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Avoidance and Minimization Policies under the KSHCP (updated 5/24/10 new weblink )
KSHCP Applicants and Participants are required to implement avoidance practices to the maximum extent practicable. Avoidance measures reduce the risk of seabird light attraction due to the lights and related activities. Avoidance measures are those which cease or suspend lighting activities posing threats to the covered species.
KSHCP - Avoidance Strategies
- Turning off all outside lights from dusk through dawn during the fledgling fallout period (Sept. 15-Dec. 15).
- Permanently removing roof lights or other lights that direct light upward and horizontally.
KSHCP - Minimization Strategies
KSHCP participants are required to implement minimization measures to the maximum extent practicable to obtain an Incidental Take Permit. Minimization practices are used in conjunction with avoidance measures to decrease the risk of seabird take due to lights and associated activities. Minimization measures are those which modify lighting (that cannot be turned off or replaced) to eliminate upward lighting and reduce spill light. These measures also include the training of staff and outreach conducted to raise awareness and preparedness for seabird interactions.
The types of minimization practices applied will be dependent on the types of existing facility lighting, planned lighting, and the purpose of the lights. KSHCP staff are available to visit each facility as requested to assist with HCP lighting assessments, to discuss options, and to provide guidance and criteria related to acceptable minimization measures. In some cases, it may not be practicable to alter lights to the recommended extent due to operational requirements set forth by state or federal agencies. In these instances, the Applicant and/or Participating facility shall explain the limiting requirements in relation to the changes that are / are not being made to explain how they are implementing avoidance and minimization measures to the maximum extent practicable. If recommended or acceptable modifications to lights are not administered due to cost or some other reason, the facility manager must include as part of the application an explanation of the failure to meet the minimization standards in a report detailing their minimization practices. Applicants/Participants area required to implement minimization within a reasonable timeframe.
There are several options regarding how a facility manager can accomplish the minimization outlined in the assessment. Facility staff or maintenance can install the necessary shields or change the angle of the facility lighting. For more complicated changes, the manager may choose to hire local electricians or contractors to provide needed lighting modifications. In regards to outreach and training materials, KSHCP provides basic materials that can be modified easily for the individual facility or business of the HCP Applicant.
Various minimization strategies are listed below, but there may be others that may apply. These avoidance measures can be implemented together. KSHCP Applicants will be encouraged to implement permanent changes. However, seasonal changes would be approved with sufficient justification and verification of completion each year. All strategies will be based on outdoor lighting standards readily available through the IESNA, IDA, and NLPIP unless otherwise inappropriate to the local setting or KSHCP goals and objectives:
Install full cut-off lights, down lights. This is considered the best strategy to obtain minimization and increase light efficiency.
UPDATE May 2010Lighting manufacturers will be moving away from the cutoff rating system to the BUG system - http://www.iesna.org/PDF/Erratas/TM-15-07BUGRatingsAddendum.pdf .
This system is very restrictive with high angle glare. A rating of U0 (no uplight in Up-High and Up-Low, UH UL) and U1 (slight uplight, some post top full-cutoff looking luminaire would fit here).(source: Robert Wagner-IDA)
Shielding existing lights. Lights that are not full cut-off models should be retrofitted with shields or shrouds to enable a full cut-off lighting style. Reed et al. (1985) suggest that in areas where other light sources are rare, the shielding of principal lights would likely result in an even larger effect in decreasing light attraction.
Decrease lighting levels. Outside lighting sometimes follow Illuminating Engineering Society of North America (IESNA) including those related to setting maximum light levels for parking lots, walkways, roads, etc. Security lighting often should be set to lower light levels for maximum effectiveness in concert with closed-circuit security cameras. Bright lights produce high amounts of glare which can temporarily blind customers from seeing moving objects. Bright lights also create deep dark pockets where criminals can hide (see IDA information sheet on security lighting link below).
Angle Lights Downward. Angling and repositioning lights may present an alternative to shielding or replacing light fixtures and may be sufficient to make lights full cut-off and eliminate light shining horizontally and vertically. Light fixtures may be adjusted so that light fixtures point down to the ground as far as possible, to obtain a 90 degree angle between the light fixture and the mounting surface/pole.
Installation Motion Sensors. If a sensor light is required for security purposes, the light equipped with the sensor should be at low light levels. Light sensors should be used with full cut-off or shielded lights or as a minimum to decrease risk of unshielded floodlights pending replacement or shielding.
Alteration of light color: In some places installation of amber, blue lights may be appropriate in decreasing risk of attraction. There have been recent studies on the use of a green light however, experimental data are lacking with reference to seabirds. In 2007, NAM (Nederlandse Aardolie Maatschappij) and Philips UK jointly conducted studies in the north Sea to evaluate the effects of green color lights on oil platforms on birds migrating across the north Sea. Off the island of Vlieland along the Dutch Coast, almost all the floodlights on the NAM platform L15 were replaced with newly designed 36W TLD and 400W HPI lamps for a period of 3 nights. According to the study (Van De Lar 2007), a 50-90% reduction of impact can be achieved: fewer birds displayed circling behavior than could reasonably have been expected based on migration and weather conditions and the number birds landing on the platform was markedly smaller than under normal lighting conditions. Philips is performing an onshore pilot project using the green light to test the effects on habitat at a small harbor.
Alter Light Structure: An interim measure for globe lights may include painting the top half of the globe or light cover to make it opaque and thus decrease the amount of light being emitted from the top and sides of the fixture.
Additional components of Avoidance Strategies that do not involve changing lights are worker training and outreach. These strategies will be strongly encouraged as appropriate for all KSHCP Applicants.
Worker Seabird Awareness Training (WSAT). Applicants would benefit from training their employees in seabird awareness. The WSAT would cover the regulations pertinent to seabirds and the HCP, biological information and identification of covered seabirds, and staff responsibilities and procedures for avoiding and minimizing light attraction and responding safely to downed seabirds. The format utilized for training by KSHCP staff is often a Microsoft PowerPoint presentation module and demonstrations as needed. Annual verification of WSAT will be required to verify completion of this measure.
Outreach. Outreach materials are recommended and can provide a public relations and publicity benefit to Applicants. The outreach material may include a brochure on the problems of light attraction, how the Applicant is addressing the problem, biological information and photographs, and ways in which guests and customers can help minimize seabird fallout at the facility and respond to downed seabirds. KSHCP staff can help provide electronic files for the printing use of outreach materials.
Hosting a Save Our Shearwaters Aid Station. Some facilities may elect to host a Save Our Shearwaters Aid Station to facilitate seabird rescue, particularly if they are located in a relatively remote area or have the potential to find many birds.
NEW!
See the new BUGS rating system for light cutoff ratings: http://www.iesna.org/PDF/Erratas/TM-15-07BUGRatingsAddendum.pdf
° What is a true "Full Cutoff" outdoor lighting fixture?
° Guidence Notes for the Reduction of Obtrusive light - by the Institution of Lighting Engineers
° Security Lighting: Let’s Have Real Security, Not Just Bad Lighting
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