Comment from Richard Cherry

This comment was submitted to the New York State Public Services Commission but is relevant to this petition and the FDA's response to it: Recent Evidence of Additional Damaging Effects of LED Light on Human Health and the Environment 1) Outdoor LED lighting, like street lights, is interfering with microbial systems in the soil, threatening soil functions which are necessary to life: Light from outdoor LEDs reaches deep into the ground, causing what researchers call a “killing affect” on microbes responsible for critical ecosystem services like soil nutrient cycling. Disrupting the nutrient cycle with LED lighting threatens both the food chain in nature and agricultural crop production. Furthermore, LED light’s killing effect on microbes disrupts the soil carbon cycle, disregulating healthy soil’s role in lessening methane and methanol emissions, affecting greenhouse gas emissions and ozone stability, and weakening urban trees, inhibiting their beneficial contributions in maintaining community well-being. Lighting that undermines natural carbon cycling dynamics, and that degrades soil’s ability to sustain food producing plants, can’t rightly be called “climate smart,” ecologically sustainable, or in any way safe or fit for outdoor use. “Artificial light at night triggers negative impacts on nutrient cycling and plant health regulated by soil microbiome in urban ecosystems.” j.Geoderma 2023 Examining Sound, Light and Vibrations as Tools to Manage Microbiomes and Support Holobionts, Ecosystems and Technologies.” j.Microorganisms 2024. n.b. page 17: “the type of light is critical and white LED light is not beneficial for the human microbiome or for health.” “Consequences of Artificial Light at Night (ALAN) on Urban Tree Functioning” j.Nature; Urban Forests, Climate Change and Environmental Pollution n.b. “The findings reveal that ALAN [50 W LED] significantly affected chlorophyll content, stomatal conductance, transpiration, air and leaf temperature, leaf area, and soil moisture. All measured physiological functional traits declined under ALAN compared to control plants.” From the abstract. 2) LED street lighting makes air-pollution worse, increasing public risk of asthma, allergic rhinitis, pulmonary ailments and atopic diseases: Overnight LED lighting destroys air-cleansing nitrate radicals. After sunset, nitrate radicals naturally dispel ground level ozone, a major source of disease-causing particulate matter and a component of smog. This nightly pollutant-cleaning cycle cannot occur in communities which are lit overnight with intense electronic lighting. Increased air pollution in turn makes light pollution worse, setting up a vicious cycle and feedback loop that further deteriorates human and environmental health. “Does Light Pollution Affect Nighttime Ground-Level Ozone Concentrations?” j.Atmosphere MDP1 2022 “The Air-Light Pollution Connection” DarkSky Consulting 2024 “Nighttime Photochemistry: nitrate radical destruction by anthropogenic light sources.” NOAA, CIRES Association of exposure to Artificial Light at Night with Atopic Diseases: a cross-sectional study in college students. International Journal of Hygiene and Environmental Health 2022 We are dismayed that the Commission has not yet acted on overwhelming evidence and clear, consistent reports of LED-induced harm. The solution the petitioners are requesting is simple and straightforward: return to legacy street lighting, which did not cause these problems or generate these complaints. Since the state itself created this crisis of harm and discrimination by the inappropriate and unstudied imposition of damaging lighting on the state’s population, the Commission’s obligation to ensure and protect human health and safety requires the Commission to act immediately.