely,
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Patrick Ehrbar
Director of Regulatory Affairs
a https ://www.enersv. gov/eere/enersy-effi ciency
5 Petition at 20, lines 9-13.
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