The staff of the PNNL that is responsible for the DOE

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1 April 8, 2016 Dr. Reuben K. Varghese Health Director and Division Chief Public Health Division Arlington County, Virginia Dear Dr. Varghese: Thank you for presenting your conclusions on the Human Health Consequences Associated with Artificial Lighting to the Williamsburg Field Site Evaluation Work Group on March 16. It was helpful that you provided your two primary sources and the logic you used in reaching your conclusion. In expressing skepticism about the severity of health effects arising from night-time artificial lighting, I believe that you may not have had full information on the proposed lighting that we are evaluating or a full understanding of what at least one of your primary sources considered and did not consider. Below, I provide additional information about the Department of Energy (DOE) report on which you relied as well as two studies of which you may be unaware and which I believe are far more relevant to the proposed Williamsburg lights. I have now read the DOE June 2013 Fact Sheet and the 2012 AMA Report, and I have spoken with Bruce Kinzey, Director, Municipal Solid-State Street Lighting Consortium (MSSSLC) of Pacific Northwest National Laboratory (PNNL), a contractor to DOE responsible for the DOE report. I learned several things that I believe are relevant to your review and conclusions: The staff of the PNNL that is responsible for the DOE

2 document does not include any health experts on staff. The goal of the Consortium that PNNL operates is to build a repository of valuable field experience and data that will significantly accelerate the learning curve for buying and implementing high-quality, energy-efficient LED lighting. Consequently, the staff is technology experts who follow health studies in the field, but do not have medical expertise themselves. The lighting for Williamsburg field is proposed at 5700 Kelvin, a very cool color temperature that does not exist in other technologies in use (e.g., metal halide lights) and which has much more blue light than those technologies. For the prior technologies, about 4200 Kelvin is the coolest light from the earliest technologies. The advantage of such cool light from LEDs is that it is much more energy efficient. LED lights could be installed with less blue light (such as Kelvin) but doing so would significantly reduce energy savings and would increase operating costs. I note, in that regard, that the International Dark Sky Association (IDA) which serves as an independent third-party certifier of lighting fixtures that minimize adverse health effects has reduced the allowable correlated light temperature for LEDs from 4100 (neutral light) to 3000K (warm light). Both figures are, of course, far lower than the 5700K fixtures (a total of 80 fixtures) proposed for the Williamsburg fields. The DOE document statement that the proportion of blue light in the spectrum is not significantly higher for LEDs than it is for any other light source at the same correlated color temperature (CCT) is accurate but irrelevant to the Williamsburg field proposal. The DOE paper s introductory statement, The risk of blue light hazard is sometimes associated with LEDs, even though LEDs that emit white light do

3 not contain significantly more blue than any other source at the same color temperature Is similarly irrelevant. Since there is no alternative white light technology at the same color temperature (because they have less of the blue light of concern), any safety comparison between them is based on a false premise. The DOE document addresses only the optical safety of LEDs particularly retinal damage), not the health effects of sleep loss and consequent risks of cancer (particularly breast and prostate cancer and obesity) or of glare. At the start of your March 16 presentation, you elicited concerns from the Working Group and listed them on the easel, including (by memory) cancer, sleeplessness, vision effects, and obesity. I don t remember if glare was included. But the only potential effect that the DOE paper addresses is retinal or vision effects, and those only for LED lights of a lower color temperature than proposed. The second report you referenced, the AMA report, covering literature through March 2012, does consider health effects beyond the retinal risks considered in the DOE report, but it provides no basis for confidence that those risks can be ignored. It considers disability/discomfort glare and health effects from melatonin suppression and its impact on circadian rhythms: risks of breast cancer, obesity, diabetes, depression and mood disorders, and reproductive problems. The Conclusions include: Further information is required to evaluate the relative role of sleep versus the period of darkness in certain diseases or on mediators of certain chronic diseases or conditions including obesity. and a need exists for further multidisciplinary research on occupational and environmental exposure to light-at-night,

4 the risk of cancer, and effects on various chronic diseases. I do not see anything in the AMA paper that would lead to the conclusion that we know enough about the risks to conclude that they are risks worth taking or that the risks would be alleviated to a sufficient extent by the adaptability of the human body. Since there have been no studies of the direct health impact of high-intensity, cool LED lights in a close-in field setting such as Williamsburg, all of these possible concerns may ultimately be determined to be manageable in this instance, but we don t know that now. In fact, the studies summarized below and referenced in the attachment raise real concerns about those health effects. Of greatest concern to me is the effect of melatonin suppression on sleeplessness, particularly the suggestion in some research studies (see attached list of studies) that exposure to blue light can cause a delayed effect on sleeplessness, resulting in disrupted sleep hours after the exposure to the light has ended, with the consequent health risks. Though not covered by these studies on lights, any concerns about the effects of lights on sleeplessness could be exacerbated by the effects of noise from late-night games on the sleep of children and the elderly. Please be aware that the homes immediately surrounding the Williamsburg field include small children, infirm elderly residents, and at least one individual with glare disability. The closest homes are 76 feet from the soccer goal line, which would place the light poles even closer. I am attaching a list of relevant studies and articles, some of

5 which were on the prior list I provided before your presentation. Some are more recent than those available when the DOE and AMA reports you considered were available. I hope you can consider those as well in reconsidering and updating your conclusions. In particular, I would like to refer you to a report entitled Health Effects of Artificial Light, prepared by the European Commission s Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR 2012). That report was prepared by the SCENIHR because of increasing concerns raised by European member states regarding the phase-out of incandescent lamps and their replacement with more energy efficient lamps. Although the SCENIHR did not examine specifically the very high intensity LED lights associated with sports lighting, it did examine LED lights and its findings regarding lights emitting disproportionately blue light are particularly relevant here. Among numerous other findings, the SCENIHR concluded, in its discussion of lighting effects on the eye, that: there is strong evidence from animal and in vitro experiments that blue light induces photochemical retinal damage upon acute exposure and some evidence that cumulative blue light exposure below the levels causing acute effects can induce photochemical retinal damage... On the basis of the action spectrum of blue light in animal studies, blue light exposure may be considered a risk factor for long-term effects which should be investigated in case-control and cohort studies. Its conclusions regarding the effect of blue light on melatonin suppression and circadian disruption are even more alarming. THE SCENIHR repeatedly noted that blue light also

6 affects sleep structure and activates brain structures, including the hippocampus and the amygdala that are involved in cognition, memory and mood. It concluded that there is moderate evidence that monochromatic blue light or light artificially enriched in blue has an effect on cognitive function, memory, and mood that is stronger than other lights. It noted that the melatonin suppression [in one human study] was significantly greater after exposure to the 6,500 K light, suggesting that our circadian system is specially sensitive to blue light even at low light levels. Reviewing another study of humans, the SCENIHR stated that blue-enriched white light synchronized the circadian timing system, [and was] in accordance with some other studies showing that blue-enriched light is more efficient in melatonin suppression than other wavelengths. It concluded that [t]here is a moderate weight of evidence that ill-timed light-at-night measured by night shift work, possibly through melatonin suppression and circadian disruption, may increase the risk of breast cancer. There is furthermore moderate overall weight of evidence that exposure to light-at-night, possibly through circadian disruption, is associated with sleep disorders, gastrointestinal and cardiovascular disorders, and with affective disorders. It cautioned further that, due to the frequent exposure to light at inappropriate times (ill-timed exposure), there is an urgent need for further interdisciplinary research on occupational and environmental exposure to light-at-night-and risk of certain diseases. I also refer you to a white paper prepared by the International Dark-Sky Association (IDA) entitled Visibility, Environmental, and Astronomical Issues Associated with Blue-

7 Rich White Outdoor Lighting (2010) That report also cautioned about the increasing use of LED lighting in outdoor settings and warned that such lighting will increase sky glow and that there is strong evidence for additional potential negative impacts. Most important, the IDA noted, the blue portion of the spectrum is known to interfere most strongly with the human endocrine system mediated by photoperiod, leading to reduction in the production of melatonin, a hormone known to suppress breast cancer growth and development. It noted that solid-state LED lights require careful examination because of the current emphasis on blue-rich cool white LEDs in the marketplace. The IDA singled out, for special attention, the effect of LED lights on the aging eye stating: since blue-rich sources produce relatively more discomfort glare and older people are more sensitive to glare, blue-rich outdoor lighting is presumed to impact the elderly more than other groups. The IDA paper goes on to summarize the uncontroversial and strong evidence of the adverse effects of blue rich light on melatonin development. Although more research is needed, the IDA said, the evidence is strong enough to suggest a cautious approach and further research before a widespread change [to blue-rich white lighting] gets underway. In view of the additional information presented here and in the attachment, I hope you can answer the following questions: QUESTIONS: How would you characterize the degree of health risk to players, coaches, fans, and nearby residents from the effects of the 5700 K array of lights proposed to allow nighttime play on Williamsburg field?

8 On March 16, you premised your conclusion on the adaptability of the human body to minimize any risks from the possible exposures. Although it may be argued that the natural aversion of the eye to direct very bright LED lights might mitigate some adverse effects of acute on-field exposure, how could participants, visitors, and nearby home-owners fend off circadian rhythm disruption and sleep disturbances known to be associated with ill-timed exposure to high blue component light? In view of the additional information presented here and in the attached list of studies/articles, is it your opinion that any health risks faced will be sufficiently small that the bodies of those exposed will adjust to avoid the health effects of concern? If your conclusion is that there is little or no risk of adverse health effects from human exposure to lights of the intensity and color proposed at Williamsburg, how can your conclusion be reconciled with the findings of other professional groups that there is moderate overall weight of evidence or strong evidence supporting health disorders associated with lighting with a significant blue light component? On March 16, you said that there is no way to assure no risk, but that the proper way to deal with the residual risk is to inform the public of the specific nature and degree of risk and let them make informed decisions. [The example you gave was for parents deciding whether to allow their children to play on the lighted fields at night.] How would you communicate the potential direct and indirect health risk to potentially affected children, parents, other participants, and neighbors in a way that is understandable to the average citizen, and is communicated reliably to all affected citizens (not just posted or sent but also received and

9 understood) and in a timely fashion? And even if such a process could be developed, is it conceivable that the County would allow play to proceed if notices of this kind were deemed advisable? The installation of lights themselves could be deemed by ordinary County residents as an affirmation of safety that no warning notice could possibly soften. And, of course, nearby residents would have no choice but to bear whatever risks and costs are inevitably imposed by sports lighting outside their homes. Thank you for evaluating your conclusions based on this additional information. Your conclusions should help the WFWG reach its own fact-based conclusions. I would be happy to meet with you to discuss this if it would be helpful. Sincerely, Roy Gamse