HomeMy WebLinkAbout10 20 2025 Item 7.4 - Allow Electronic Billboards - Dr Paul LynmanUniversity of California Observatories/Lick Observatory
7281, Mount Hamilton Road,
MOUNT HAMILTON,
CA 95140
17 October 2025
Honorable Mayor and City Council,
Item 7.4. Provide Policy Direction on a Proposed Zoning Ordinance Text Amendment to
Allow Electronic Billboards along State Route 101.
This communication comprises written public comment regarding the above-titled matter before the
Council. This correspondent has been an advocate for dark skies for 40+ years, informing local and
regional authority lighting policies in Europe and North America. The writer holds a degree in astronomy
with applied physics, masters in physics, doctorate in astrophysics and has worked at academic research
institutes and/or observatories in the UK, Germany, Chile and the US for 30+ years — with one
exception: Prior to joining the University of California Observatories/Lick Observatory (UCO/Lick) in
2011, he was affiliated with GroupM, the World’s largest media buying agency1 . For decades, UCO/Lick
has advised local authorities on lighting ordinances, including (in the 1960s and 1970s) the deployment
of sodium lighting, subsequent upgrades to LED2 technologies and, most recently, the deployment of
Electronic Billboards3
The matter of EMCs has repeatedly been brought before Council since at least 2018. Following appeals
from concerned Gilroy residents, UCO/Lick submitted spoken and written contributions to both Council
and Planning Commissioners on this matter between April 2021 and March 2023. A fundamental prob-
lem presently pervading California is that the night sky is not considered an environmental phenomenon
under CEQA4 ’. This, despite the United Nations declaration:
An unpolluted night sky that allows the enjoyment and contemplation of the firmament
should be considered an inalienable right of humankind equivalent to all other environmental,
social, and cultural rights.
By excluding the night sky from its description of ‘the environment’, CEQA is deficient. Hence, it
becomes responsibility of California’s local authorities to ensure the protection of dark skies and public
health. Elected, appointed and staff members from the City of Gilroy have been repeatedly invited to
visit Mount Hamilton to understand the deleterious impact of accelerating light pollution. Not a single
member of Planning staff attended.
1 GroupM is a subsidiary of the World’s largest advertising agency, WPP
2 Light Emitting Diode.
3 These devices can be interchangeably referred to as Electronic Billboards, Digital Billboards and Electronic Message
Centers (EMCs).
4 CEQA: The California Environmental Quality Act.
Since March 2023:
•The aspirations of the City of Gilroy (as expressed in the General Plan) have not changed. The
General Plan demands:
LU 8.7:Minimize any negative impact on the visual environment.
LU 8.13:Limit light pollution from outdoor sources, and direct outdoor lighting downward and
away from sensitive receptors.
There has been no discernable shift from the inherent large-scale revulsion to EMCs among the
majority of the populace.
•The nature, physics, regional trespass and harms of light pollution5 on astronomical endeavours
are unchanged. EMCs disproportionately exacerbate the impacts already being experienced by
Lick Observatory. Adding scattered light to the environment negatively impacts the night sky as
a cultural resource.
•The science regarding the harms of LAN to human health, circadian disruption — and LEDs in
particular — has hardened. LAN causes changes in the environment that have adverse direct or
indirect effects on fauna and flora (e.g. bats, insects, trees) altering our sense of place. LAN is
a hazard to human health and probable carcinogen. Blue light (primarily from LEDs) is toxic for
all life.
It should come as no surprise that UCO/Lick does not endorse EMCs. As in previous contributions,
we present the scientific concencus that has emerged, based on multitudinous, independent, peer-
reviewed studies. These established facts contrast with the largely speculative numbers presented in
the application — a theme that pervaded its previous incarnation. Beware:
The advertising world wields an inexhaustible faculty for gilding every lily.
— Bauby (1997)
Harm to Dark Skies & Astronomical Pursuits
Light pollution is already harming the operation and mission of UCO/Lick. In 1989, of 17 major
US-based observatories, Lick Observatory was ranked among the top 3 most heavily light-polluted
astronomcal sites (Garstang et al. 1989). By 2022, in a list of 23 major observatories worldwide, Lick
Observatory was cited as the most affected astronommical site in visible light (Green et al. 2022; Falchi
et al. 2023). Light pollution trespasses regionally. Metropolitan light impacts astronomical sites up to
200–300 km away (Duriscoe et al. 2018).
The prevalence of light pollution across the industrialized world is accelerating at a rate outpacing
population growth. Over the past 25 years, growth rates of between 49% and 270% have been measured.
For rapidly developing conurbations in the industrialized world (e.g. San Francisco Bay Area) this figure
could be as high as 400%. Some estimates suggest growth rates of 7% to 10% annually (Kyba et al.
2023).
5 Also referred to in academic literature as Anthropogenic Light At Night (ALAN) or simply Light At Night (LAN).
2
The nature of EMCs means that they will have a significant impact on the natural and built environment,
producing glare, light trespass, sky glow and substantially changing the nightscape. The LEDs in
EMCs are not shielded, so the light is emitted in all directions, including flooding into the night sky,
which wastes energy and contributes to light pollution. Light from EMCs can cause glare and be a
dangerous distraction to drivers. In some cases, the light from EMCs can be visible from long distances
and may affect breeding, foraging, and orientation behaviors in nocturnal wildlife.Regardless of the
technology or originating fixture,any and all light sources which interact with the atmosphere
contribute to an additive effect to scattered light, elevating the intensity of the diffuse sky
background.
The foregoing and following discussion directly contradict the false assertion presented in the application:
Per the IS/MND, electronic billboards permitted in accordance with the proposed Zoning
Ordinance text amendment would not have an impact on the work of Lick Observatory
on Mt. Hamilton, as the sign would be limited to a maximum light output level of 0.3
foot-candles at 250 feet from the billboard above ambient conditions. At this lighting level,
light cast beyond 250 feet would not register on a light meter. The Lick Observatory is 25
miles from Gilroy, so its operations will not be impacted by electronic billboards in Gilroy.
At the risk of repetition, independent studies cited above prove that light pollution is already harming
the operation and mission of Lick Observatory. Every additional light source elevates the problem.
Additional scattered light does not simply ‘blend in’ to the pre-existing level of diffuse sky background
light.
Furthermore, EMCs — and particularly the blue-rich LEDs they employ — contribute disproportionately
to light pollution. LEDs combine emission from peaks of intensity across many colors — particularly
blue — thus contaminating the entire visible spectrum, whereas incandescent or discharge (e.g. sodium)
lighting consists of isolated spectral peaks, with adjacent spectral regions free from contamination. In
particular, with few exceptions, practical electric lights prior to LEDs were wholly absent of a blue
component. In contrast,LEDs produce a preponderance of blue light. In large part, sky-glow is a
consequence of the physics of ever-present aerosols (e.g. water vapor, particles, etc.) which redirect, or
scatter light —not exclusively direct illumination.The impact studies presented in the application
are wholly deficient since they neglect any analysis of scattered light. Scattering is responsible
for twilights, renders clear daytime skies as blue and cloudy skies as gray. One of the dominant scattering
processes,Rayleigh scattering, has not simply an additive or multiplicative dependence, but a fourth-
order power law dependence, such that bluer (shorter) wavelengths are much more strongly scattered
than redder (longer) wavelengths.
3
On the ‘Analysis’ Presented in the Application
Because of the fourth-order power law, assertions by proponents that LEDs contribute less to sky-glow
and light trespass are absolutely false. The unquestioning acceptance and propagation of such assertions
undermines the credibility of anyone deploying them. Applying the physics of aerosol scattering to model
sky brightness arising from use of lighting can be enormously complex. As far as can be determined,
the analyses described in the application are solely empirical, using light meters viewing directly along
isolated lines-of-sight to an illuminated surface, across a narrow range of wavelengths (color). The
‘analysis’ presented in the application is misleading. It comprises ‘a sign brightness survey and a
photometric review of the signs that would be permitted in accordance with the proposed Zoning
Ordinance text amendment’. The survey consists of collections of selected (arguably curated) — and
therefore biassed — line-of-sight spot-measurments (in units of candelas per square meter, cd/m2 ) on
the surfaces of existing conventional (i.e.not the closely-packed illuminated picture elements of modern
digital arrays) signs in the City. The analysis erroneously concludes:
‘a digital billboard [typical brightness range between 75–250 cd/m2 ] would provide equal
or less brightness as the existing signs [with some areas of the static signs exceeding 300
cd/m2 by over 300 cd/m2 ] in the City of Gilroy’.
However, nowhere in the analysis are the spot values (per square meter)combined over the area of
the conventional signs studied (e.g. mean, median or any other representative statistical measure).
The dimensions of the signs studied are omitted. Hence, readers are prevented from calculating such
values.Design differences between conventional and proposed signs (e.g.linear density of the individual
illuminated elements) are not accounted for. The analysis is wholly insensitive to concerns regarding
the phenomenon of scattered light. In order to properly account for scattering, analyses should:
•Integrate over all lines-of-sight to the surface(s) within a complete hemisphere surrounding each
surface (i.e. including lines-of-sight above and behind the sign, since some scattering processes
involve back-scattering).
•Intergrate over all wavelengths (colors) of light. Rayleigh scattering, in particular, exhibits not
simply an additive, multiplicative or square law dependence, but a power law (of order 4), such
that shorter (blue) wavelengths are more strongly scattered than longer (red) wavelengths. LEDs
(as proposed in the application)of any vintage introduce a preponderance of blue light compared
with traditional incandescent illumination.
•Sum over the entire surface area of the illuminated surface(s), since the contribution to scattering
is a function of the interaction cross-section between surface and atmosphere and not from a
viewer’s perspective.
The failure of the analysis to grasp those concerns (coupled with biassed measurements along individual,
directly illuminated, lines-of-sight; the omission of basic dimensions and lack of statistical rigour) reveals
a lack of understanding of physical (i.e. Rayleigh scattering) processes, thus demonstrating that no
suitably-qualified person contributed to the analysis. The finding that the ‘existing monument signs
emit as much, if not more, light to the surrounding areas than the proposed electronic billboard signs’
is vacuous.
4
DarkSky Recommendations
It is impractical to shield light from EMCs due to their orientation, so many of the traditional approaches
to reducing the impacts of artificial light at night do not translate to EMCs. As a result, the potential
harm of EMCs cannot be completely mitigated by design alone. Rather, minimizing the harmful effects
of EMCs is best accomplished through careful operation, programming, and location of this technology
to the greatest extent practical.
Ever since our earliest (2021) contributions to the City’s considerations of EMCs, UCO/Lick has con-
sistently advocated for the adoption of the guidance for EMCs compiled by DarkSky International6 .
This technical and scientific guidance, addresses deficiencies in many sign codes (e.g. CEQA) that only
address legacy sign installations, in order to minimize the environmental hazard. The DarkSky guidance:
1.Recommends best practices for the amount of light emitted by electronic billboards and signs
for urban, suburban, and rural areas.
2.(Among other measures) recommends curfews for when signs and billboards should be turned
off, specifically:
EMCs shall be switched off completely after 2300 h (11:00 p.m.) or 30 minutes after
the close of business for on-premises signs, whichever is later, and shall remain off until
one hour before sunrise. EMC applications for traffic and safety information shall be
exempt from Curfew.
3.Identifies best management practices to decrease or eliminate negative impacts on the envi-
ronment, reduce visual clutter and improve safety for drivers and pedestrians.
On 14 March 2023 UCO/Lick noted that for Californian cities that have adopted billboard ordinances,
inspection yields common language, often being ‘in accordance with [sections of] the California Business
and Professions Code, CBPC’. It would be a mistake to assume that the CBPC is a homogeneous,
one-size-fits-all, set of provisions. It contains numerous clauses and exemptions, predominantly in-and-
around Los Angeles. In many contexts, the CBPC establishes regulations7 demand that:
the advertising display is authorized by, or in accordance with, an ordinance [...] adopted by
the City that regulates advertising displays by identifying the specific displays or establishing
regulations that include, at a minimum,all of the following:
(A) Number of signs and total signage area allowed.
(B) Maximum individual signage area.
(C) Minimum sign separation.
(D) Illumination restrictions and regulations, including signage refresh rate, scrolling, and
brightness.
6 DarkSky International (formerly, the International Dark-Sky Association).
7 For example, CBPC Divsion 3. Professions and vocations generally [5000 - 9998.11]; Chapter 2. Advertisers [5200 -
5486]; Article 3. Application of Chapter [5270 - 5275].
5
(E) Illuminated sign hours of operation.
These provisions align both with the DarkSky guidelines to minimize damage to dark skies,and the pleas
of public health researchers to reduce, curb, mitigate or reverse the proliferation of LAN. However, the
appellants’ prescription for Gilroy conspicuously and extraordinarily) excluded such measures throughout
the previous (2021–2023) episode. Despite claiming to have reviewed ‘best practices from other cities
that permit billboard signage’ the analysis contained in the present, renewed, application again neglects
the DarkSky guidance — a continuing omission that could be interpreted as inherent intransigence.
To maintain our ability to carry out top-grade astronomical research, it is neces-
sary that the ALAN affecting observatories is reduced as soon as possible ...[this]
might be the last call for a serious, collective, unambiguous, no-compromise ac-
tion to lower light pollution now.
— Falchi et al. (2023)
Harm to Public Health from Pervasive Light Pollution: ‘Edison’s Cancer Epidemic’.
Light pollution from artificial light is harmful to human health — considered by some ‘the biggest
public health crisis going on right now8 ’. Every major disease is associated to some extent with short
sleep/long light. Sleep disorders are now arguably the most prevalent health concern in the industrialized
world (Bogard 2013, Winter 2017).The consensus that has emerged from over 10,000 peer-
reviewed scientific articles published by over 30,000 scientists cements the conclusion that
light at night is carcinogenic, as well as causing a host of other medical problems. Mammals
are highly sensitive to light at night, which has the power to dramatically, negatively affect circadian
rhythms. Circadian rhythms control aspects of physiology, behavior, metabolism, body temperature,
blood pressure and pineal hormone (e.g. melatonin) secretion. It is the shorter wavelengths of light
(i.e. blue) that most affect melatonin production. LEDs — with their preponderance of blue emission
— are of most concern.
Beginning in 1970s, multitudinous studies have identified links between circadian disruption to behav-
ioral changes,sleep disorders, (e.g. Wang et al. 2022),mental disorders, (mood and anxiety
disorders e.g. Paksarian et al. 2020),diabetes, (e.g. Zheng et al. 2023),depression,obesity,coro-
nary heart disease, (e.g. Muenzel et al. 2020, and references therein), Mild Cognitive Impairment,
MCI (a transitional phase between normal aging and dementia e.g. Chen et al. 2022),dementia and
Cerebrovascular disease (including stroke and other conditions affecting blood flow to the brain e.g. Wu
et al., 2024)stroke.
Circadian disruption, induced by light pollution, is harmful — considered a probable human carcinogen
by WHO9 (Stevens et al. 2011, Bogard 2013). The American Medical Association (AMA) and groups
(e.g. The American Heart Association,heart.org/stroke.org;breatscancer.org; The Sleep
Foundation) advocate for light pollution control efforts for public safety. Hundreds of scientific studies
have shown the association between electric light exposure and cancer, and the biological mechanisms by
8 Clip: Prof. R. Fosbery: Interactions between light & life (21 October 2022) [00:04].
9 The World Health Organization.
6
which it occurs. Electric light has been called ‘the tobacco of breast and prostate cancer’. These
two cancers — along with cancers of the lung, colon and rectum have multiple, well-established
causal pathways between those cancers and light pollution. Modern texts describe the prevalence of
light at night as ‘Edison’s Cancer Epidemic’ (Moore-Ede 2024).
Over the past decade, a concensus has emerged in the academic literature: Light pollution has already
gone too far. ‘Mitigation’ has gradually been expunged from the lexicon. Multi-disciplinary, independent,
peer-reviewed scientific studies are begging:
We advise people, especially those living in urban areas, to consider reducing exposure
[to outdoor artificial light] to protect themselves.
— Jianbing Wang, Ph.D (25 March 2024)10
Harm to Public Health from LEDs: ‘The New Asbestos’
During Council deliberations, in attempting to dispute the links between light and health, a mobile
telephone was brandished aloft:
This is LED light right here, people look at it all day long, they don’t seem to have a
problem with it.
— Council Member Bracco (20 March 2023)
No pleasure is taken in reporting that, on the contrary, the foregoing statement could not be further
from the truth. Even literature reviews cited by those seeking to refute the overwhelming scientific
concensus (e.g. Miller et al. 2024) are unable to reject, refute, invalidate or dismiss the grave concerns
regarding exposure to LEDs. Further high-quality studies are a pressing need. We are now realizing
that blue light is toxic for all life11 ’. Light at night originating from LEDs directly damages cellular
mitochondria via ‘the same process produced by Chernobyl radiation [...] a slow death12 ’.
Public health experts refer to the effect of growing light pollution as ‘21st century scurvy’. LEDs are
described as ‘the New Asbestos13 ’.
We may regret [introducing LED and fluorescent light tubes] due to to health
hazards as well as economic and social costs associated with it, and, therefore, it
should be considered unsustainable.
— Haim & Portnov (2013)
10 American Heart Association/heart.org/stroke.org
11 Clip: Prof. R. Fosbery: Concerns on the impact of life from blue light LEDs (12 May 2022) [00:11].
12 Clip: Prof. R. Fosbery: Interactions between light & life (21 October 2022) [01:15].
13 Clip: Prof. R. Fosbery: Interactions between light & life (21 October 2022) [00:12].
7
Conclusion
City Staff are seeking policy direction from the City Council on a proposed Zoning Ordinance text
amendment to allow electronic billboards along State Route 101. The claimed purposes of the proposed
policy amendment(s) that the application requires are:
1.To provide adequate signage for commercial businesses that have a regional customer base.
2.Establish procedures for the review and approval of electronic billboard(s).
3.Specify development criteria to ensure that the permitting of electronic billboard(s) does not
create visual clutter or create other operational impacts on surrounding uses, or the public health,
safety or general welfare of the City.
To which we respond:
1.Doubts remain whether a multinational outdoor advertising operator is best-suited to cater for
regional buisness the majority of the time,
2.The applicant appears to have no genuine interest in — and continues to evade — the recommen-
dations of best practice from multiple sources (e.g. DarkSky International, California Business
and Professions Code, CBPC) when seeking to contribute to the establishment of procedures for
review and approval. If the policy amendment is to be approved, it should fully incorporate these
recommendations. If the application is to be approved, it should be fully compliant with these
recommendations. Any application should be required to provide an unbiassed analysis, compiled
by suitably-qualified professionals, properly accounting for the physics of scattered light.
3.While assessments of visual clutter can be argued to be subjective, one would hope that decision-
makers would defer to the majority public opinion. However, the scientific concensus is irrefutable:
Light pollution is already harming the operation and mission of Lick Observatory. Additional light
sources elevate those harms — EMCs disproportionately so. Exposure to light at night (LAN) is
harmful to public health and welfare. There is emerging evidence that blue-rich LED light is toxic
to all life.
Serious, collective, unambiguous, no-compromise action to lower light pollution
now.
— Falchi et al. (2023)
Curb the surging light pollution at night.
— Chen et al. (2022)
Reduce artificial light at night.
—Al Nagger & Anil (2016)
Regulations on nighttime advertising [...] and switching off.
— Haim & Portnov (2013)
8
Thankfully, these pleass are being heeded: In nearby communities such as West Marin and Santa
Rosa, citizens have been proactive in demanding DarkSky-compliant lighting ordinances. Similar efforts
are gaining traction at State level (witness the progression of legislation to reduce light pollution14 ).
Already, a number of States ban billboards — of any vintage — outright. The time is coming when
light pollution will be as strictly regulated as noise or air pollution (Ecklof 2023).
Thank you for your attention and service to the community.
Yours faithfully,
Dr Paul D. Lynam FRAS
Astronomer
UCO/Lick Observatory
14 Legislation to reduce light pollution progresses to Senate Committee on Appropriations (4 August 2023).
9
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